The Michigan Municipal League has partnered with the Michigan Townships Association, Southeast Michigan Council of Governments, Great Lakes Water Authority, Detroit Water and Sewerage Department, Oakland County and the Michigan Chapter of the American Water Works Association to develop public comments in response to the draft Lead and Copper Rule recently released by the State. The group has identified many areas of the rule were there is disagreement and attempted to address those issues through our comments.
We have respectfully requested that the drinking water rule revisions not be finalized until the following items are addressed
- The rule reflects the systematic, targeted approach envisioned by both the Infrastructure Commission and the Child Lead Poisoning Elimination Board.
- The Regulatory Impact Statement is revised to accurately reflect total costs,alternatives considered and their comparative benefits, expected costs to property owners with lead service lines, and the necessity to proceed in advance of federal rulemaking the state acknowledges will require more stringent protection from exposure to lead in drinking water.
- The numerous legal issues outlined in the attached memorandum are resolved.
Michigan simply cannot meet the challenges of the 21st century and provide the quality of life fundamental to its success if it continues to confront challenges such as lead poisoning by issuing policy and rules in silos through departments based on their individual, independent areas of authority. By definition, the problem transcends the responsibilities of individual organizations and departments. So the solution must also transcend these boundaries.
Please click on the following link to view the comments that will be submitted.
Please feel free to support these comments through letters of support or use them to formulate your own. Public comments are due by 5:00 P.M. on March 21st and can be submitted to DEQ-LCR-Comments@michigan.gov.
John LaMacchia is the Assistant Director of State and Federal Affairs for the League handling transportation, infrastructure, energy and environment issues. He can be reached at firstname.lastname@example.org or 517-908-0303.