Virtual Public Listening Sessions on EPA's draft Lead Strategy to Reduce Lead Exposures and Disparities in U.S. Communities Docket ID: EPA-HQ-OLEM-2021-0762 R2 Public Listening Session  Date: February 10, 2022 Start Time: 6:00 PM ET Record of Public Comments (To view a recording of the listening session, please visit: https://youtu.be/u6SlyYkVBVQ?t=265)

25:05 [Matthew Chachere, Northern Manhattan Improvement Corporation] I've decided that I'm going to submit my comments in writing because of the abbreviated nature of the time here. 25:18 But I wanted to just make two remarks, number one. 25:23 My congratulations to Lisa Garcia who I've known for many years, from working with her in the past on this issue, and I'm looking forward to her leadership in Region 2. 25:35 And number two, I'm , as  someone who's been working in this field for about three decades now. 25:43 The problem remains that primary source of lead poisoning 25:51 for children is hazardous conditions in their homes, and the unfortunate reality is that in most of this country and certainly most of region two, there was actually no requirement under local laws, state laws or federal laws that poor tenants in dangerous 26:13 Housing/homes be made safe. There is none, none at all. 26:21 No matter what the standards are whether we set the limits at 40 micrograms per square foot of dust or 10 or five, or two, or one. 26:30 If you're a poor family in rental housing with hazardous conditions 26:36 You have no right necessarily under the law to call someone and say that needs to be corrected. And that's the fundamental flaw that we've been dealing with ever since title 10 was passed 30 years ago. 26:52 And until we address that, and I realize this may be way beyond the scope of regulation. 26:57 We're going to continue to be counting the number of lead poisoned children. Each year, and wondering why the problem persists and the problem persists because there's no actual regulations that require slumlords to do anything. 27:12 Period. 27:13 I'm a legal services attorney. And I can tell you that, that if I was representing somebody in most of this jurisdiction and they had a hazardous lead paint condition, there would be no remedy for that, unless their child was overly lead poisoned. 27:28 Thank you. 27:30 And I will as I said I will be submitting written comments, which will be much more detailed. 29:11 [Amy Goldsmith, Clean Water Action and Clean Water Fund] So, my name is Amy Goldsmith I'm with Clean Water Action and Clean Water Fund, we're a national organization with over a million members across the country, our, our name clean water action comes from our founder who helped write the original Clean Water 29:28 Act, hence our name Clean Water Action, and we've been very involved in a variety of different fronts around lead, lead poisoning whether it's lead in soil,  lead in water, and lead in paint and clean interactions very concerned about making sure as was 29:46 stated earlier that we have healthy homes holistically, have healthy homes, and whether it's paint or water or soil, and I know from work that I've done in Camden around soil that, you know, kids are playing underneath, bridges, that had lead paint, you 30:07 know put on the bridges that are all flaking off, and no one really understands what that impact is in addition to all the work that's been done on paint and, and on water. 30:22 Regarding water, 30:26 the, you know, the youngest children the infants who are still on infant formula and pregnant women get the biggest dose of lead from water. And then, as kids start you know toddling around then you end up with paint and dust and other things. 30:46 So, we think that you know it's critically important that one we do the assessments of buildings in New Jersey we know are the drinking water utilities are required  to do lead service line inventories and they're required in next week, or the by the 31:07 22nd to inform people of lead service lines, I have a lead service line, I know I do. 31:13 And I'm interested in finding out if I'll actually get a notification about it. 31:19 So one is you know, knowing that you have a problem and then getting to the remedy and tomorrow. 31:25 Vice President Kamala Harris is coming to Newark to talk about the success of Newark, in that it was able to mobilize enough dollars to go in and remediate, you know lead service lines over 20,000 of them in less than three years, and they trained people 31:45 who had not been trained in the past or not been employed in the past to work side by side with the contractors to do that work to then put them on a career path for the future. 31:58 So I think what we need to do is one, we know we have lead problems, two make sure that we not just assess it but we put the dollars together, and there are many more dollars available now with build back better and other things and make sure that we actually 32:16 train people in the community, to do the work to get to the remedies that we seek. 32:23 I'll submit some additional comments at a later time. Thank you. 34:02 [Rob Hayes, Environmental Advocates, NY] Well, good evening everyone, my name is Rob Hayes, I'm the director of Clean Water for Environmental Advocates New York, EANY is a statewide nonprofit organization based in Albany and committed to advancing state level policies that further environmental 34:17 justice and protect public health, and I'll be speaking today specifically about the issue of lead service lines and lead in drinking water. 34:25 First I just want to convey the scale of the lead service line problem here in New York State. 34:30 There are an estimated 360,000 lead service lines across the state of New York. 34:37 You know almost all of our cities are older cities industrial cities, and there are huge numbers of these pipes still delivering water to people's homes. 34:45 New York City for example has an estimated, 130,000, of these pipes with another 220,000 that are unknown material and could very well be lead, and we're already seeing contamination being caused by these pipes in New York State and have for a long time. 35:02 Recent lead action level exceedances have happened in cities like Newburgh and Ilion and Amsterdam reinforcing you know what we all already know to be true, which is that, lead in drinking water is most impacting low and community, low income communities 35:17 and communities of color. 35:19 And it's so it's because of the scale of this crisis that we were really excited to see the $15 billion commitment to lead service line replacement in the bipartisan infrastructure bill, even though we know that money isn't enough to eliminate all the 35:33 lead pipes, still buried underground. And there are three ways in which we hope that EPA's lead strategy document will provide more details on how that funding is going to be implemented, because just sending out the funding is not enough the details 35:48 really matter to make sure that we're fully protecting health and prioritizing the communities that have been most harmed by the lead poisoning crisis with this funding. 35:56 So first we want to make sure that this funding is not allowed to be used for partial lead service line replacements, which are very dangerous procedures to make drinking water more dangerous. 36:06 There, there should be a complete prohibition on partials, when using this funding. 36:11 There should also be a requirement that any costs of a replacement with a lead service line using this funding, none of those costs should fall under on to the homeowner, you know someone struggling to pay their grocery bills or their electric bills  36:24 can't afford to pay a couple thousand dollars to replace perhaps a half of a pipe that they own coming into their home. 36:31 And finally, we want to make sure that all the money that's been set aside 49% of these lead pipe replacement funds, those funds should be directed to disadvantaged and environmental justice communities, it's so important that EPA clarifies that that is 36:45 is the case and in their guidance to states, because those are the communities, whose pipes need to get dug up first and are the ones least able to take on debt from loans and other things like that. 36:57 So I see I'm running out of time, but I think that covers it for me. So thanks again for the time. 37:30 [Joan Matthews, NRDC] Hi everybody I'm Joan Leary Matthews director of urban water and senior attorney at the Natural Resources Defense Council. I am also a former water division director at EPA Region 2. NRDC has long been dedicated in its advocacy to remove lead from the 37:47 environment in the 1970s NRDC waged a years long battle to remove lead from gasoline. Since then we have continued to fight for the removal of lead from consumer products, homes and environment. 38:01 We have particularly focused on lead in drinking water, both from lead service lines serving homes and from drinking water taps in schools. On October, 28 2021, EPA announced a whole of government strategy intended to curb exposure to lead found in contaminated 38:18 water, paint, air and soil, with a focus on children and communities at high risk their response to a lawsuit filed by NRDC and others. The Biden EPA also committed to announced by December 16 2021, the actions that it will take to address lead in drinking 38:37 water. 38:38 NRDC, states, and others sued to block the weak Trump federal drinking water regulation, as it left, millions of people exposed to toxic lead in drinking water 38:50 in many cases for another 33 years or more. 38:54 In our view, the US should have a whole of government strategy, including an effective lead and copper rule  to remove lead from the environment, because the stakes are so high, lead robs children of their future, especially children of color who live 39:09 in poverty, more than a century ago science established that lead can cause devastating health harm. Yet today children drink water contaminated by lead. 39:20 They inhale lead emitted into the air from industrial processes and airplanes and they play in lead laden homes and soil. We believe that an effective cross government lead strategy will require tougher standards vigorous enforcement clear deadlines for 39:37 action, and an unrelenting commitment to equity and justice for communities that bear the undue burden of lead contamination. 39:45 While we appreciate the need to develop the strategy. 39:48 The lead strategy that EPA released falls short of what needs to be done. It fails to outline specific actions EPA will take to address drinking water contaminated by lead, and it should explicitly commit to promptly fixing the lead and copper rule and 40:05 fully eliminate all lead service lines within 10 years, consistent with President Biden, and Vice President Harris's promises. 40:14 The fight is not over and the removal of lead from drinking water NRDC estimates that there could be up to 13 million lead service lines delivering water to homes in the US, and we know that our children are drinking water from school taps that contain 40:29 lead. So thank you for this opportunity to comment tonight. 41:20 [Jeanne Fox, Columbia SIPA] I just wanted to talk briefly I'm really thrilled the EPA is doing this as a priority, or actually first congratulate my friend Ms. Lisa Garcia as being the Regional Administrator. 41:32 She was the best choice for this job as the first Puerto Rican who finally has the RA position and she well deserved it she's excellent. 41:40 I also want to mention back in the 90s under Clinton, there was a DEP in New Jersey, lead paint, remediation was a huge priority and in New Jersey we passed a law that taxed paint. 41:54 So that, that tax could be used for lead paint remediation. 41:58 There's obviously clearly some significant problems still existing. I would suggest that you might want to take a whole home approach or building an approach, especially where children live to deal with the lead paint issue which is just critical because that 42:14 little fingers are always eating whatever around on their fingers, as well as for the lead pipes. 42:22 It's just horrible that we've known all these years that the children are impacted so dramatically by lead, and yet we still have the situation there, I would suggest maybe other places could do paint taxes as well. 42:35 I also suggest when, when homes are sold. 42:40 In addition, every state in addition to looking at asbestos, they also need to look at the pipes, as well as lead paint so they could be remediated. 42:51 And then finally I would suggest that, as was mentioned by the gentleman from New York who went first something needs to be done about rentals. And it could be that a home can't be again rented unless there are tests and quite possibly remediation, 43:10 that's probably something that's done on a state by state level but if EPA could do it through the regulations, or even for best practices. I think that would make a whole heck of a lot of sense and recommend the states what they could be doing what are 43:25 the best practices. Thank you. 45:25 [Ruth Ann Norton, Green & Health Homes Initiative] So I'm Ruth Ann Norton I'm the president and CEO of the green and healthy homes initiative we are committed to addressing the social determinants of health opportunity and racial equity by creating healthy lead free, an energy efficient housing, but at 45:42 the core of our mission is the eradication of lead poisoning from all sources I also serve as the chair of the Maryland lead poisoning prevention commission, you will be receiving extensive comments from us in writing. 45:59 So I will be very brief tonight. 46:02 But I want to first commend the EPA for the extensive process of putting this into the public for comment, encourage you to continue to dig deep into communities that are often not heard from and who have been disenfranchised in understanding the barriers 46:21 and need, but I want to echo a couple of things you've heard, I want to put some things out for thought. And then we will follow up in a written piece. 46:33 As you think about the whole of government. We will not end the toxic legacy of lead in the United States without a whole of government approach. So I urge Administrator  Regan and EPA to encourage a reconstitution of an interagency working group 46:55 group on lead and healthy housing, that is robust, public and transparent. 47:02 I do believe that the White House should appoint a person, Special Advisor to oversee and push forward, a complex series of inter agency, work that is necessary to address, lead in housing in water, soil, products across the board. 47:28 I think that we need to resolve the EPA and HUD enforcement provisions to ensure subpoena power across agencies alignment is critical here, and I think that one of the things that EPA could do to advance its own complexities that it's asking to move 47:49 on lead is to fund the ability for mayor's, Governor's, county executives to complete asset and gap analyses of needs in community to ensure that monies are directed at the most under resourced and disenfranchised communities that have suffered most, and 48:12 to have a set of measurements on not only closing the health disparities and the actions and outputs, but on actual racial equity, including workforce capacity building and measures to encourage the ownership of companies assessment, contracting and otherwise, 48:35 that the community owned and community lead. 48:39 We asked EPA to join in the interagency effort to ensure the federal government does not continue to sell homes that are leaded and on disclosure to move from disclosure to disclosure and environmental remediation for pipes, paint and soil in a re-look 49:01 at Title 10, and to ensure that for standards that we are striving for leaded water, and other sources that we uphold of the action of the CDC child. 49:17 Lead Advisory Council. That was adopted to have no safe level of lead to set standards at zero provide the capacity and support through all of your grant programs to be targeted at zero level of acceptability, and I will leave the rest to our comments 49:43 in written form and appreciate the opportunity to advance Workforce through Justice40, and racial equity, and the elimination of the toxic legacy of lead through funding community driven and community based efforts. 50:02 Thank you. 52:14 [Maricela Ureno, Columbia University Center for Children's Environmental Health] Okay, so yes I'm with the Center of Columbia, the Center for Children's Environmental Health, and my role is really to disseminate the research that gets conducted there. 52:28 We did a community needs assessment last year with communities we serve, which is the South Bronx, Harlem, and Washington Heights and of all the topics that we covered on environmental health and justice lead still our community advisors stakeholder board, 52:45 when they reviewed these findings they said well we still want to address lead we can't believe there's still these issues with lead. So it's just really sort of just thank you, because the timing of your work, and that our community wants to focus on 52:58 this and be involved in this, they were all invited to attend your meeting, I will share the information with them that we gather here, but just thinking back of two things I'd also worked at a Head Start program for over 10 years as the health coordinator 53:11 and my role was to make sure those babies got their lead tests at 12 and 24 months which is so critical and the great thing about the headstart programs is that they, you know, it is required, but I think it's such an important requirement that should 53:25 happen across the board, and in other ways that we could reach the youngest children that are most at risk. Because if you don't go to a Head Start program well maybe it doesn't get done right just as many families would come to me, and the doctor, you 53:38 know they just do an oral assessment and not a blood test but since we had to be so pesky about it, we, you know, talk to the parents and send them back and call the clinics and do all the follow up, that was needed. 53:50 So I think that's just a really important place to not forget how powerful that is, and that maybe it can get extended to other kinds of programs that serve young children, and , Oh yes, the other thing, when we were doing our needs assessment. We had some members from NYCHA and one of the things they said is that yes we see that in New York there's still a lot of problems with lead especially in NYCHA housing, government housing, even  54:17 other, of course not just NYCHA as people ever have already mentioned, the housing issue and lead. 54:24 But they said one of the big problems is that the quality of materials that is used is so poor that yeah they'll go and they'll paint your house or they'll fix a hole but you know you turn around in two months and, you know, the compound that they put 54:37 just didn't hold up the paint is peeling again so that there should really be some standards of the quality of materials to be used. And I'm also aware that we have our, you know in New York, we have, you know, the standards for contractors and people 54:53 that make repairs that they have to have this lead training, well they'll have the lead training which is wonderful, but how do these things get enforced and how and to again help families, you know, reach and make contact. 55:07 You know the city agencies to help enforce. 55:10 When these construction projects are occurring, so that safety issues can be taken. 55:16 So that's it, thank you so much i love the timer. Thank you, 67:26 [Oceanna Fair, Families for Lead Freedom Now] Hi, my name is Oceanna Fair, and I'm from Syracuse, New York where I am part of a group called Families for Lead Freedom Now. We're a group of directly affected families of lead poisoning for my family lead poisoning  has now become generational so this is 67:41 an important matter to us. If the EPA is going to be successful at reducing the disparities and lead poisoning along racial, ethnic, and social economic lines then we need to bring the US Department of Housing and Urban Development into the picture, the 67:58 HUD lead remediation and the abatement grants in our area in Onondaga county Syracuse, New York, do not come with an easily accessible mechanism for  transparency, which communities are being reached, who was being missed. 68:14 How long is the HUD remediation work holding up? 68:17 These and other questions are unanswered in our area, but are important for creating any hope of focusing HUD funds  on reducing disparities and lead poisoning rates. 68:28 I will give you a prime example of that. My home was remediated for lead in the beginning of 2020, January, to be exact. Our porch was painted in upstate New York, in the middle of January. 68:40 That paint peeled within a week of the contractor putting it down, yet the inspector for the county signed off on that. 68:51 It has, we have complained about it they sent the contractor back out again in April of 2020 to repaint the porch completely pulled up again, I cannot pass my inspection with the health department or the lead, which have poisoned my granddaughter. 69:07 Here we are in February of 2022, and I am just now getting on Onondaga county to agree to come back out and do something to remedy the porch. 69:19 The work isn't holding up in our area. The city of Syracuse has 90% of the lead poisoning and in Onondaga  county in those zip codes that have that lead poisoning. 69:34 It is predominantly black and brown children, families need to be a part of the solution. And the EPA should be meeting with us to figure out what that is we are on the front line of it every day. 69:45 As I said, it is generational for my family now I have a 42 year old brother, who has been lead poisoned and relies on us for everything. And now I have a granddaughter, and a grandson who have been lead poisoned in the same six block radius of where 70:00 my brother was lead poisoned. 70:02 So after 42 years, we're still dealing with this problem. 70:08 I would ask that the EPA meet with families for lead freedom now and talk about some of the solutions that we can put in place to make that happen. 70:17 Thank you. 70:37 [Darlene Medley, Families for Lead Freedom Now] Good evening, everyone. My name is Darlene Medley. I'm a member as well of Families for Lead Freedom Now as Oceanna 70:45 Just stated. I'm going to back everything that Oceanna just said, I just am, going to give my two cents as well. 70:53  Here in Syracuse, New York, we deal with a lot of what we would call slumlords who do not take care of their properties, unfortunately, so it's left on a tenant, and a lot of times, the tenants are already struggling to make ends meet. 71:13 So I've never understood why there has not been some form of a program where a tenant is able to go and for simple repairs such as paint, a tenant should not have to pay for paint but we look at this landlord. 71:28 He's already on the list as a slumlord, he doesn't do what he needs to do with his properties. Why can a tenant not go to a certain home repair store and be able to get maybe that paint that they may need to paint their house, or even including I see 71:43 there are a lot of trainings going on, things of that nature start including people that have really been and truly been affected by leadin those trainings, to be able to go ahead and back certified individuals because those people that have been affected 71:58 by lead are going to be able to know a little bit more than those who are just walking around because they're certified if you understand what I'm saying, you know, they're, they're going to know like how the person who just said something about the paint 72:14 being cheap and then peeling, when they when they said that like that really touched me because today as I was in my home when my kids were at school, cleaning my walls, 72:22 I'm, you know, wiping the wall just a regular household dish cloth.  andnext thing you know the paint starts chipping and I get a little nervous because I'm like, do I keep wiping the wall, or do I stop because it's chipping, you know, so it kind of leaves 72:37 you like in a state or puts you in a state of depression and everything because you don't know what you're supposed to do when there's no hope for you especially you being a tenant. 72:47 I have two children that was affected by lead due to them being a set of twins. And it's just so disheartening to just watch them just go through what they're going through. 72:57 And I'm, you know you as a parent you feel like it's your fault because your supposed tod protect your most valuable possessions which are your children, and you're crying out for help but unfortunately here I know we live at like we've been crying for some 73:11 time and we are just making bare minimum strides which is really sad because we shouldn't be here but unfortunately this is where we are today so I'm just hoping you know with everything that spotlight finally being put on lead things like that that real 73:27 stuff for real people is going to start happening not just for landlords or higher up people and things of that nature, like, Don't forget the little people, the little people  that are still left like the same house that was poisoning our children when they 73:38 two, and now they're about to have their sixth birthday in the same house that they were poisoned by this is what this is where I am right now, still in the same position in the same predicament afraid to really do anything but knowing that the same time, 73:52 I have to do something because these are my children. So even though the landlord doesn't want to come repair anything. 73:57 I have to figure out something and do something to be able to go ahead and make these repairs or else now. 74:02 I'm going to be dealing with a whole new situation and probably even worse now, because now it's like a double whammy. 74:08 So you know that's what I'm hoping will happen is that the little people us, you know that really can't afford it will really get looked after and really get thought about this time. 74:43 [Anabel Cole, Community center for Children's Environmental Health] So my name is Anabel Cole, I work also with the Columbia Center for Children's Environmental Health. 74:49 I wanted to speak on a personal note, right. Um, I think that there needs to be standards, not just for the quality of the lead remediation as prior speakers have said and just hearing a family speak it's just heartbreaking. 75:02 Um, but, so standards, not just for the quality of the lead work that's happening, but protections in place while the work is happening. So in New York City, where I'm from, unscrupulous landlords they, they cut corners, when making repairs, they hire contractors that are not trained in lead remediation work or the safety precautions that need to be in place while the work is being done and the cleanup that needs to happen after the work is done. And I consider myself someone with well resources and connections and information and I  75:36 was in that situation, personally, and really felt like there was, I was powerless to really do anything I had my three year old in the apartment while they were doingscraping, 75:47 I guess the super came up himself and did scrape a wall that we knew had lead paint, dry scraped it dust all over the floor, no plastic put in place. 75:59 All kinds of sort of violations, and I knew they were there was nothing that I could do in the moment. And then they left all the lead dust all over the place without cleaning it and like the prior speaker. 76:12 I had to lock my son up in a room and try to find ways to, you know wet mop. 76:20 You know from the floor, from the highest counters down to the floor, you know, to really just try to get rid of that. 76:30 So that's just to say you know I think that there needs to be. And there are regulations that are in place that they are just not being enforced and so how do we make landlords that are looking to cut corners, especially in older buildings, responsible 76:45 for that work. 76:48 So that's one. And second, I just wanted to say that I think that it's so important to include youth and youth leadership in this process because one children are the most affected but I think that having youth, learn about this early on in schools to 77:05 their curriculums. 77:08 You know they can easily bring information back to their families and really help you know promote enforcement of some of these rules that are in place that are not that it's not happening. 77:20 So, thank you so much. 78:18 [Kathy Basile, Private Citizen] Hi, my name is Kathy. I'm a public health nurse and I work in Northwestern NJ. 78:30 And my heart really goes out to Oceanna for, you know, having the problems that she's had and having them as generational problem. But first I just wanted to say that I think that whatever the EPA is doing. 78:47 As far as trying to get this together you. The homeowner accountability is key here, and also for those that own rentals as Matthew said earlier, pose a major problem that need to be addressed. 79:03 Whether it's through, through taxing people citing people but that work has to be done. And they have to be more actionable in our community. 79:15 I also would like to ask the EPA to definitely include in the discussion as Ms. Cole has just mentioned, to include youth leaders. I also want to be sure that you include public health nurses in the discussions because public health nurses are on the front 79:40 line of a  lot of this, we go in the home and screening, we do screening at clinics. And one of the outreach items that we had done in Morris County was to outreach to pregnant women through the WIC program. 79:57 And I know a lot of public health nurses do that. 80:01 We want to get people 80:03 armed with information before they actually become mothers, you know, in real life. I know  they're mothers already but also the information is very important to them but not only that the resources that people need to know what is their recourse. 80:23 For example, if they need to speak to the local health department or county health department, about what to do what comes next. You know why is my kid exposed to this, and legal services I know in New Jersey we have legal services of New Jersey, and 80:40 they work with people that don't have resources to pay and fundupon 80:48 these kinds of issues. 80:49 And I also think that the science educators in school should be talking about lead, like when they go over things, there should be some type of classes that lead is addressed as the previous speaker just said. 81:06 So thank you very much for your time and I really appreciate the opportunity to speak with you. 82:04 [Shereyl Snider, Private Citizen] Hi I'm Shereyl Snider. And I just want to say thank you again, EPA because I live here in Trenton, New Jersey. 82:13 And I know in Trenton, we have a big issue with  lead. I mean we're legacy lead city, there's 82:28 high exceedances of lead levels in our soil. We have old lead service lines running in our streets, into our homes in some homes, the pipes of lead are all the way throughout the house. 82:44 so it's like we can't wait for everything to trickle down to us to help us, and I'm sorry about the ladies in New York. I live in New York, I lived in Brooklyn lived in Queens. 83:00 I had no idea that the lead levels were so bad upstate New York I didn't have, I have no idea that you guys was dealing with these issues. But here in Trenton and dealing with these issues. 83:15 I'm, I'm an organizer and I am so happy to have a community center. The East Trenton Collaborative that's working with other organizations to to advocate the get the residents to advocate for lead safe communities. 83:34 And because the residents don't know what's happening. They don't know when they see people in the street and they're digging up the street or making a whole bunch of noise. 83:45 All they want is the noise the stop they don't care what's happening. And this is happening to make their home safe and partial line replacements is where you could just change some of the lead minds. 83:59 That's public, and then on the customer side, you gotta pay. It's crazy. It's they want the customers to pay $1,000 to have their lead service lines replaced. 84:13 We want our residents to start advocating to our city to our county. 84:20 No customer cost share, you know, get these lead lines out of here. Just get it done don't charge the residents any money they are paying high taxes as it is. 84:34 And another thing we have to push for ordinances, people are not letting you just come in their home. But if we have a right to come in a home because we want to change these lines, then we can get more work done. 84:47 Those are the comments I just wanted to make. Thank you. 85:31 [John Adams, Private Citizen] Well, first off, my name is John Adams I do want to say thank you to the EPA, and particularly those in the region two administration for putting this together. 85:41 I think this type of format and being able to talk to people at all levels and all structures and strata of life is much more attainable when you do things in the evening when many working people are able to be able to come up comment and interact with 85:57 you. 85:59 My background is you know I had about a decade of work doing childhood lead poisoning primary prevention work in upstate New York, around the City of Utica. 86:08 I'm currently working as a Utica-Oneida County 86:11 GHHI site outcome broker, trying to create a braided funding model using lead hazard control monies ASG home dollars, NYSERDA  empower money Weatherization Assistance Program and so forth. 86:26 But what I wanted to really focus on for the EPA was just two things. 86:31 The realization that the laws and the regulations in the structure that in the in the infrastructure and the  you know regulatory system and ecosystem they created is, is very tight is very good. 86:46 But where it's really sincerely lacking, particularly for the 13 or 14 states in this country that have not adopted RRP policies thereby and allowing themselves to internally enforce this are for those states, particularly as you heard from people in Syracuse 87:01 and hearing from me in Utica. The state of New York has not adopted RRP Policies 87:07 And when I think of the EPA rules as good as they are in a place like New York State. It's really like having a cop who can issue speeding tickets but not having a court, so behavior is not going to change it all, you can hand out tickets to people going 50 in 87:21 a 30 day all day long, and if they know there's no court and there's no enforcement mechanism and people are not going to leave Edison, New Jersey except now to maybe visit three upstate counties in New York on an annual basis. They see through it, you know, the EPA has got 87:36  to fund the enforcement mechanism, there has to be a stick to it, the carrot is good, the carrot is great, I love the EPA and HUD are closer and closer to aligning their standards, quicker than ever. 87:50 You know reminds me of a time, not too long ago when the FBI and the CIA began communicating better and better after an event back in 2001, and their ability became much more effective because of that communication that coordination. 88:02 I would love to see the EPA do that with HUD. 88:05 You know, the whole of government approach is absolutely necessary tightening the dust standards as always a great way to go. And the last thing I'll say on my comment is that while I know the intent of dust standard was never meant to be a screening tool, 88:21 It was always meant to be a clearance post remediation kind of endeavor. 88:26 The dust screening and the front end of the use of dust wipes and the standards set for dust wipes has in  practice become one of the most pragmatic cheapest ways for hard pressed resource depleted health departments around this country with major 88:41 lead issues to be able to screen with them. So I hope that the EPA understands the value of their dustsystem. I hope they understand how great their system is 88:49 But the real tweaking needs to be an understanding that people understand they can drive as fast as they want. Because, even if they, you know, there are not a lot of cops on the road and if they do get a ticket, you know you don't hear about them going 89:00 to court and it doesn't come back down, you know the media that way to us. So, thank you very much for everything you're doing, we're we're plugging away, we support everything you do. 89:09 We look forward to finding out how you're going to help us get more of this hard work finished. thank you very much.