EDF Health

Michigan utilities report much lower percentages of service lines of lead or unknown material than Wisconsin or Illinois

Tom Neltner, J.D. is the Chemicals Policy Director

Note to readers: As we all grapple with the grave global health challenge from COVID-19, we want to acknowledge the essential service that the public health professionals at water utilities provide in delivering safe water not only for drinking but for washing our hands and our surroundings. In the meantime, we are continuing to work towards improved health and environmental protections – including reducing lead in drinking water. We’ll plan to keep sharing developments regarding lead in drinking water that may be useful to you. In the meantime, please stay safe and healthy.

Lead service line (LSL) inventories provide useful insights into the location and number of LSLs in states and the funding needed to fully replace these lines. In previous blogs, we examined mandatory reporting by utilities of service line material in Illinois and Wisconsin.[1] Here, we examined a March 2020 preliminary report by the Michigan Department of Environment, Great Lakes, and Energy (EGLE) summarizing data submitted by 1,029 utilities. Unlike the annual reporting in Illinois and Wisconsin, Michigan required utilities to submit a preliminary inventory by January 1, 2020 and requires a complete inventory before 2025. While the preliminary report allows lines to be designated as unknown, the material must be determined by 2025. This is a two-step process, rather than the annual report approach that California has taken.

Michigan reports less than 100,000 LSLs and 276,000 lines of unknown material that may be lead

The state’s preliminary report is based on 1,029 utilities[2] (74% of the state’s 1,386 total) with 2.40 million service lines (90% of the 2.66 million total).[3] This reporting rate is lower than what Illinois experienced at a similar stage in the first year of mandatory reporting.

For the 1,029 utilities that reported, utilities reported 99,000 (4% of total) lead, 21,000 (0.9%) galvanized steel,[4] 177,000 (7%) of unknown material but likely to be lead, and 276,000 (12%) as unknown with no information. If all of the four categories are actually lead (which is unlikely), there would be 573,000 (23%) LSLs in Michigan.

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The next infrastructure stimulus bill is the right place for lead pipe replacement funding – to create jobs, save money and provide safer water for all

Joanna Slaney, Legislative Director and Tom Neltner, J.D., Chemicals Policy Director.

Note to readers: As we all grapple with the grave global health challenge from COVID-19, we want to acknowledge the essential service that the public health professionals at water utilities provide in delivering safe water not only for drinking but for washing our hands and our surroundings.

During the past few weeks, Congress has taken extraordinary measures to provide much-needed emergency relief to people as we collectively struggle with the COVID-19 crises. Over the coming months, lawmakers have said they will turn their attention to providing funding to stimulate the economy with a focus on water infrastructure as a priority. Lead pipe replacement should be an essential part of that effort.

To guide the Congressional effort, EDF and hundreds of others signed onto U.S. Water Alliance’s COVID-19 Relief and Recovery: Guiding Principles to Secure Our Water Future. The four principles are:

  1. Ensure water is reliable and affordable to all
  2. Strengthen water utilities of all sizes
  3. Close the water access gap
  4. Fuel economic recovery by investing in water systems

In line with of our support for these principles, EDF is advocating that Congress provide $45 billion for water utilities to fully replace lead service lines (LSL) – the lead pipes connecting a home to the water main under the street. Today, there are more than nine million homes still serviced by LSLs in the country, exposing millions of children and adults to the myriad of harms associated with lead. For children, these harms include undermining brain development. In adults, lead has been shown to cause heart disease, cancer, and impact the neurological, reproductive, and immune systems. While there is broad consensus that LSLs must be fully removed to protect public health, funding challenges have stymied progress.

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Latest Wisconsin data on water service lines provides important insights, reveals over 150,000 lead pipes

Tom Neltner, J.D. is the Chemicals Policy Director

Note to readers: As we all grapple with the grave global health challenge from COVID-19, we want to acknowledge the essential service that the public health professionals at water utilities provide in delivering safe water not only for drinking but for washing our hands and our surroundings. In the meantime, we are continuing to work towards improved health and environmental protections – including reducing lead in drinking water. We’ll plan to keep sharing developments regarding lead in drinking water that may be useful to you. In the meantime, please stay safe and healthy.

With the comment period now closed on the Environmental Protection Agency’s proposed revisions to its Lead and Copper Rule (LCR), agency staff are busy reviewing the 687 distinct comments submitted to the docket with a goal of finalizing the rule by the end of the year. To help water professionals plan ahead, the cover article in the March edition of Journal AWWA walks readers through the proposal and its implications. It ends with six suggestions to water systems that include developing a service line material inventory and identifying funding strategies to accelerate full lead service line (LSL) replacement.

With this suggestion in mind, we are continuing our work evaluating state efforts to develop LSL inventories by taking a closer look at reporting by Wisconsin municipal and private water utilities[1] to the state Public Service Commission (PSC) for calendar year 2018.[2] Of the other states with mandatory inventory reporting, we have previously covered Illinois in detail and will evaluate Michigan’s newly released reports soon. The only other state with mandatory reporting is California, but it has limited value because it only covers the portion of the service line owned by the utility and excludes the portion on private property.

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Tightening lead leaching standards for new drinking water fixtures – Opportunity for public comment

Tom Neltner, J.D. is the Chemicals Policy Director

Update: On May 11, 2020, EDF and EWG jointly filed comments to NSF International supporting proposed changes to the NSF/ANSI/CAN 61 Standard.

We have a legacy of lead in our pipes, our paint, and our soil. These are the most significant sources of human lead exposure and, therefore, draw most of the attention and resources because they are costly to fix. It is also important to limit lead from new sources to avoid adding to that environmental burden. For that reason, EDF has sought, as part of our larger efforts, to reduce the amount of lead that leaches from new plumbing devices such as faucets and fountains.

Thanks to the leadership of California Assembly Member Chris Holden, a collaboration with Environmental Working Group, and a productively and collaboratively engaged Plumbing Manufacturers International (PMI), the trade association that represents the manufacturers that provide 90% of the plumbing products sold in the United States, we are seeing real progress from our efforts. We wanted to update you on two parallel, but related, developments:

  • A proposal to revise the current U.S. consensus national standard NSF/ANSI/CAN 61; and
  • California Assembly Bill AB 2060 to revise 116875 of the California Health and Safety Code.

These changes are needed because the current federal limit of 0.25% of lead by weight is insufficient to ensure that lead levels in drinking water are as low as possible, especially during the first few weeks of use before they are conditioned to the water. With these changes, buyers will be able to identify and purchase new devices that should meet the American Academy of Pediatrics recommended action level of one part per billion.

If all goes as anticipated, the more stringent NSF standard will be in place by the end of the year, manufacturers will begin the process of certifying products to the more protective lead limits, and there will be sufficient certified devices on the market in California to meet the anticipated demand from child care centers.

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Every lead service line replaced yields an estimated $22,000 in reduced cardiovascular disease deaths

Tom Neltner, J.D. is the Chemicals Policy Director.

See all blogs in our LCR series.

Using publicly available information from the Environmental Protection Agency (EPA), EDF estimated that fully replacing the 9.3 million lead service lines (LSL) in 11,000 community water systems (CWS)[1] across the country would yield societal benefits of more than $205 billion, or about $22,000 per LSL removed. This estimate is based solely on reducing lead exposure in adults in order to have fewer cardiovascular disease (CVD) deaths over 35 years. It does not include the benefits to children’s brain development.

We submitted our analysis in comments to EPA on its proposed revisions to the Lead and Copper Rule (LCR), the federal regulation that limits lead in drinking water. Given the magnitude of the benefits, we called on the agency to incorporate CVD mortality into its economic analysis and consider strengthening its proposal by requiring full LSL replacement as an integral part of every CWS’s efforts, instead of as a last resort when lead levels get too high.

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A closer look at the environmental justice implications of EPA’s proposed lead in water rule

Tom Neltner, J.D., Chemicals Policy Director, Lindsay McCormick, Program Manager, and Sam Lovell, Project Manager.

See all blogs in our LCR series.

Household-level changes that depend on ability-to-pay will leave low-income households with disproportionately higher health risks.

 

EPA Environmental Justice Analysis of the proposed rule.

Reviewing a rulemaking docket can be intimidating, especially for a major rule like the Environmental Protection Agency’s (EPA) proposed revisions to its Lead and Copper Rule (LCR), which includes 853 supporting documents and tens of thousands of pages. Though we cannot claim to have read all of the documents, we did a targeted scan of key materials, knowing that they often yield insights and results that are lost in the summary that appears in the Federal Register. 

The effort for us paid off when we read EPA’s Environmental Justice (EJ) Analysis of the LCR proposal revisions (the Proposal), commissioned in response to Executive Order 12898. The Order directs agencies to identify and address, “as appropriate, disproportionately high and adverse human health or environmental effects of its programs, policies, and activities on minority populations and low-income populations” in rulemaking. The agency’s contractor essentially found:

  • The current LCR disproportionately impacts low-income and minority populations as they are more likely to live in older housing that has lead service lines (LSLs), the most significant source of lead in drinking water.
  • The Proposal’s corrosion control requirements should help reduce current disparities. Because water treatment is consistent across an entire community, stronger requirements that reduce the ability of lead to leach into water from LSLs, leaded solder, and other sources should mitigate, but not eliminate, the disproportionate burden in homes with LSLs.
  • The Proposal may make disparities worse if it depends on individual household’s ability to pay for LSL replacement (LSLR). The report stated that “Household-level changes that depend on ability-to-pay will leave low-income households with disproportionately higher health risks.”[1]

In the Federal Register notice, EPA glossed over the third point and concluded that the Proposal is “not expected to have disproportionately high and adverse human health or environmental effects on minority populations and low-income populations.”[2] The agency ignores the fact that the Proposal makes no change to the current LCR provisions that rely on a household’s ability to pay when it says water systems are “not required to bear the cost of removal of the portion of the [LSL] it does not own.”[3] We are aware of only a small – but growing – number of communities that have funding options to assist households with the cost of LSLR on private property.

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