EDF Health

EDF considers potential health equity impacts of partial lead service line replacement

Tom Neltner, J.D.Chemicals Policy Director and Lindsay McCormick is a Project Manager.

“LSL replacement initiatives should address barriers to participation so that consumers served by LSLs can benefit equitably, regardless of income, race or ethnicity.”

– A founding principle of the Lead Service Line Replacement Collaborative

States and communities across the country are taking important steps to accelerate replacement of lead service lines (LSLs) – lead pipes connecting the water main under the street to homes and other buildings. As part of this progress, many programs have strictly limited the standard practice of partial LSL replacement – replacing only the portion of the LSL on public property, which commonly arises when rehabilitating the main and reconnecting the existing line. Partial replacement is likely to increase, at least temporarily, lead levels in drinking water in homes and may not reduce lead exposure in the long run.

The default approach for most water utilities rehabilitating their main has been to simply alert property owners to the risk of partial replacement and advise them to hire a contractor to voluntarily replace the remaining portion of the LSL on their property.

Other utilities have rejected this approach and gone further to protect residents. For example, Washington, DC offers to coordinate private side and public side replacement to reduce costs and make participation easier but still expects the property owner to pay for the private side. Others, such as Cincinnati, OH, have required full LSL replacement, providing a significant subsidy to the homeowner and allowing the cost to be spread over ten years through a property tax assessment. Indiana American Water and Philadelphia, PA go even further and pay for the cost of full LSL replacement out of ratepayer or capital improvement funds. States are acting too, with Michigan requiring utilities to pay the cost of replacement on private property and Wisconsin requiring cost sharing. For more examples, see our webpages recognizing communities and states that are leading the way.

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From villages to states, significant progress on lead service line replacement in 2018

Sam Lovell, Project Specialist and Tom Neltner, J.D.Chemicals Policy Director

We recently finished a round of updates to our webpages recognizing states and communities leading the way in efforts to accelerate lead service line (LSL) replacement across the country. As we start the New Year, we wanted to summarize the good news from 2018 and highlight some opportunities for more success.

Ninety-five communities are leading the way on LSL replacement programs:[1]

  • 6 communities have publicly announced that they have completely replaced all known LSLs.
  • 53 communities have publicly set a goal of eliminating LSLs on public and private property, totaling more than 300,000 LSLs. Ten of the communities are in Wisconsin; Indiana has one investor-owned utility, American Water, which operates 27 separate community water systems; Michigan has four communities; Colorado and Ohio have two; and Arkansas, Massachusetts, Pennsylvania and Washington have one.
  • 36 communities are publicly taking steps to replace LSLs but have not yet set a goal of full replacement. One third of these communities are from Wisconsin; seven from Illinois; and five or fewer from New York, Massachusetts, Michigan, Pennsylvania, Rhode Island, Iowa, and Kentucky.

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California Water Board makes misleading claim that only four water systems have lead lines

Tom Neltner, J.D.Chemicals Policy Director

[Update 12/14/18: The California Water Boards added a webpage providing more background for customers on the inventory requirement, including the clarification that “user service line” does not include the service line on private property. This clarification was also added to the Status Map webpage.]

The California Water Board posted the results of its statewide inventory of lead service lines (LSLs) in community water systems (CWSs) yesterday. They also became the first in the nation to post the results in an interactive online map. We are pleased to see the state take this important step, but are disappointed that the press release it sent out to announce the map’s launch undermines its efforts with misleading and confusing statements.

The central problem is that the press release fails to be clear that the inventory does not cover the portion of the service line between the meter and the home or building.  As a result, a CWS that removed all of the lead pipes between the main under the street and the meter but left them on private property was listed as having no LSLs. A customer would justifiably – but mistakenly – assume that LSLs were not an issue in their community.

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Mapping state-level lead service line information: Indiana as a model

Lindsay McCormick, is a Project Manager. Tom Neltner, J.D., is the Chemicals Policy Director.

Developing inventories to document and share what water utilities know – and do not know – about lead service lines (LSLs) with the public is a difficult, but critical, step in creating an effective LSL replacement program.

States can play an important role in collecting estimates of the number of known and potential LSLs for each utility and shaping how that information is communicated to the public. 14 states have surveyed utilities operating community water systems in their state to acquire such information.

States have made this information publicly available through different methods. Some have posted individual utility reports, while others have provided a report summarizing the findings. In analyzing the approaches, we found that no state currently makes the results available in a format that allows the public to easily see the information from multiple utilities.

But in today’s world, people typically expect data to be presented in a visually friendly and digestible format. So as a model, we decided to create a state-level map of LSL information.

Of the 14 states, we found that Indiana has one of the most robust surveys, asking detailed questions about portions of the service line containing lead, information sources checked, and service line ownership on public versus private property.  Further, it has a good response rate for a voluntary survey. While only 57% of systems responded, these systems account for 92% of the service lines in the state – as most non-respondents were primarily smaller community water systems.

EDF acquired a spreadsheet from the Indiana Department of Environmental Management and combined this information with data from EPA’s State Drinking Water Information System (SDWIS) to develop a map of LSLs in Indiana as a model.

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American Water demonstrates strong leadership on lead service line replacement

Tom Neltner, J.D.is Chemicals Policy Director

In a landmark decision on July 25, 2018, the Indiana Utility Regulatory Commission (IURC) approved American Water’s plan to fully replace the lead service lines (LSLs) in the communities served by its Indiana subsidiary over the next 10 to 24 years. This represents the replacement of about 50,000 LSLs across 27 community water systems (CWSs). As we highlighted in our blog on the company’s January 2018 proposal, the plan provides a framework that enables the cost of fully replacing LSLs, whether owned by the utility or by customers, to be shared by its 300,000 customers. As far as we know, this is the first comprehensive, voluntary LSL replacement program developed by an investor-owned utility in the country.

In its plan, American Water cited both long-term health and economic benefits that would be realized from avoiding partial replacements when rehabilitating water mains and laterals. The plan showed that having a single contractor handle the entire line reduces the overall cost by 25 to 30%. It also avoids the likely increased risk of consumer’s exposure to lead when only part of the lead pipe is replaced.

IURC’s approval found the plan “to be reasonable and in the public interest.” Even though the customer will continue to own the service line, American Water will be allowed to add the cost to remove and replace the customer-owned portion to the value of the utility’s property. The increase would be considered an infrastructure improvement cost once the new service line is placed into service.

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Lead service line inventories – Indiana as a good model of a voluntary survey

Tom Neltner, Lindsay McCormick, and Audrey McIntosh

This blog is part of a series focused on how states are handling the essential task of developing inventories of lead service lines (LSLs) and making them public. The first blog identified 14 states that were taking on the issue: 4 with mandatory programs and 10 with voluntary. The second blog described programs in four states that mandate an inventory. In this blog, we highlight Indiana’s 2016 voluntary survey of utilities operating community water systems (CWSs) as a model because it ask utilities to: 1) identify who owns the line and provide the legal basis for that claim; and 2) rate its confidence in its estimates on a 1 to 10 scale. 

We found no other state survey asked about LSL ownership even though it is a central question in determining who is expected to pay for replacement. The Environmental Protection Agency’s (EPA) National Drinking Water Advisory Council (NDWAC) recommended[1] in 2015 that the agency require utilities to provide states this information as part of a revised Lead and Copper Rule (LCR). Unfortunately, 43% of the 781 CWS did not respond to Indiana’s survey, revealing a serious limitation of voluntary surveys.

In January 2016, a month before EPA encouraged states to develop an inventory of LSLs and make it available to the public, the Indiana Department of Environmental Management (IDEM) sent a two-page survey to utilities that operate CWSs in the state asking about drinking water service lines. The agency posted scanned PDF copies of the individual responses online but has not yet released a summary.[2]

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