EDF Health

Selected tag(s): lead service line inventory

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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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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Where are Illinois’ lead pipes? Chicago Water has nearly 60%, and small systems don’t know.

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

Chicago is the epicenter for lead service lines (LSLs) in the United States. In a report submitted to Illinois Environmental Protection Agency (IEPA) in April, Chicago Water reported having 392,614 LSLs – 75% of the total service lines in its water system that serves 2.7 million people living in the city and the city’s 125 suburbs. The number of LSLs is over three times higher than any other city. For additional context, this number represents 58% of the known LSLs in Illinois and 6% of the estimated 6.1 million LSLs in the country.

Chicago Water also reported an additional 120,760 service lines as unknown material that may be lead. Only 7,299 (2%) of its total service lines are made of something other than lead.

These numbers are based on the second year of mandatory reporting that IEPA makes publicly available. Earlier this year, we summarized the first year of reporting. In the second year of reporting, IEPA improved the program by allowing CWSs to separately report lines of unknown material where the utility was confident they were not LSLs – most likely because the lines were installed after the date the CWS stopped allowing use of lead. So the remaining lines of “unknown material” were more likely to be lead. In addition, all community water systems (CWSs) in the state reported in the second year.[1] Given these improvements, we looked more closely at the data.

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Denver Water proposes innovative plan to remove an estimated 75,000 lead service lines in 15 years

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

Update (12/18/19): EPA approved Denver Water’s Lead Reduction Program on December 16, 2019. The utility will start implementing the program in 2020. 

Yesterday, Denver Water’s board approved its proposed “Lead Reduction Program Plan” to fully replace the estimated 75,000 lead service lines (LSLs) in their system within 15 years.  The plan is an innovative solution that will remove the primary source of lead within Denver Water’s system, while avoiding the use of orthophosphate that can further exacerbate nutrient pollution problems in rivers, streams and oceans, an issue EDF’s Ecosystems team is working hard to solve.

As proposed, Denver Water would fund full replacement of LSLs through water rates, bonds and sales of new connections to the system, hydropower production and other sources rather than have individual property owners contribute.  In addition, the utility’s proposal to provide filters to residents until their LSLs are replaced represents a model other communities should consider based on the effectiveness of their ongoing pilot.  Before implementing the plan, Denver Water will need to receive approval from the Environmental Protection Agency (EPA).

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ASDWA releases useful guidance to help states develop lead service line inventories

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

As we have explained in past blogs, it is critical that states have rough estimates of how many lead service lines (LSLs) each drinking water utility in the state may have in order to develop sound policy decisions and set priorities. Congress recognized the importance of LSL inventories when it directed the Environmental Protection Agency (EPA) in the America’s Water Infrastructure Act of 2018 to develop a national count of LSLs on public and private property in the next round of the 2020 Drinking Water Infrastructure Needs Survey. States have a crucial supporting role in the Needs Survey since it is the basis of allocating State Revolving Loan Funds to the states.

This month, the Association of State Drinking Water Administrators (ASDWA) released a useful guidance document to help states develop LSL inventories. The guidance builds on the lessons learned from:

  • Mandatory surveys conducted by California, Illinois, Michigan, and Wisconsin;
  • Voluntary surveys conducted by Indiana, Massachusetts, North Carolina, and Washington; and
  • Responses to requests for updated Lead and Copper Rule (LCR) service line preliminary materials inventories conducted by Alabama, Louisiana, Kansas and Texas.

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EDF analysis: Lead service lines in Illinois communities

Tom Neltner, J.D.Chemicals Policy Director

Building statewide, comprehensive inventories of lead service lines (LSLs) in community water systems (CWSs) is a critical part of any effort to eliminate lead pipes. With a solid inventory, states can conduct a credible needs assessment and engage the public in supporting community efforts to replace LSLs.

In January 2017, the Illinois legislature passed a law designed to reduce children’s exposure to lead in drinking water. It included a requirement that CWSs submit annual reports to Illinois Environmental Protection Agency (IEPA) regarding a “water distribution system material inventory” by April of each year. EDF sees Illinois’s approach to developing an inventory as a model to be considered by other states because it:

  • Requires all CWS to report (unlike Indiana which had a well-designed one-time voluntary survey but only a 57% response);
  • Covers the entire service line (unlike California which ignored the portion of the service line on private property); and
  • Requires annual updates to track progress, especially in reducing the number of service lines with unknown materials (unlike Michigan which requires updates only every five-years).

In August 2018, IEPA released a summary of the first year submissions and has updated it several times. IEPA indicated that 95% of CWSs submitted reports and provided totals of each type of piping material reported with 414,895 LSLs and 1,504,748 of unknown material. At the time, the agency did not provide information on what each CWS reported.

Making totals public is important but does little to engage the public in understanding what the information means for their community. But earlier this week, IEPA published an online tool, which allows residents to search for their water system and download the data for individual reports of the types of materials currently reported by their water system.  EDF also received the information pursuant to a Freedom of Information request. Click here to see the data for all the CWSs in a spreadsheet. We also used an EPA database to identify the 84 CWSs that did not comply with the law.

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