Tom Neltner, Chemicals Policy Director
The Cincinnati City Council has voted unanimously to authorize Greater Cincinnati Water Works (GCWW) to pay 100% of the cost of replacing private lead service lines (LSLs) that bring drinking water to customers’ homes and other buildings. The Council’s December vote supports its larger strategy to “provide quality healthy housing for all income levels.” More broadly, the action is the latest act of leadership from the city as it works to address the environmental justice issues in its communities.
The ordinance gives GCWW the authority to help more customers pay to fully replace LSLs as the utility conducts infrastructure work on drinking water mains that connect to the lead pipes. Since 2017, the utility has subsidized up to 40% of a customer’s replacement cost through grants, and allowed customers to take a 10-year, interest-free loan.
Despite these incentives, the utility recognized that the cost of replacement was an obstacle for many customers, especially for low-income residents. About 60% of customers declined to participate, leaving them with partial LSL replacements that left lead pipes on private property in place. These partial replacements create higher short-term spikes in lead levels in drinking water and do not reliably reduce the risk of lead exposure over the long-term, as full replacement does. This is an important step for Cincinnati, as it ends LSL replacement practices that force customers to share in the costs that can lead to environmental justice and civil rights issues.
While we have not seen demographic information on who did and did not participant in Cincinnati’s loan program, a peer reviewed case study of Washington, DC conducted by American University ‒ with assistance from EDF and the city’s utility ‒ found that “household income is a major predictor of full replacement prevalence, with race also showing significance in some analyses.” Because of redlining and historical underinvestment in neighborhoods predominantly comprised of people of color, race and income are correlated in many cities, including Cincinnati.
Like utilities in Denver CO, Newark NJ, and Washington, DC, Cincinnati has shown a willingness to be innovative to address these issues. GCWW and the city of Cincinnati’s decision to fully fund LSL replacement is just the latest example of their leadership. Specifically, they:
- Launched an on-line interactive map in 2016 to help the public know whether a property may have an LSL. While these maps have become more common, GCWW was one of the first.
- Adopted ordinances in 2017 that:
- Authorized GCWW to give notice to property owners demanding that they remove LSLs on their property when given notice. The utility has opted to hold off exercising this authority due to funding and equity reasons.
- Mandated landlords to disclose the presence of LSLs to prospective tenants based on the map on GCWW’s webpage.
- Cooperated with the National Institute for Occupational Safety and Health in 2020 on a health hazard evaluation to identify lead exposure risks to workers conducting LSL replacements. The report provided recommendations for best practices that all utilities should adopt.
- Over five years, steadily drove down the cost of replacing private LSLs as GCWW ramped up its efforts and got more experienced. According to GCWW, the FY18 cost to replace the LSL on private property was $5,604. The cost is now $2,375 – less than half.
- Applied for and received almost $10 million in State Revolving Loan Funds from Ohio EPA in 2021 to replace four drinking water mains and included funds to replace more than 350 LSLs associated with those mains.
We anticipate that GCWW will be able to dramatically accelerate its efforts by making use of Ohio’s share of the $15 billion dedicated to supporting LSL replacement from the bipartisan Infrastructure Investment and Jobs Act enacted in November. Last month the Biden Administration noted that the US Environmental Protection Agency (EPA) had already released funds to states and is pushing them to prioritize environmental justice investments. We continue to urge Congress to pass pending legislation providing an additional $9 billion to support leaders like Cincinnati accelerate full LSL replacement even more.
We encourage GCWW to leverage the new funding and set a goal of completely eliminating LSLs within five years, and no more than ten. The city of Newark New Jersey has shown it can be done by engaging and training residents who are looking for work that benefits their community.