EDF Health

Denver Water proves its Lead Reduction Program is a national model

Tom Neltner, Senior Director, Safer Chemicals and Lindsay McCormick, Senior Manager, Safer Chemicals

What’s New: After an extensive review process, EPA approved Denver Water’s request to extend the variance to allow the utility to administer their Lead Reduction Program for the full 15-year term. EPA touts Denver Water’s Lead Reduction Program as an “innovative and aggressive approach” to lead service line replacement (LSL) in a letter approving the variance.

Denver Water will continue to:

  • replace all lead service lines at no cost to homeowners,
  • provide residents with filters to help reduce their exposure in the short-term, and
  • use an alternative approach to water treatment that still ensures effective corrosion control.

We applaud their emphasis on environmental justice and commitment to ensure that the program continues to prioritize disproportionately impacted neighborhoods – and EPA’s new requirement to track this progress.

This fall, we visited Denver Water’s field operations to see for ourselves how it is successfully replacing more than 4,500 lines per year. We were impressed by what we saw, and sent a letter to EPA’s Regional Administrator expressing our full support for Denver Water’s March 2022 request to continue their program. Read More »

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Mapping Lead Pipes: Powerful tool helps communities find underground hazards

Lead service line replacement (Photo Credit: Mercury Insurance)

Roya Alkafaji, Manager, Healthy Communities and Tom Neltner, Senior Director, Safer Chemicals Initiative

We have all come to expect access to information at our fingertips. To meet this demand, water utilities are increasingly posting interactive maps online to help residents identify whether their homes are connected to lead service lines (LSLs).[1] These are the pipes that deliver water from the main under the street to homes and buildings. In homes built before 1986, this pipe could be made of lead.

With this information, people can:

  • Better assess their risk of lead exposure from drinking water and take steps to reduce possible exposure (e.g., water filters);
  • Make decisions when renting or purchasing a new home, and/or;
  • Demand that their water utility and community invest in effective LSL replacement programs to reduce harmful exposure to lead, particularly for children who are most vulnerable.

Given the importance and growing popularity of LSL maps, we are launching a new blog series, Mapping Lead Pipes, that will explore how utilities are approaching maps, evaluate which map features are most and least effective, and share best practices to help guide future efforts.

EPA recognized the value of interactive maps in its August 2022 guidance on developing service line inventories. The agency recommended utilities of all sizes consider making information available through interactive maps using commonly available tools, like GIS software. The guidance references EDF’s 2019 study for evidence of the power of these interactive maps and spotlights LSL replacement programs in Cincinnati and Denver as examples of best practices.[2]

We wholeheartedly agree with EPA’s recommendations. As a result of the agency’s guidance, we anticipate that the number of online maps is likely to grow dramatically as utilities meet an October 2024 deadline to make their inventory of service line materials publicly accessible to comply with EPA’s revised Lead and Copper Rule (LCR).

Top 100 Cities: Who Has Maps – And Who Doesn’t

We identified over 50 interactive LSL maps that utilities have made publicly available to residents across the United States. Looking at the utilities that serve the 100 largest cities in the country, we found that 15 have LSL maps—a positive step that leverages existing asset-management tools such as GIS, while increasing public transparency. Together, these 15 utilities provide drinking water to more than 16 million people.

Throughout this blog series we’ll take a closer look at maps; in some cases, we’ll be critical of those that don’t meet the criteria for an effective map. Nonetheless, we recognize these utilities have taken a step in the right direction and should be applauded for their efforts.

We discovered that 12 large utilities were notably absent from the list of those with online maps. Given their size and location, these utilities presumably have LSLs in their distribution areas and the in-house resources to develop effective maps. We hope that by shining a light on the cities that are leading the way and addressing the contrast with those cities without maps, we can help spur action so residents of large cities served by these utilities will have access to this crucial information. For a list of the 12 utilities without maps and 15 with maps, see the tables below. We’ll continue to revise these lists as more large cities publish interactive maps online.

By the Numbers

It’s important to understand the broader landscape as we track cities that are choosing interactive maps as a key tool for communicating about LSLs to the public. Using estimates from EPA’s Regulatory Impact Analysis for the revised LCR, the figure below shows the number of community water systems that fall under the purview of the LCR and subsequent requirements based on presence of LSLs and population served.

By October 2024, more than 50,000 utilities[3] will either submit an initial service line inventory or demonstrate the absence of LSLs in their distribution area.[4] EPA estimates that more than 12,000 utilities will find LSLs and thus will be required to make their inventory publicly accessible; those that serve over 50,000 people will also be required to post the inventory online.

More to Come

Follow along as we explore interactive maps and the role they play in LSL replacement.

Utilities Serving Top 100 Largest Cities With Online Interactive Maps

UtilityPopulation Served†Estimated # of LSLs‡
New York City, New York (Map)8.3 million360,000
Boston, Massachusetts (Map)2.6 million3,900**
Denver, Colorado (Map)1.4 million64,000**
Columbus, Ohio (Map)1.3 million28,000*
Seattle, Washington (Map)956,0002,000*
San Francisco, California (Map)884,0001,600*
Cincinnati, Ohio (Map)750,00040,000
Memphis, Tennessee (Map)700,00014,000*
Tucson, Arizona (Map)675,000600
Washington, D.C. (Map)632,00042,000**
Pittsburgh, Pennsylvania (Map)520,00016,000**
Toledo, Ohio (Map)480,00030,000**
St. Paul, Minnesota (Map)400,00027,000
Newark, New Jersey (Map)295,00024,000**
Jersey City, New Jersey (Map)262,00016,000
*Map and/or estimated number of LSLs reflects public side only.
**Active or completed LSL replacement program. The number listed reflects the estimated number of LSLs prior to the start of the program.
†Source is SDWIS, 2022.
‡Source available upon request.

 

Select Utilities Serving Top 100 Largest Cities That Lacked Online Interactive Maps

UtilityPopulation Served†Estimated # of LSLs‡
Chicago, Illinois2.7 million380,000
Baltimore, Maryland1.6 millionNot reported
Philadelphia, Pennsylvania1.6 million20,000
Cleveland, Ohio1.3 million200,000
Charlotte, North Carolina1.1 millionNot reported
Indianapolis, Indiana (Citizens Energy – Water)837,00055,000-75,000
Nashville, Tennessee722,000Unknown
Detroit, Michigan714,00080,000
Milwaukee, Wisconsin590,00066,000
Omaha, Nebraska554,00016,000-17,000
Minneapolis, Minnesota424,00049,000
New Orleans, Louisiana291,000Unknown
†Source is SDWIS, 2022.
‡Source available upon request.

 

[1] For this blog series, LSLs includes service lines that are “galvanized requiring replacement” per 40 CFR § 141.2.

[2] See Section 7.2 of EPA’s service line inventory guidance.

[3] For purposes of this blog series, community water suppliers as defined by EPA are referred to as utilities.

[4] Per 40 CFR 141.84(4), CWSs must categorize each service line, or portion of the service line where ownership is split, as lead, galvanized requiring replacement, non-lead, or lead status unknown. In order to declare that the system only contains non-lead service lines, this must be “determined through an evidence-based record, method, or technique.”

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EPA greenlights 21 states’ SRF plans to fund LSL replacement projects

Tom Neltner, Senior Director, Safer Chemicals

What’s New: EPA announced it has awarded $1.16 billion to the State Revolving Fund (SRF) programs in 21 states, the District of Columbia, and three territories to support lead service line (LSL) replacement projects. In order to secure funding, these states developed and submitted Intended Use Plans (IUPs), which included LSL replacement projects that met EPA’s requirements.

Why It Matters: These 25 programs can now begin distributing their share of the first of five years of funding from the $15 billion Congress included in the 2021 Infrastructure Investment and Jobs Act (IIJA) specifically for full LSL replacement projects. The remaining states are working to get their IUPs submitted to EPA.

Read More »

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The LSLR Collaborative’s new guide helps communities design equitable lead service line replacement programs

Guest post from Mason Hines, Mediator with RESOLVE and Facilitator for the Lead Service Line Replacement Collaborative.  See the original post here.

For over six years, RESOLVE has convened the Lead Service Line Replacement Collaborative, a joint effort of 28 national public health, water utility, environmental, labor, consumer, housing, and state and local governmental organizations to accelerate full removal of the lead pipes providing drinking water to millions of American homes.

A guiding principle of the LSLR Collaborative is that lead service line (LSL) replacement program should consider and address barriers to participation so that people served by LSLs can benefit equitably, regardless of income, race, or ethnicity. Questions of equity surface at many points in the design of LSL replacement programs, including determining how replacements are funded, how to sequence replacement schedules, and how the program is communicated to community members.

Understanding these are important and complex questions, the LSLR Collaborative recently released a step-by-step guide communities can use to help consider and account for issues of equity when developing LSL replacement programs.  Read More »

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Leveraging LSL replacement funding: Chicago Fed steps up

Tom Neltner, Senior Director, Safer Chemicals Initiative

The Federal Reserve Bank of Chicago serves Iowa and much of Illinois, Indiana, Michigan, and Wisconsin—areas of the country that likely have more LSLs than those served by any of the other 11 banks in the Federal Reserve System. Image source: Federal Reserve Bank of Chicago

What Happened: On November 2, the Federal Reserve Bank of Chicago held a meeting of more than 50 stakeholders interested in new strategies to fund and finance lead service line (LSL) replacements. I attended, representing the Lead Service Line Replacement Collaborative.

Why It Matters:

  • The meeting was an important first gathering of its type to focus on helping:
  • Lead pipes represent the most significant source of lead in drinking water. Replacing the nation’s estimated 9 million LSLs is predicted to cost $45 billion.
  • Federal funds alone will not be enough to help states and communities eliminate this lead pipe legacy, municipal water utilities need to leverage federal funds by getting the lowest rates for bonds to finance their efforts.

Our Takeaway: EDF applauds Chicago Fed for its leadership in taking on this complicated but critical issue. The meeting advanced the discussion in a way that only a neutral party like the Chicago Fed can do.

Next Steps: Within days of the convening, I am already hearing from participants interested in making connections or learning more about the issue. Chicago Fed should continue these convenings and engage more stakeholders.

Go Deeper: In February 2022, staff at the Chicago Fed began to offer a series of excellent articles, videos, and case studies to explain the issue of lead pipes to their stakeholders. We recommend this interview with Margaret Bowman, a water expert with 30 years in the nongovernmental and philanthropy sectors, as she explains the financing needs and opportunities.

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EPA should ensure federal funds do not support harmful partial LSL replacements

Tom Neltner, Senior Director, Safer Chemicals Initiative and Roya Alkafaji, Manager, Healthy Communities

Last year, the White House set a goal of eliminating lead service lines (LSLs) by 2032 and worked with Congress to enact the Infrastructure Investment and Jobs Act (IIJA)—also known as the Bipartisan Infrastructure Law—which included critical resources to help meet this goal.

Through IIJA, communities across the United States have access to federal funds to replace an estimated 9 million LSLs, which are the pipes that connect homes to water mains under the street. EDF fully supports the President’s goal and related efforts to protect public health and advance environmental justice.

EPA is off to a good start. The agency:

  • Distributed the first of five years of IIJA funds to state revolving fund (SRF) programs, including $15 billion dedicated to LSL replacement and $11.7 billion in general funding for drinking water infrastructure projects (which may also be used for LSL replacement).
  • Provided guidance to states to help ensure the funds go to “disadvantaged communities” and that the $15 billion is used for full (not partial) replacements.
  • Plans to publish the results of its drinking water Infrastructure Needs Survey and Assessment. That report is crucial to updating the formula by which SRF funds will be allocated to states in subsequent years.

However, as states begin to administer SRF funds from the $11.7 billion in general infrastructure funding, EPA’s lack of clarity on what the funds can and cannot be used for reveals problems. Specifically, some states may allow this funding to pay for partial – as opposed to full – LSL replacements when a utility works on aging water mains that have LSLs attached to them.

Read More »

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