EDF Health

Better data is critical to address health disparities in air pollution’s impacts

By Ananya Roy / Published: March 31, 2021

This post originally appeared on the EDF Global Clean Air Blog.

Ananya Roy, Senior Health Scientist, and Maria Harris, Environmental Epidemiologist 

The last several months have seen a wave of momentum in policies seeking toward advance environmental justice and equity through better data collection and mapping. In his first week in office, President Biden signed an executive order to initiate the development of a screening and mapping tool to identify disadvantaged communities with the goal of informing equitable decision making. And legislation introduced in the House of Representatives and Senate would launch a similar effort. This focus on data and mapping is critical.  

At EDF, we’ve worked with community and research partners to map air pollution at the block-by-block level, and found that hyperlocal data can reveal pollution hotspots and variability within cities and neighborhoods that would otherwise be missed. Building on this research, our latest work shows how the health impacts from air pollution can vary at a hyperlocal level and how using local level data can greatly improve our ability to identify health disparities and target action. Our findings illustrate why it is important to incorporate health information into such decision-making, as both pollution exposure and health vulnerability influence the health impacts of air pollution.

These insights have relevance not only for actions at the federal level, but also for cities and states across the country that are seeking to reduce air pollution and address health inequities.

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An issue nearly everyone agrees on: It’s time to fund lead pipe replacement

By Joanna Slaney / Published: March 25, 2021

Joanna Slaney, Legislative Director, and Sam Lovell, Project Manager.

As Congress looks to various infrastructure priorities in the coming months to get the country back on track, funding replacement of lead pipes should be an essential part of that effort. Recent polling from Black Millennials for Flint, BlueGreen Alliance and EDF demonstrates that there is strong bipartisan support for this initiative across party lines and regions of the country. Funding lead pipe replacement will protect health, create jobs, permanently improve water infrastructure, and reduce health inequities. It’s time for action.

And we are already seeing movement on this important issue, with legislation in the first few months of the new Congress in both the US House and Senate including lead pipe replacement as a key infrastructure priority.

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Lead pipe replacement in action: New case examples highlight innovative approaches to financing, outreach, and more

By Sam Lovell / Published: February 22, 2021

Sam Lovell, Project Manager.

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See new case examples of state and local agencies, community groups, and other stakeholders tackling lead service line replacement challenges.

[/pullquote]Across the country, over 9 million homes still get their water through a lead pipe, called a lead service line (LSL). Fully replacing LSLs poses a myriad of challenges – cost chief amongst them – but replacement is critical to protecting the public from the harms posed by lead exposure. It is also a necessary step to upgrading the country’s aging water infrastructure.

To assist water systems, elected officials, health professionals, and other key stakeholders with navigating these challenges to accelerating LSL replacement, the Lead Service Line Replacement Collaborative developed an online toolkit several years ago. EDF is a founding member of the Collaborative, which now has 27 members representing public health, water utility, environmental, labor, consumer, housing, and state and local governmental organizations. The toolkit includes everything from technical replacement information to recent LSL replacement news to equity considerations.

Now, the Collaborative is featuring case examples and interviews with states, water utilities, and advocates advancing LSL replacement with innovative strategies.

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Spotlighting advocates for environmental justice: LaTricea Adams with Black Millennials for Flint

By Sam Lovell / Published: February 11, 2021

LaTricea Adams credits her background as an educator with motivating and shaping her community advocacy work. For five years, Adams taught Spanish to middle and high school students in Nashville, Tennessee.

Now, she’s the Founder Chief Executive Officer and President of Black Millennials for Flint (BM4F) – a grassroots, environmental justice and civil rights organization with the purpose of bringing like-minded organizations together to collectively take action and advocate against the crisis of lead exposure specifically in African American and Latino communities throughout the nation.

Last month, we sat down (virtually) with Adams to learn about her experience advocating for environmental justice.

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EPA’s three new service line notices: Critical to transparency and accelerating lead pipe replacement

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: January 21, 2021

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

This is the second in a series of blogs evaluating various aspects of EPA’s December 2020 revisions to the Lead and Copper Rule (LCR) and what they may mean for accelerating lead service line (LSL) replacements. The blogs cover: 1) new service line inventory; 2) three new LSL notices; 3) environmental justice implications; 4) communicating health effects of lead; 5) economic implications; and 6) sampling and trigger/action level.

Note that President Biden’s Executive Order on Protecting Public Health and the Environment and Restoring Science to Tackle the Climate Crisis directs agencies to review the former administration’s regulations and actions, including the Lead and Copper Rule. 

Three new notices required by the revised LCR from water systems to people with known or potential LSLs provide critical opportunities to build public support for LSL replacement by helping individuals better understand their situation and specific actions they should take. However, we recognize that, like all notices, many people may simply ignore them, especially if only delivered as an insert to a monthly or quarterly bill. We anticipate that notices will be most effective when coupled with broader outreach efforts and requirements that property owners share the notice with potential buyers and tenants.

As explained in a previous blog on the new service line inventories, water systems must assign all service lines to one of four categories. The rule treats three categories – “Lead,” “Galvanized Requiring Replacement,” and “Lead Status Unknown” – as known or potential service lines containing lead. People receiving water from a service line in any of these three categories must receive three new types of notices designed to prompt them to take steps to address the risk of lead in their drinking water pursuant to 40 CFR § 141.85(e) to (g). The three types of notices are:

  1. An annual notice;
  2. A notice of disturbance to service line; and
  3. A notice if trigger or action levels exceeded.

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EPA’s new service line inventory: The good, the bad, and the absurd

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: January 19, 2021

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

This is the first in a series of blogs evaluating various aspects of EPA’s December 2020 revisions to the Lead and Copper Rule (LCR) and what they may mean for accelerating lead service line (LSL) replacements. The blogs cover: 1) the new service line inventory; 2) three new LSL notices; 3) environmental justice implications; 4) communicating health effects of lead; 5) economic implications; and 6) sampling and trigger/action level. 

Note that President Biden’s Executive Order on Protecting Public Health and the Environment and Restoring Science to Tackle the Climate Crisis directs agencies to review the former administration’s regulations and actions, including the Lead and Copper Rule. 

The backbone of the revised LCR is a new service line inventory[1] that all public water systems, whether large or small, rural or urban, must develop by January 2024 unless they can demonstrate that they have no LSLs. If properly designed and implemented, the inventory should transform how utilities, communities and states approach LSLs by moving from rough estimates to a data-driven approach that allows water systems to identify what is known and not known about the service lines, communicate that information to the public, and establish LSL replacement priorities.

Unfortunately, EPA has included an unfortunate and absurd new detail in the inventory that requires systems to categorize service lines that contain a two-foot piece of lead pipe, often known as a gooseneck, as “Non-lead.” We anticipate that the absurdity of calling a lead pipe “Non-lead” will undermine the inventory’s credibility and effectiveness.

What is the new service line inventory and how is it used?

By January 2024, water systems must submit a service line inventory to the state and make it publicly accessible pursuant to 40 CFR § 141.84(a). To develop the inventory, they must assign all service lines, regardless of ownership, for the portions on public or private property to one of four categories:

  1. Lead: where a portion of the service line is made of lead (excluding lead connectors, such as goosenecks, as explained below). We presume this includes lead-lined pipe.
  2. Galvanized Requiring Replacement: where a portion of the service line is galvanized iron or steel.[2] If the system can determine that the galvanized pipe was never downstream of an LSL (or lead connector, such as a gooseneck[3]), then it is essentially a galvanized pipe not requiring replacement and can be categorized as “Non-lead.”
  3. Non-lead: where the line is determined not to be “Lead” or “Galvanized Requiring Replacement” (see discussion below for lead connectors). Our understanding is that systems could assume service lines installed after the 1986 federal ban on lead pipe are “Non-Lead.”
  4. Lead Status Unknown: where it has not been determined if the service line met the SDWA Section 1417 definition of “Lead-free” at 42 U.S.C. § 300g-6. We presume this means that solder or flux must be less than 0.2% lead and other wetted surfaces must be less than 8% from 1986 to 2013 and less than 0.25% for 2014 to present.[4]

Under these requirements, a service line is classified as an LSL if it is in the “Lead” or “Galvanized Requiring Replacement” categories.[5]

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