EDF Health

Leveraging LSL replacement funding: Chicago Fed steps up

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: November 10, 2022

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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Another reason to reduce methane emissions: Saving lives 

By Sarah Vogel / Published: November 10, 2022

Sarah Vogel, Ph.D., is Senior Vice President, Healthy Communities

Cutting methane emissions is one of the fastest, most effective ways to stabilize the climate. It can also improve public health.   

Today, 130 countries are committed to cutting methane emissions by 30% by 2030 as part of the Global Methane Pledge. As countries work to meet these commitments and more nations join the Global Methane Pledge, there is an opportunity to identify and implement solutions that both reduce methane emissions and improve the public’s health. Finding climate solutions that center health and wellbeing of people is essential if we are to secure a vital Earth for everyone.

At this year’s COP in Sharm El-Sheikh, Egypt, we have a unique opportunity to bring together experts on oil and gas, agriculture, waste and public health on November 15 at the Health Pavilion to discuss the nexus between methane and health as well as opportunities for action.

WHY IT MATTERS

Methane is a short-lived climate pollutant, and cutting these emissions is important because it is the fastest way to advance global climate goals while also achieving significant near-term public health benefits. Methane contributes significantly to the impacts of climate change on our health–from extreme heat to increased risk of infectious disease. It contributes to ground-level ozone and particulate pollution, which damages airways, aggravates lung diseases, causes asthma attacks, increases rates of pre-term birth, cardiovascular morbidity and mortality, and boosts stroke risk.

Consequences from these health impacts include lost productivity, higher medical costs, and greater pressure on health systems. By suppressing crop growth, ozone can also exacerbate food insecurity.

But there’s also reason for hope. We can prevent vented and fugitive methane emissions with existing technologies, and our ability to identify methane leaks continues to improve. By taking full advantage of such tools and targeting super emitters, policymakers can advance climate action while delivering enormous health benefits regionally as well as to communities living near oil and gas operations.

We can also reduce methane emissions in agriculture and solid waste management. Providing livestock with higher-quality feed would cut methane produced during digestion, improve the animals’ health and deliver more nutritious dairy products for people. Capturing methane from manure and treating digestate to minimize ammonia emissions (precursors of particulate matter) would provide a local source of energy, reduce odors, and mitigate public health risks of those living nearby.

It is crucial to highlight the near-term health benefits of cutting methane. With the help of researchers and community-health practitioners who understand the issue best, we hope to generate the support, collaboration and investment needed to cut methane emissions and improve public health worldwide.

With support from the Wellcome Trust, EDF will convene a series of dialogues in early 2023 about the health-methane nexus and hold a workshop during the UNFCCC Intersessional in Bonn to collaboratively develop recommendations to the UNFCCC for presentation at COP28.

Watch the “Health-Methane Nexus: Opportunities for Action” panel livestream from COP 27 at 10:00 a.m. EET (Egypt)/3:00 a.m. ET or view the post-event recording at GlobalCleanAir.org Convenings.

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

By Roya Alkafaji / Published: November 8, 2022

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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Unleaded Juice: FDA’s challenge of continuous improvement and compliance assurance

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: October 2, 2022

Tom Neltner, Senior Director, Safer Chemicals

This is the sixth in our Unleaded Juice blog series exploring how the Food and Drug Administration (FDA) sets limits for toxic elements like lead, arsenic, and cadmium in food and the implications for the agency’s Closer To Zero program. 

A core tenet of FDA’s Closer to Zero program is the “Cycle of Continuous Improvement” represented by the image below on the program’s webpage. The four-stage, outer ring represents FDA’s process for revising its action levels for food contaminants. The inner, grey ring describes the agency’s on-going monitoring, research, and compliance program.


This approach makes sense, and we fully support it. However, the success of this approach relies on FDA addressing several significant structural weaknesses.

  • Future funding is not guaranteed: In March 2022, Congress appropriated $11 million in Fiscal Year 2022 (FY22) funding for FDA’s maternal and infant health work—in part to support the agency’s efforts to reduce arsenic, lead, and cadmium in children’s foods. Last year’s request and appropriations were a significant increase over previous years, but that funding level is not guaranteed for future years.
  • Action levels are guidance—not legally binding requirements: FDA’s action levels for contaminants in food are established in guidance. The guidance introduction makes it clear that “The contents of this document do not have the force and effect of law and are not meant to bind the public in any way, unless specifically incorporated into a contract.” It assumes that the food industry—from the largest multinational corporation to the smallest entrepreneur—will comply.
  • The agency has limited means to monitor compliance: FDA largely relies on physical inspections and market sampling, supplemented by voluntary reporting, to assure compliance with action levels. Inspections at high-risk facilities must occur every three years (but likely have been delayed due to the COVID pandemic). We understand that most facilities will see an inspector once every eight years. This is particularly problematic because FDA says it lacks the authority to require food companies to provide requested documents without the physical inspection, and the agency does not require ongoing testing and reporting by companies for action levels.
  • Action levels must be consistently strong enough to drive research and impact markets: FDA correctly points to its success in setting an action level for inorganic arsenic in infant rice cereal as a model to lower contamination. Unfortunately, the model assumes the action level for a contaminant is set low enough to result in research investments and increased product and ingredient testing and to provide FDA with sufficient information to act on problems. This is not the case for lead in juice.
     
    We explore each of these weaknesses below.

Read More »

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Successful Denver Water Lead Reduction Program Seeks 12-Year Extension

By Roya Alkafaji / Published: September 22, 2022

Roya Alkafaji, Manager, Healthy Communities and Lindsay McCormick, Senior Manager, Safer Chemicals

Denver Water has one of the most successful lead service line (LSL) replacement programs in the country. Since it began the program in 2020, the utility has replaced nearly 14,000 LSLs—prioritizing lines to buildings serving vulnerable populations, such as child-care facilities. Denver Water has also distributed over 102,000 filters to local residents. EPA should continue to support their innovative approach.

Watch this video to learn more about Denver Water’s Lead Reduction Program.

In 2019, we blogged about a novel program that Denver Water designed to address the estimated 64,000 to 84,000 LSLs in its system. These lead pipes connect buildings to water mains under the street.  At the time, the water utility proposed to fully replace all LSLs in their entirety within 15 years under its Lead Reduction Program.

The utility decided to fund the work through water rates and bonds, hydropower production, and other sources. In addition, they proposed to provide filters to residents until six months after replacement of the LSL.

Critically, the program includes a comprehensive effort to engage local partners to reach all members of the community. For example, Denver Water partnered with CREA Results, a local community-based organization that is helping to engage and educate Spanish-speaking and immigrant communities on the risks of lead in drinking water and to ensure that residents understand the steps involved with LSL replacement in their neighborhoods. Denver Water’s program has emerged as a national model and its success is recognized by the Lead Service Line Replacement Collaborative and EPA (including its recent service line inventory guidance).

Read More »

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Workers are people too; EPA should treat them that way

By Maria Doa, PhD, Senior Director, Chemicals Policy / Published: June 21, 2022

EPA’s proposed TSCA rule to limit risks from chrysotile asbestos uses a higher “acceptable” cancer risk for workers than the rest of the population

Maria Doa, Ph.D., Senior Director, Chemicals Policy

When it comes to drawing the line on cancer risks, should workers be treated differently than the general population? Of course not. Unfortunately, EPA’s recently proposed rule to manage risks from chrysotile asbestos does just that, using one level of acceptable risk for workers and another – more protective threshold – for everyone else.

EPA says it uses a range for determining acceptable cancer risks under the Toxic Substances Control Act (TSCA), the country’s main chemical safety law. The range spans a risk (or the chance that a person will develop cancer) of less than one in 10,000 to a risk of less than one in one million. EPA says this is consistent with the cancer benchmark used by the National Institute for Occupational Safety and Health (NIOSH).

However, EPA’s proposed TSCA rule for asbestos does not actually use a range and it is not supported by TSCA. EPA instead applies a risk level to workers 100 times less protective than for everyone else! Read More »

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