EDF Health

Selected tag(s): Federal funding

The next infrastructure stimulus bill is the right place for lead pipe replacement funding – to create jobs, save money and provide safer water for all

By Joanna Slaney / Published: April 16, 2020

Joanna Slaney, Legislative Director and Tom Neltner, J.D., 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.

During the past few weeks, Congress has taken extraordinary measures to provide much-needed emergency relief to people as we collectively struggle with the COVID-19 crises. Over the coming months, lawmakers have said they will turn their attention to providing funding to stimulate the economy with a focus on water infrastructure as a priority. Lead pipe replacement should be an essential part of that effort.

To guide the Congressional effort, EDF and hundreds of others signed onto U.S. Water Alliance’s COVID-19 Relief and Recovery: Guiding Principles to Secure Our Water Future. The four principles are:

  1. Ensure water is reliable and affordable to all
  2. Strengthen water utilities of all sizes
  3. Close the water access gap
  4. Fuel economic recovery by investing in water systems

In line with of our support for these principles, EDF is advocating that Congress provide $45 billion for water utilities to fully replace lead service lines (LSL) – the lead pipes connecting a home to the water main under the street. Today, there are more than nine million homes still serviced by LSLs in the country, exposing millions of children and adults to the myriad of harms associated with lead. For children, these harms include undermining brain development. In adults, lead has been shown to cause heart disease, cancer, and impact the neurological, reproductive, and immune systems. While there is broad consensus that LSLs must be fully removed to protect public health, funding challenges have stymied progress.

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Every lead service line replaced yields an estimated $22,000 in reduced cardiovascular disease deaths

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: February 20, 2020

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

See all blogs in our LCR series.

Using publicly available information from the Environmental Protection Agency (EPA), EDF estimated that fully replacing the 9.3 million lead service lines (LSL) in 11,000 community water systems (CWS)[1] across the country would yield societal benefits of more than $205 billion, or about $22,000 per LSL removed. This estimate is based solely on reducing lead exposure in adults in order to have fewer cardiovascular disease (CVD) deaths over 35 years. It does not include the benefits to children’s brain development.

We submitted our analysis in comments to EPA on its proposed revisions to the Lead and Copper Rule (LCR), the federal regulation that limits lead in drinking water. Given the magnitude of the benefits, we called on the agency to incorporate CVD mortality into its economic analysis and consider strengthening its proposal by requiring full LSL replacement as an integral part of every CWS’s efforts, instead of as a last resort when lead levels get too high.

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A closer look at the environmental justice implications of EPA’s proposed lead in water rule

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: February 4, 2020

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

See all blogs in our LCR series.

[pullquote]

“Household-level changes that depend on ability-to-pay will leave low-income households with disproportionately higher health risks.”

 

– EPA Environmental Justice Analysis of the proposed rule.

[/pullquote]Reviewing a rulemaking docket can be intimidating, especially for a major rule like the Environmental Protection Agency’s (EPA) proposed revisions to its Lead and Copper Rule (LCR), which includes 853 supporting documents and tens of thousands of pages. Though we cannot claim to have read all of the documents, we did a targeted scan of key materials, knowing that they often yield insights and results that are lost in the summary that appears in the Federal Register. 

The effort for us paid off when we read EPA’s Environmental Justice (EJ) Analysis of the LCR proposal revisions (the Proposal), commissioned in response to Executive Order 12898. The Order directs agencies to identify and address, “as appropriate, disproportionately high and adverse human health or environmental effects of its programs, policies, and activities on minority populations and low-income populations” in rulemaking. The agency’s contractor essentially found:

  • The current LCR disproportionately impacts low-income and minority populations as they are more likely to live in older housing that has lead service lines (LSLs), the most significant source of lead in drinking water.
  • The Proposal’s corrosion control requirements should help reduce current disparities. Because water treatment is consistent across an entire community, stronger requirements that reduce the ability of lead to leach into water from LSLs, leaded solder, and other sources should mitigate, but not eliminate, the disproportionate burden in homes with LSLs.
  • The Proposal may make disparities worse if it depends on individual household’s ability to pay for LSL replacement (LSLR). The report stated that “Household-level changes that depend on ability-to-pay will leave low-income households with disproportionately higher health risks.”[1]

In the Federal Register notice, EPA glossed over the third point and concluded that the Proposal is “not expected to have disproportionately high and adverse human health or environmental effects on minority populations and low-income populations.”[2] The agency ignores the fact that the Proposal makes no change to the current LCR provisions that rely on a household’s ability to pay when it says water systems are “not required to bear the cost of removal of the portion of the [LSL] it does not own.”[3] We are aware of only a small – but growing – number of communities that have funding options to assist households with the cost of LSLR on private property.

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