EDF Health

Selected tag(s): Lead in Drinking Water

Top 10 cities with the most lead pipes

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

EDF identified 10 cities in the U.S. with the most lead service lines (LSLs) based on numbers reported in 2021.[1] These cities collectively have over one million LSLs, representing 12% of the 9.2 million EPA estimates are in the country.

Below we rank each city from most LSLs to fewest, and briefly describe the progress each city has made toward LSL replacement. Some have robust programs, while others have yet to start addressing the problem.

The List

1. Chicago, IL

Chicago Department of Water Management reported 387,095 LSLs in 2021, more than twice as many as the next city on this list. Three-quarters of its service lines are LSLs, and virtually all the rest are of unknown material. City ordinance actually mandated that LSLs be installed until the federal government banned them in 1986.

Decades later, Chicago is struggling to pull itself out of a deep hole relative to most other large cities that took earlier action against lead pipes. Chicago has a small LSL replacement program but applied for a $336 million loan from EPA in 2020[2] and $8 million in state revolving funds (SRF) from Illinois EPA in 2023 to accelerate the effort.

2. Cleveland, OH

Cleveland Water reported 185,409 LSLs in 2021, about 43% of all its service lines.

The utility has a small LSL replacement program but is seeking more than $63 million in federal infrastructure funding from Ohio EPA in 2023 to accelerate the effort.

3. New York, NY

New York City reported 137,542 LSLs in 2021 and an additional 230,870 lines that are of unknown material. About 43% of the city’s service lines are lead or of unknown material.

It has a small LSL replacement program and is seeking more than $58 million in federal infrastructure funding from New York State DEP in 2023 to accelerate the effort.

4. Detroit, MI

Detroit Water and Sewerage Department reported 79,617 LSLs in 2021 and an additional 28,922 lines that are of unknown material. About one-third of its service lines are lead or of unknown material.

With support from the Detroit mayor and funding from the State and EPA, the utility has an excellent LSL replacement program that is designed to replace 5,000 lines in 2023 and ramp up to 10,000 per year starting in 2024.

5. Milwaukee, WI

Milwaukee Water Works reported 74,099 LSLs in 2021, about 45% of its service lines.

The utility has a modest LSL replacement program that replaced 1,200 LSLs in 2023 and aims to ramp up to 2,200 replacements by 2025. They are seeking more than $16 million in federal infrastructure funding from Wisconsin DNR in 2023 to accelerate the effort.

6. Denver, CO

Denver Water reported 63,955 LSLs in 2021 and an additional 8,791 service lines that are of unknown material. About one-quarter of its service lines are lead or of unknown material.

The utility has a model LSL replacement program that replaced 5,000 lines in 2022, ramping up to more than 8,000 per year starting in 2023. The program’s success would likely move Denver down to 9th place on the list.

7. St. Louis, MO

City of St. Louis Water Division reported 63,000 LSLs in 2021. About half of its service lines are lead.

The city does not appear to have an active LSL replacement program according to its website or applied for funding from Missouri’s SRF program.

8. Indianapolis, IN

Citizens Energy Group reported 55,060 LSLs in 2021 and an additional 20,000 lines that are of unknown material. About 20% of the city’s service lines are lead or of unknown material.

The utility currently has a modest LSL replacement program and has requested $95.7 million in federal infrastructure funding from Indiana Finance Authority in 2023 to accelerate the effort.

9. Minneapolis, MN

Minneapolis reported 48,502 LSLs in 2021 and an additional 3,906 lines that are of unknown material. About half of the city’s service lines are lead or of unknown material.

The city currently has a small LSL replacement program but is seeking more than $49 million in federal infrastructure funding from Minnesota Public Facilities Authority in 2023 to accelerate the effort. It is expected to receive a significant share of the $240 million in state funding over the next ten years to remove lead pipes.

10. Cincinnati, OH

Greater Cincinnati Water Works reported 40,214 LSLs in 2021 and an additional 2,863 that are of unknown material. About 18% of its service lines are lead or of unknown material.

The utility has a model LSL replacement program that replaces about 2,000 lines a year and plans to ramp up in 2023. Based on its 2022 success, updated reporting would likely push the utility out of the top 10 list.

Why It Matters

If we are to make significant progress toward reaching the White House’s goal of eliminating LSLs by 2032, utilities in these cities must deliver results.

Next Steps

In the coming years, we will focus our advocacy on accelerating LSL replacement in these 10 cities by highlighting progress and problems and engaging community leaders and local elected officials.

 

[1] Reporting based on utility responses to 7th Drinking Water Infrastructure Needs Assessment Survey available as of May 13, 2023, in response to a FOIA request by NRDC. Data for New York City was exported from NYC OpenData’s LSL Location Coordinates on July 7, 2021 and counted service lines designated as potential lead as lead.

[2] Chicago Department of Water Management has applied for a $336 million loan from EPA’s Water Infrastructure Finance and Innovation Act (WIFIA) program to replace LSLs and water mains.

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Mapping Lead: New Jersey State map as a backbone for real progress on lead

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

What Happened: The State of New Jersey published an interactive map showing potential sources of lead exposure for any given address in the state. Currently, the map specifically looks at lead-based paint in housing, though the State has plans to expand this to include other sources of lead, including drinking water from lead service lines (LSLs).

Why It Matters: The availability of address-specific information is important to engage residents, potential home buyers, and renters so they can make better informed decisions about protecting their families from harmful lead exposure. New Jersey is the first state to move beyond neighborhood-level mapping of lead risks to provide specific information about lead at the address level.

The map uses housing age as an indicator to assess risk to lead exposure, which is an excellent place to start because it is relevant to the prevalence of both lead-based paint and lead in drinking water.

As more information is added on lead pipes, lead-contaminated soil, and nearby commercial operations that release lead, as well as details on lead poisoning prevention requirements, the map will become a critical tool in the effort to comprehensively consider lead risks and drive exposure closer to zero.

Source: New Jersey Department of Environmental Protection Potential Lead Exposure Mapping (click on Lead-based paint tab at the top and zoom in until you see parcel-level detail with color overlays)

Read More »

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Lead Pipe Replacement: EPA changes state shares of funding

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

What Happened?

Earlier this month, EPA announced an updated formula it will use to allocate federal funds for lead service line (LSL) replacements. This new formula will be based on each state’s expected needs, as determined by a 2021 survey of state and water utility estimates.

Why It Matters

EPA’s distribution of the first of five years of the historic $15 billion dedicated to LSL replacement from the Infrastructure Improvement and Jobs Act (IIJA) was not necessarily going to states and communities that needed it most.

Many water utilities rely on the State Revolving Fund (SRF) program to build and maintain their drinking water infrastructure. EPA funds SRF programs each year and their previous formula to determine allocations was based on a 2015 survey of estimated drinking water infrastructure funding needs including LSL replacement – putting populous states like California at the top of the list. However, a 2016 article by the American Water Works Association (AWWA) showed LSLs are most heavily concentrated in the Midwest and Northeast, in states like Illinois, Ohio, Michigan, Missouri, New York, and New Jersey.

With EPA’s new formula, each state’s need, based on its estimated number of LSLs, will be used to distribute the next four years of IIJA funding for LSL replacement. This is a critical step to ensure that the system for distributing federal funds is functioning equitably and funds go to those communities with the greatest needs.

Projected Number of Lead Services Lines by State–2023

But wait…what’s going on in Florida and Texas?

When we dug into the details, there was one surprise in particular. Florida’s level of funding has increased a whopping 228%, based on a new estimate that the state has 1.2 million LSLs – more than any other state – and that about one in every six of its service lines is an LSL. Based on the age of infrastructure in the state, we think that this number is a gross overestimate. If we’re right, other states will get shorted on their share of LSL-replacement funding.

At first blush, data from Texas also caught our eye. The state reported almost 650,000 LSLs – up from 270,000 in the AWWA survey. But in contrast to Florida, this means Texas is claiming that only 5% of all its services lines are LSLs. Overall, Texas’ funding under the new formula will decrease by one-third.

What’s Next?

Starting this federal fiscal year (October 1, 2023), states will receive their new allocations of IIJA funding for LSL replacement. We’ll continue to monitor the funding flowing into each state for the critical task of getting the lead out, especially in communities that need it most. For states like Florida that may be in line for more than their fair share, we’ll be monitoring where those dollars are going.

Want to learn more?

Check out EPA’s detailed factsheet: 7th Drinking Water Infrastructure Needs Survey and Assessment

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Rhode Island expects LSL replacements to be ‘simultaneous and complete’ when funded by SRF

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

What Happened: The Rhode Island Department of Health (RIDOH) published notices on January 18 and January 30 indicating that Providence Water would need to stop partial replacement of lead service lines (LSLs) when the work is funded by the State Revolving Fund (SRF) program.

RIDOH specified that “only [LSL] replacement that results in simultaneous and complete replacement of both the public (water main to curb stop) and private (curb stop to water meter inside buildings) portions of the lead service lines will occur.”

Why It Matters: EPA made it clear in its FAQs that federal SRF funds should not be used to support harmful partial LSL replacements, which increases the risk of lead exposure in drinking water.[1] To our knowledge, Rhode Island is the first state that has applied its National Environmental Policy Act (NEPA)-like environmental review process to protect residents from partial LSL replacements by requiring the simultaneous and complete replacement of an LSL. All states have a similar review process pursuant to EPA requirements and should be taking similar action.

Our Take: RIDOH’s determination is an important application of the state’s environmental review requirements for its SRF program. We strongly supported RIDOH’s action in comments. We also asked that it be applied to six other SRF-funded projects that are likely to disturb LSLs, like water main replacement and asked for a public hearing if RIDOH allows partials for those other projects.

The Backstory: EDF objected to RIDOH’s March 2022 proposal to grant Providence Water a categorical exclusion that would have allowed partial LSL replacements. We reasoned that the practice would “disproportionately and adversely affect the health of low-income, Black, Latinx, and Native American residents by increasing their risk of exposure to lead in drinking water.” Accordingly, the utility was not eligible for a categorical exclusion and must either stop partial LSL replacements or conduct a full environmental review. This review would likely demonstrate the project was not eligible for funding.

Later, RIDOH withdrew the proposal based on follow-up discussions with EDF and separate discussions with Childhood Lead Action Project.

Go Deeper: Read RIDOH’s April 2022 and January 2023 public notices, a related civil rights administrative complaint filed with EPA, and EDF’s objections to RIDOH’s April 2022 proposal.

 

[1] EPA Frequent Questions about Bipartisan Infrastructure Law State Revolving Funds and LSLR:

Question 4. If some customers (e.g., homeowners) refuse to allow the water utility access to replace the privately-owned portion of the lead service line, does this affect the project’s DWSRF funding?

State DWSRF programs may still fund the overall project but are strongly encouraged to use technical assistance and other outreach methods to achieve the fullest possible participation. If the customer continues to refuse access, then the water system should leave the publicly-owned portion of the lead service line in place (so as to not create a partial replacement) and document this action. To be clear, partial service line replacements are not eligible for DWSRF funding (from any DWSRF funding source).”

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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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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.

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