EDF Health

Selected tag(s): Lead service line inventory

Lead service line inventories – Indiana as a good model of a voluntary survey

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: July 31, 2018

Tom Neltner, Lindsay McCormick, and Audrey McIntosh

This blog is part of a series focused on how states are handling the essential task of developing inventories of lead service lines (LSLs) and making them public. The first blog identified 14 states that were taking on the issue: 4 with mandatory programs and 10 with voluntary. The second blog described programs in four states that mandate an inventory. In this blog, we highlight Indiana’s 2016 voluntary survey of utilities operating community water systems (CWSs) as a model because it ask utilities to: 1) identify who owns the line and provide the legal basis for that claim; and 2) rate its confidence in its estimates on a 1 to 10 scale. 

We found no other state survey asked about LSL ownership even though it is a central question in determining who is expected to pay for replacement. The Environmental Protection Agency’s (EPA) National Drinking Water Advisory Council (NDWAC) recommended[1] in 2015 that the agency require utilities to provide states this information as part of a revised Lead and Copper Rule (LCR). Unfortunately, 43% of the 781 CWS did not respond to Indiana’s survey, revealing a serious limitation of voluntary surveys.

In January 2016, a month before EPA encouraged states to develop an inventory of LSLs and make it available to the public, the Indiana Department of Environmental Management (IDEM) sent a two-page survey to utilities that operate CWSs in the state asking about drinking water service lines. The agency posted scanned PDF copies of the individual responses online but has not yet released a summary.[2]

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Mandatory lead service line inventories – Illinois and Michigan as strong models

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: July 30, 2018

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

This blog is part of a series focused on how states are handling the essential task of developing inventories of lead service lines (LSLs) and making them public. The first blog identified 14 states that were taking on the issue: four with mandatory programs and ten with voluntary.  In this blog, we explore the four mandatory programs and highlight Illinois and Michigan as strong models for other states to consider.  Updated 11/3/18 to reflect updated estimates from Illinois.

Four states – California, Illinois, Michigan and Ohio – require utilities that operate community water systems (CWSs) to identify and report to the state in some form their number of lead service lines (LSLs). Illinois and Michigan both have strong approaches that could serve as models for other states and EPA to require nationally. California’s approach is seriously flawed because it ignores part of the service lines and can be misleading. Ohio requires utilities to either report they have zero LSLs or provide maps where the LSLs are likely to be found, with no requirement to provide an estimated number. We explore all of these approaches below.

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Posted in Drinking water, Health policy, Lead, Public health, Regulation / Also tagged , , , , , , , | Comments are closed

Developing accurate lead service line inventories and making them public: Essential tasks

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: July 17, 2018

Tom Neltner, Lindsay McCormick, and Audrey McIntosh

This blog is the first in a series focused on how states are handling the essential task of developing inventories of lead service lines (LSLs) and making them public.

Most communities have a general sense of how many lead service lines (LSLs) they have and what neighborhoods have them. The utilities that manage these community water systems (CWSs) base their estimates on installation and maintenance records, size and age of the service line, and professional experience supplemented with field investigations. It is the 80:20 rule in action; most utilities know enough to scope out the problem, develop a strategy, and set broad priorities.

Utilities hesitate when they are expected to provide precise numbers or say with confidence whether a specific address has or does not have a LSL. It is especially difficult for older neighborhoods where records are particularly weak and there are long histories of repairs.

It takes leadership for utilities to share what they know – and don’t know – about LSLs with their customers and the public. They need to be prepared for questions, including why they don’t know more and what they plan to do to remove the lead pipes. Sharing the information with state regulators and the Environmental Protection Agency (EPA) brings additional scrutiny, especially if they claim they have zero LSLs.

For these reasons, EDF applauds leaders such as Boston, MA; Washington, DC; Cincinnati, OH; Columbus, OH; Evanston, IL; Providence, RI; and Pittsburgh, PA that have address-specific maps available online showing what is known and not known about each customer’s service line. We encourage you to check out their maps. In the coming months, we will share a study EDF recently conducted that evaluates consumer reactions to various approaches to online maps to help guide communities planning similar efforts.

An accurate, publicly-accessible inventory of LSLs was a key element of the National Drinking Water Advisory Council’s (NDWAC) recommendations to EPA in December 2015 for its overdue revisions to the Lead and Copper Rule (LCR).[1] Two months later, EPA sent letters to each governor and state environment/public health commissioner asking, as one of five near-term actions, that they:

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