EDF Health

Selected tag(s): Lead service line replacement

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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Posted in Drinking water, Lead / Also tagged , , , | Comments are closed

Latest Wisconsin data on water service lines provides important insights, reveals over 150,000 lead pipes

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: April 16, 2020

Tom Neltner, J.D. is the 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. In the meantime, we are continuing to work towards improved health and environmental protections – including reducing lead in drinking water. We’ll plan to keep sharing developments regarding lead in drinking water that may be useful to you. In the meantime, please stay safe and healthy.

With the comment period now closed on the Environmental Protection Agency’s proposed revisions to its Lead and Copper Rule (LCR), agency staff are busy reviewing the 687 distinct comments submitted to the docket with a goal of finalizing the rule by the end of the year. To help water professionals plan ahead, the cover article in the March edition of Journal AWWA walks readers through the proposal and its implications. It ends with six suggestions to water systems that include developing a service line material inventory and identifying funding strategies to accelerate full lead service line (LSL) replacement.

With this suggestion in mind, we are continuing our work evaluating state efforts to develop LSL inventories by taking a closer look at reporting by Wisconsin municipal and private water utilities[1] to the state Public Service Commission (PSC) for calendar year 2018.[2] Of the other states with mandatory inventory reporting, we have previously covered Illinois in detail and will evaluate Michigan’s newly released reports soon. The only other state with mandatory reporting is California, but it has limited value because it only covers the portion of the service line owned by the utility and excludes the portion on private property.

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Posted in Drinking water, Lead / Also tagged , , | Comments are closed

EDF asks EPA to strengthen key lead service line definition, inventory, and notification provisions in its proposed revision to the LCR

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: December 13, 2019

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

See all blogs in our LCR series.

Yesterday, EDF submitted comments to the Environmental Protection Agency (EPA) on their proposed revisions to the Lead and Copper Rule (LCR), focusing on changes that EPA should to make to the:

  • Definition of a lead service line (LSL);
  • Requirements for water systems to develop LSL inventories; and
  • Notification of individual consumers who drink water that passes through an LSL.

We highlighted strengths and weaknesses of the LCR in a blog earlier this week, and we encourage states and communities to consider adopting the positive provisions now in addition to the changes we ask EPA to adopt in these comments. Below is a summary of our comments on these three issues. We plan to address other issues on the proposed revisions to the LCR in later comments.

Lead Service Line Definition

EPA’s proposed change to the current definition of an LSL at 40 CFR § 141.2 is flawed because it continues to exempt goosenecks, pigtails, or other connectors made of lead. These connectors are a major source of lead in drinking water not just because they are made of lead, but because they can release significant amounts of lead particulate into water as they flex with temperature, are scoured by turbulent water flow, and as other conditions change.

The exemption of these connectors from the definition of an LSL would render a water system’s LSL inventory and periodic notices to customers misleading because service lines described as “non-lead” may actually have some lead pipe in them. This will give residents a false sense of security. We recommend that the agency modify the proposed definition by deleting the exemption and explicitly stating that goosenecks, pigtails and connectors made of lead are LSLs.

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Posted in Drinking water, Lead, Regulation / Also tagged , , , , | Authors: / Comments are closed

Despite its flaws, states and communities should get ahead of the curve on EPA’s proposed lead in drinking water rule

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: December 10, 2019

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

See all blogs in our LCR series.

In October, the Environmental Protection Agency (EPA) proposed changes to its outdated Lead and Copper Rule (LCR), the federal regulation designed to control those contaminants in drinking water. As the result of more than a decade of work by dedicated agency experts, the proposal makes several improvements to key parts of the rule, including requirements for lead service line (LSL) inventories and customer notification. LSLs are the lead pipes that connect the main under the street to homes and buildings and are the most significant source of lead in drinking water.

Unfortunately, EPA’s proposed rule has several serious flaws, including that it:

  • Continues to treat full LSL replacement as a last resort. The proposed rule should make LSL replacement an integral part of a long-term solution, including periodic benchmarks for all water systems to achieve regardless of water testing results.
  • Continues to allow water systems to conduct partial replacements where the property owner is unwilling or unable to pay the cost for the portion not owned by the water system. Partial LSL replacement may significantly increase lead levels in drinking water for months and does not reliably reduce lead levels in the long term. While water systems would be required to gives residents tools (e.g. advanced notice and filters) to reduce the exposure, more is needed. EPA’s own analysis finds that relying on a resident’s ability-to-pay to replace the LSL on their property to avoid partial replacements will leave low-income households with disproportionately higher health risks.
  • Backslides on the rate of mandatory LSL replacement. When a water system’s lead levels are so high that full LSL replacement is mandated, EPA proposes an annual replacement rate that gives the system at least 33 years rather than the current minimum of 15 years to replace all of its LSLs. While more systems are likely to have to conduct mandatory full LSL replacement because of the stricter sampling requirements, most will not.

EPA is accepting comments on the proposed revisions until February 12, 2020. We are preparing detailed comments calling for the agency to fix the flaws before finalizing the rule, and we encourage others to comment as well.

Despite these shortcomings, we want to highlight four positive elements of the proposed rule and encourage states and communities to consider implementing them now – not just because they are likely to be required in the future – but also because they set the stage for full LSL replacement. These elements are that water systems must:

  • Develop an LSL inventory, update it annually, and make it publicly accessible;
  • Notify customers that they have or may have an LSL;
  • Take precautions when disturbing LSLs; and
  • Sample more homes with LSLs and take earlier action based on the results.

In this blog, we provide an overview of these key improvements. In future blogs, we will describe our recommendations to strengthen the rule based on our comments to the agency.

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

Taking on the lead challenge: State and community action accelerates across the country

By Sam Lovell / Published: September 3, 2019

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

In January, we reported on the tremendous progress made by states and communities in 2018 to replace lead service lines (LSLs) – the estimated 6.1 million lead pipes across the country that connect homes and other buildings to the water main under the street. At that time, our tracker stood at 95 communities and 16 states working to replace LSLs.

Half a year later, and the total number of communities (including municipalities and water utilities) EDF has learned of that are leading the way has swelled to 181.[1]

  • 7 communities located in Massachusetts, Michigan, Oregon, South Dakota, Washington, and Wisconsin have publicly announced that they completely replaced all known LSLs.
  • 108 communities have publicly set a goal of eliminating LSLs on public and private property, totaling more than 381,000 LSLs. Nearly ¾ of these communities are served by the investor-owned utility, American Water’s, operations in Missouri (34 communities), Indiana (27 communities), and Pennsylvania (19 communities). For the remaining states, Wisconsin is leading the way with 11 communities followed by Michigan with five; Colorado and Massachusetts with two; and Arizona, Arkansas, Montana, New Jersey, and Washington each with one.
  • 66 communities are publicly taking steps to replace LSLs but have not yet set a goal of full replacement. These communities include 15 in Wisconsin; 12 in New York; 11 in Illinois; seven in Michigan and Massachusetts; five or fewer in Colorado, Iowa, Kentucky, Minnesota, New Jersey, Ohio, Pennsylvania, Rhode Island, Texas, Vermont, and Virginia; and Washington, D.C.

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Denver Water proposes innovative plan to remove an estimated 75,000 lead service lines in 15 years

By Lindsay McCormick / Published: August 15, 2019

Lindsay McCormick, is a Program Manager. Tom Neltner, J.D., is the Chemicals Policy Director.

Update (12/18/19): EPA approved Denver Water’s Lead Reduction Program on December 16, 2019. The utility will start implementing the program in 2020. 

Yesterday, Denver Water’s board approved its proposed “Lead Reduction Program Plan” to fully replace the estimated 75,000 lead service lines (LSLs) in their system within 15 years.  The plan is an innovative solution that will remove the primary source of lead within Denver Water’s system, while avoiding the use of orthophosphate that can further exacerbate nutrient pollution problems in rivers, streams and oceans, an issue EDF’s Ecosystems team is working hard to solve.

As proposed, Denver Water would fund full replacement of LSLs through water rates, bonds and sales of new connections to the system, hydropower production and other sources rather than have individual property owners contribute.  In addition, the utility’s proposal to provide filters to residents until their LSLs are replaced represents a model other communities should consider based on the effectiveness of their ongoing pilot.  Before implementing the plan, Denver Water will need to receive approval from the Environmental Protection Agency (EPA).

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Posted in Drinking water, Lead, Public health / Also tagged , , | Authors: / Comments are closed