EDF Health

Selected tag(s): Lead service lines

Flaws found in EPA’s lead pipe survey of states and water utilities

By Roya Alkafaji and Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: June 29, 2023

Deep Dive: Read our Deep Dives blog for an in-depth analysis on the data that drove the 2023 allocation of federal funding for lead service line replacements.

What’s New: EPA recently estimated there are 9.2 million lead service lines (LSLs) in the nation’s drinking water infrastructure based on information reported by states and water utilities. This was collected as part of a survey conducted every four years to understand drinking water infrastructure needs.

The agency estimated the number of LSLs for each state. Two had surprisingly high numbers: Florida with 1.2 million LSLs and Texas with 650,000.

After reviewing data EPA used to estimate each state’s totals[1], we believe that these two may have less than 100,000 LSLs each. If true, this means the country may actually have about 1.6 million fewer LSLs than originally thought – good news overall.

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Top 10 cities with the most lead pipes

By Roya Alkafaji and Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: June 6, 2023

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.

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Mapping Lead: Ohio issues map of properties with known lead hazards

By Roya Alkafaji / Published: May 25, 2023

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

What Happened: The Ohio Department of Health published an interactive map showing almost 1,200 properties whose owners have refused to comply with an order to correct known lead-based paint hazards. As a result, the Department has declared these properties are unsafe to live in until the hazards have been remediated.

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. Ohio is the second state after New Jersey that we’re aware of to move beyond neighborhood-level mapping of lead risks to provide specific information at the address level.

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

By Roya Alkafaji / Published: April 28, 2023

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)

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Lead Pipe Replacement: EPA changes state shares of funding

By Roya Alkafaji / Published: April 21, 2023

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

By Roya Alkafaji / Published: March 17, 2023

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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