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EPA’s three new service line notices: Critical to transparency and accelerating lead pipe replacement

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: January 21, 2021

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

This is the second in a series of blogs evaluating various aspects of EPA’s December 2020 revisions to the Lead and Copper Rule (LCR) and what they may mean for accelerating lead service line (LSL) replacements. The blogs cover: 1) new service line inventory; 2) three new LSL notices; 3) environmental justice implications; 4) communicating health effects of lead; 5) economic implications; and 6) sampling and trigger/action level.

Note that President Biden’s Executive Order on Protecting Public Health and the Environment and Restoring Science to Tackle the Climate Crisis directs agencies to review the former administration’s regulations and actions, including the Lead and Copper Rule. 

Three new notices required by the revised LCR from water systems to people with known or potential LSLs provide critical opportunities to build public support for LSL replacement by helping individuals better understand their situation and specific actions they should take. However, we recognize that, like all notices, many people may simply ignore them, especially if only delivered as an insert to a monthly or quarterly bill. We anticipate that notices will be most effective when coupled with broader outreach efforts and requirements that property owners share the notice with potential buyers and tenants.

As explained in a previous blog on the new service line inventories, water systems must assign all service lines to one of four categories. The rule treats three categories – “Lead,” “Galvanized Requiring Replacement,” and “Lead Status Unknown” – as known or potential service lines containing lead. People receiving water from a service line in any of these three categories must receive three new types of notices designed to prompt them to take steps to address the risk of lead in their drinking water pursuant to 40 CFR § 141.85(e) to (g). The three types of notices are:

  1. An annual notice;
  2. A notice of disturbance to service line; and
  3. A notice if trigger or action levels exceeded.

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

EPA’s new service line inventory: The good, the bad, and the absurd

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: January 19, 2021

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

This is the first in a series of blogs evaluating various aspects of EPA’s December 2020 revisions to the Lead and Copper Rule (LCR) and what they may mean for accelerating lead service line (LSL) replacements. The blogs cover: 1) the new service line inventory; 2) three new LSL notices; 3) environmental justice implications; 4) communicating health effects of lead; 5) economic implications; and 6) sampling and trigger/action level. 

Note that President Biden’s Executive Order on Protecting Public Health and the Environment and Restoring Science to Tackle the Climate Crisis directs agencies to review the former administration’s regulations and actions, including the Lead and Copper Rule. 

The backbone of the revised LCR is a new service line inventory[1] that all public water systems, whether large or small, rural or urban, must develop by January 2024 unless they can demonstrate that they have no LSLs. If properly designed and implemented, the inventory should transform how utilities, communities and states approach LSLs by moving from rough estimates to a data-driven approach that allows water systems to identify what is known and not known about the service lines, communicate that information to the public, and establish LSL replacement priorities.

Unfortunately, EPA has included an unfortunate and absurd new detail in the inventory that requires systems to categorize service lines that contain a two-foot piece of lead pipe, often known as a gooseneck, as “Non-lead.” We anticipate that the absurdity of calling a lead pipe “Non-lead” will undermine the inventory’s credibility and effectiveness.

What is the new service line inventory and how is it used?

By January 2024, water systems must submit a service line inventory to the state and make it publicly accessible pursuant to 40 CFR § 141.84(a). To develop the inventory, they must assign all service lines, regardless of ownership, for the portions on public or private property to one of four categories:

  1. Lead: where a portion of the service line is made of lead (excluding lead connectors, such as goosenecks, as explained below). We presume this includes lead-lined pipe.
  2. Galvanized Requiring Replacement: where a portion of the service line is galvanized iron or steel.[2] If the system can determine that the galvanized pipe was never downstream of an LSL (or lead connector, such as a gooseneck[3]), then it is essentially a galvanized pipe not requiring replacement and can be categorized as “Non-lead.”
  3. Non-lead: where the line is determined not to be “Lead” or “Galvanized Requiring Replacement” (see discussion below for lead connectors). Our understanding is that systems could assume service lines installed after the 1986 federal ban on lead pipe are “Non-Lead.”
  4. Lead Status Unknown: where it has not been determined if the service line met the SDWA Section 1417 definition of “Lead-free” at 42 U.S.C. § 300g-6. We presume this means that solder or flux must be less than 0.2% lead and other wetted surfaces must be less than 8% from 1986 to 2013 and less than 0.25% for 2014 to present.[4]

Under these requirements, a service line is classified as an LSL if it is in the “Lead” or “Galvanized Requiring Replacement” categories.[5]

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

Why now is the moment for cities around the world to act decisively on air pollution

By Sarah Vogel / Published: June 30, 2020

Sarah Vogel, Ph.D., is Vice President for Health.

This is the second in a series of Global Clean Air blogs on COVID-19 and air pollution. EDF scientists and program experts will share data about pollution levels during quarantine from a local and global perspective, and provide recommendations for governments and companies to Rebuild Better.

Around the world, we’ve seen dramatic improvement in air quality as a result of the response to COVID-19. While it’s come from an artificial and unwanted brake on the global economy, it’s drawn renewed attention to the devastating impacts of outdoor air pollution.

As many large cities around the world emerge from lockdown, city authorities need to act decisively to prevent air pollution rebounding and even exceeding pre-COVID-19 levels. That was the conclusion of participants in a “Clear Skies to Clean Air” webinar I moderated last week by the Organisation for Economic Co-operation and Development World Wildlife Fund and Environmental Defense Fund, in collaboration with the World Bank.

The improvements in air quality seen during the COVID-19 lockdown have shown individuals and policymakers what is possible and could open the door to reinvigorated efforts to address pollution.

London and Bogotá demonstrate clean recovery strategies

The webinar heard from policymakers on the front lines of addressing air pollution: Shirley Rodrigues, Deputy Mayor of London, with responsibility for environment and energy; and Claudia López, Mayor of Bogotá, Colombia.

New COVID-19 air quality/ transportation measures in London.

Cities need devolved powers if they are to address local air pollution, argued Rodrigues: “We can’t have a centralised approach … Citizens deal with their local authorities, mayors know what is needed in their cities. Devolving powers, alongside funding, is absolutely critical so we can push the electrification agenda and the reclamation of roads, so we can avoid a car-based recovery.”

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Posted in Air pollution, Hyperlocal mapping, International, Public health, Regulation, States / Also tagged , | Authors: / Comments are closed

Amid COVID-19, the Trump administration sets dangerous air pollution standards. What is at stake for Houstonians?

By Ananya Roy / Published: May 11, 2020

Ananya Roy, Senior Health Scientist; Rachel Fullmer, Senior Attorney; Jeremy Proville, Director; Grace Tee Lewis, Health Scientist

The Trump administration’s disregard for science has been clear in the response to the COVID-19 pandemic, but it’s not the only health threat they’re making worse by ignoring overwhelming scientific evidence. For three years the administration has systematically sought to weaken clean air safeguards, endangering all Americans.

We know air pollution causes heart disease, diabetes and lung disease—and that the people suffering from these conditions are at greater risk of severe illness from COVID-19. Independent of the ongoing pandemic, air pollution is responsible for tens of thousands of deaths across America year after year. This underscores the vital importance of pollution protections to protect human health both during and after the COVID-19 crisis.

Unfortunately, EPA Administrator Andrew Wheeler has proposed to retain an outdated and inadequate standard for fine particulate matter (PM2.5) pollution despite strong scientific evidence that it must be strengthened to adequately protect human health.

To understand what having this pollution standard means for families living in the Greater Houston area, Harvard University and EDF scientists undertook an analysis of the impacts of PM2.5 exposure across the city. We found that:

  • Exposure to fine particle air pollution in 2015 was responsible for 5,213 premature deaths and over $49 billion in associated economic damages.
  • More than 75% of the health burden was borne by communities exposed to PM2.5 levels below the current standard.
  • Meeting the current standard alone would have prevented 91 deaths of the more than 5,000 premature deaths due to fine particle pollution.

By ignoring the scientific evidence and retaining the current standard, Administrator Wheeler is ignoring the very real health impacts felt by Houstonians and communities across the country from exposure to fine particle pollution.

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Posted in Air pollution, EPA, Health policy, Health science, Hyperlocal mapping, States / Also tagged , , , , | Authors: / Comments are closed

Michigan utilities report much lower percentages of service lines of lead or unknown material than Wisconsin or Illinois

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: April 21, 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.

Lead service line (LSL) inventories provide useful insights into the location and number of LSLs in states and the funding needed to fully replace these lines. In previous blogs, we examined mandatory reporting by utilities of service line material in Illinois and Wisconsin.[1] Here, we examined a March 2020 preliminary report by the Michigan Department of Environment, Great Lakes, and Energy (EGLE) summarizing data submitted by 1,029 utilities. Unlike the annual reporting in Illinois and Wisconsin, Michigan required utilities to submit a preliminary inventory by January 1, 2020 and requires a complete inventory before 2025. While the preliminary report allows lines to be designated as unknown, the material must be determined by 2025. This is a two-step process, rather than the annual report approach that California has taken.

Michigan reports less than 100,000 LSLs and 276,000 lines of unknown material that may be lead

The state’s preliminary report is based on 1,029 utilities[2] (74% of the state’s 1,386 total) with 2.40 million service lines (90% of the 2.66 million total).[3] This reporting rate is lower than what Illinois experienced at a similar stage in the first year of mandatory reporting.

For the 1,029 utilities that reported, utilities reported 99,000 (4% of total) lead, 21,000 (0.9%) galvanized steel,[4] 177,000 (7%) of unknown material but likely to be lead, and 276,000 (12%) as unknown with no information. If all of the four categories are actually lead (which is unlikely), there would be 573,000 (23%) LSLs in Michigan.

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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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