Lead Service Lines: The Good, the Bad, the Money
By Alanna Kinnebrew
Figure is a simplified illustration of the components of a service line installation
Source: LSLR Collaborative
Since the Flint, Michigan water crisis, there has been heightened awareness concerning the dangers of lead and how exposure to this poisonous metal affects the human body. Based on the proposed amendments to the EPA’s Lead and Copper Rule Revisions (LCRR), there are as many as 9.3 million lead service lines (LSLs) in use across the United States. For Georgia, a 2016 national survey of water utilities showed that there was an estimated 86,000 LSLs in the state, but where they are all specifically located is unknown. LSLs connect the main drinking water line from the street to homes and buildings, which puts many Americans at risk for lead exposure. In order to mitigate this risk, nonlead piping is installed. The process is better known as “lead service line replacement” (LSLR), where both the public water system’s portion of the LSL and the homeowners’ portion are replaced. With water woven into the list of top priorities for the federal government, lead in water has become a main focus in proposed funding packages such as the American Jobs Plan, which proposes allocating $45 billion to fully replacing LSLs across the country.
Equity and Cross Subsidies
Because the water utility owns the pipe from the street to the property line/water meter, historically the homeowner is responsible for their own pipe replacement from the property line to the house. The “bad” is that this could range from $1,200 – $12,300 leaving many low-income households unable to pay for replacement which raises health, equity, and environmental justice concerns.
As part of the EPA’s LCRR, the environmental justice evaluation indicated that any “household-level changes that depend on ability-to-pay will leave low-income households with disproportionately higher health risks.” Due to health and safety concerns, many utilities are aiming to pay for some, or all, of the costs associated with full LSLR. It is important to consider the unintended consequences that leave low-income and minority households at greater risk of lead exposure.
The Good: Existing Replacement Approaches
Here are some examples of what cities across the U.S. have done to tackle their LSL concerns. It is important to note that the 2018 America’s Water Infrastructure Act makes it clear that LSLR projects are eligible for federal funding. Going forward, the Drinking Water Infrastructure Needs Survey and Assessments (DWINSA), which determines State Revolving Fund allocations, will require states to include an estimated number of public and private lead service lines as well as the costs associated with replacing those lines unless they can demonstrate that they have no LSLs.
Newark, New Jersey
Due to a federal lawsuit, Newark embarked on project that replaced over 18,000 LSLs. The city raised the money for the replacement through a bond which sped up the process and made it free for homeowners.
Washington, D.C.
In October, 2019, Washington, D.C. began their journey to cover the complete cost of LSLR on private property when DC Water replaced the portion of lead pipe in public space during a Capital Improvement Project. If both the public and private portions of the service line are lead and no capital improvement is scheduled for two years, property owners could enroll in the Voluntary Lead Service Pipe Replacement Program.
Green Bay, Wisconsin
In October 2020, the Green Bay Water Utility initiated a concerted effort to replace both public and private LSLs. They established a comprehensive LSLR program that required property owners to replace private side lead services within a year of their discovery. The city utilized state funding and the utility was then able to complete private LSLRs at no direct cost to residential customers due to Drinking Water State Revolving Funds (DWSRFs).
Parchment, Michigan
The city of Parchment had to change to a new source due to high levels of PFAS found in their water supply. The city of Kalamazoo who then took over control of Parchment’s water identified homes served by lead lines and began replacing them with copper in 2019. The cities identified about 300 homes with LSLs and replaced them using state funding.
The Money: Funding Options
Funding the replacement of customer-owned lead service lines is one of the most challenging aspects of reducing lead in drinking water and a significant policy issue that water systems must address.
Safe and affordable drinking water should be accessible to all, regardless of income, race, or ethnicity. Unfortunately, ensuring said access is not free. Therefore, it is important for utilities to implement thorough asset management plans that can help proactively prepare for the costs associated with projects such as LSLRs. As the previous section points out, some cities have already worked on LSLR projects and many more are gearing up to take on this task. With this in mind, we should ensure monetary resources are made available so that utilities can begin the planning process. Below are a few funding sources that can aid water utilities with LSLR.
The EPA has created a resource, Funding for Lead Service Line Replacement, which provides various funding resources. The list includes the DWSRF.
Another SRF-related federal resource to note is the Water Infrastructure Fund Transfer Act (WIFTA) which was passed in 2019. WIFTA allows states a one-time transfer from the Clean Water State Revolving Fund (CWSRF) to the DWSRF for lead-related, DWSRF-eligible projects.
Using rates revenue to cover the cost of replacing the portion of LSL on private property. This option may not work for some utilities due to state or local policies that prohibit this because it solely benefits the property owner. However, others may have the greenlight to do so due to new laws and policies that have allowed revenue from rates, with some limitations, to be used to replace the side on private property.
If utilizing rates revenue isn’t an option, cities could also look into leveraging bonds, similar to what took place in Newark, NJ, to fund LSLRs.
Although this list is not comprehensive, it provides a starting point for obtaining funding to replace LSLs.
Closing
Water utilities face a variety of constraints and challenges that were not anticipated when most water infrastructure was designed and built. Replacing lead service lines is a costly process which is why there are some funding options that can aid in the onslaught of projects that will continue to pop up. To begin prioritizing our aging water infrastructure, we need to tackle lead exposure in drinking water at its source and the most effective way to do so is to limit exposure by completely removing lead service lines. Although this is a huge undertaking, a more proactive approach instead of reactive one is necessary when it comes to lead service line replacement. Lead-related health crises, like in Flint, have increased public attention and a call to remove and replace lead service lines. It is important now more than ever for the water sector to have all its ducks in a row as America gears up to rebuild our nation’s aging water infrastructure.
This is part of a blog post series funded by the Georgia Environmental Finance Authority (GEFA).
Disclaimer: The opinions of the writers should not be considered legal advice or endorsement by GEFA.
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