Water utilities
Expand Access to Clean Drinking Water for All
Address the disproportionate impacts of lead exposure.
Key Actions
Implement a prioritization strategy
Infants and children are especially vulnerable to lead exposure, making it essential to prioritize replacements where they live, learn, and play. Prioritize replacements at home-based childcare facilities, high-risk neighborhoods, and communities with elevated lead levels in water or blood tests.
Locate lead pipes and data gaps
Locate lead pipes and data gaps in your community. Your water utility is required by the US EPA to develop a service line materials inventory, which must be annually updated starting after the utility’s first year of compliance with the Lead and Copper Rule Improvements inventory requirement. This inventory is a helpful place to start when making decisions on where to prioritize lead pipe replacement and will allow you to:
- Identify neighborhoods where lead pipes are concentrated
- Identify neighborhoods with large information gaps
Identify vulnerable and at-risk populations
Identify vulnerable and at-risk populations, with support from your local public health department, to ensure they are prioritized to maximize equitable investments. Some factors to consider while prioritizing vulnerable populations include:
Children
Children are particularly vulnerable to the health effects of lead. Prioritizing lead pipe replacement in places where children live, learn, and play is critical such as child care facilities and schools as well as neighborhoods with high numbers of children and families.
Low-income communities and communities of color
Low-income communities and communities of color often face higher risks of lead exposure due to disinvestment, systemic racism, historical injustices such as redlining and segregation, and unequal distribution of resources.
Elevated levels of lead
Elevated levels of lead in water samples indicate water system violations of health and safety standards and may be a sign of failing corrosion control treatment.
Be open to conducting one-off replacements
Be open to conducting one-off replacements in places where the concentration of children’s exposure to lead is high, such as schools and home daycare centers. One-off replacements may also be a good idea when funds are already being invested in lead paint abatement, ensuring that all lead hazards are removed in tandem.
To streamline one-off replacements, consider creating an automatic replacement system for households with high lead levels based on water testing. While one-off replacements will likely be less cost-effective, in certain situations, people may urgently need lead service line replacement, such as households with infants requiring formula feeding.
Conduct inventories and replacements in parallel
Conduct inventories and replacements in parallel. Capitalize on the cost-efficiency of replacement process improvement early by starting replacements, even if the inventory has unknowns remaining. Do not wait to begin the critical work of replacing known lead pipes to protect public health.
Toolbox
Prioritization of LSLRs
LSLR prioritization plans
Advocate for policies that facilitate property access
The Lead and Copper Rule Improvements (LCRI) require water systems to fully replace the lead service lines and discourage risky partial replacements, with few exemptions such as emergency repairs. Utilities can urge relevant municipal and county leadership to help remove barriers that may preclude the utility from gaining access to replace the customer-owned portion of the service line.
Encourage city leadership to expand legal access to private property
Encourage city leadership to pass ordinances that expand legal access to private property to replace the customer-owned portion of the line. While state or local law may grant access to the water utility (e.g., for inspections), the property owner typically must provide consent to replace the lead service line, usually by signing a formal access form.
Urge city leadership to allow tenant-consent
Urge city leadership to allow tenant consent to replace lead service lines if landlords are not present (see: Mayors’ Roadmap, Principle 3, Key Action 2).
Consider automatic enrollment policies
Consider automatic enrollment policies so all customers with lead services are by default enrolled in your replacement program to expedite replacements and minimize inconveniences to customers and occupants. Automatic enrollment saves time and resources by enabling water systems to schedule projects more quickly, reducing time spent following up with property owners, and eliminating uncertainty about the scope of projects. This allows water systems to instead dedicate these resources to lead service line replacements (LSLRs).
Streamline customer agreements
Streamline customer agreements to overcome hurdles of obtaining signed agreements or consent forms to access the property and perform construction. To improve the process of obtaining signed agreements you can consider:
- Simplifying agreement language when possible.
- Using online signature platforms or pre-paid return mailings.
Toolbox
LSLR mandates
Private property access
Engage renters on replacement
Lead service line replacement at rental properties comes with unique challenges, including absentee landlords and limited incentives. However, these properties often house children and may pose higher lead exposure risks. Clear communication with tenants about health risks and the replacement process is essential.
Communicate directly with renters
Communicate directly with renters to help people understand the risks posed by lead service lines and what they can expect from the program. Effective communication and coordination with community members are key to a successful replacement program.
Communicating through a diversity of channels such as bill inserts, social media campaigns, websites, and door-knocking can help ensure you communicate with the people who are directly affected by lead service lines. This is particularly relevant for many urban communities with a high percentage of renters living in older buildings where lead service lines are suspected, such as New York City and Chicago.
Support legislation enabling tenant consent
Support state and local legislation to allow renters to provide consent to replace the lead service line, particularly if the landlord is not present or unresponsive. Replacing the customer-owned portion of the line typically requires consent from the property owner to replace the lead service line, usually by signing a formal access form. This can be challenging when landlords are unresponsive or absent, unjustly placing the burden and risk of lead exposure on renters.
Work with partners in different sectors
Work with partners in different sectors, such as housing associations, to elevate the importance of engaging landlords to replace lead pipes at their rental properties and to coordinate with lead-based paint remediation and abatement. Replacing a single lead pipe in tenant-occupied multi-family housing has the added benefit of reducing lead exposure to multiple families without significant additional direct costs.
Toolbox
Ordinances enabling renter consent for LSLR
Tenant consent forms
Cover the cost of full lead pipe replacement
Partial replacements often happen when property owners are responsible for costs, typically affecting low-income households that may be reluctant or unable to pay. To prevent increased lead exposure in vulnerable communities, aim for full replacements at no direct cost to property owners.
Establish a program at no direct cost to the homeowner
Establish a program at no direct cost to the homeowner by leveraging federal, state, and municipal funding (see: Principle 2). Avoiding or minimizing the cost a customer bears directly increases customer participation in lead service line replacement programs because customers do not have to take on the entire financial burden. It also decreases the risk of ongoing exposure for low-income households and communities of color that cannot afford to pay for replacement.
Spread costs across your entire ratepayer base
If relying on rates, spread costs across your entire ratepayer base, not just those residential customers with lead service lines. Smaller annual increases to water rates spread across the customer base may be more palatable to customers than requiring the customer or one class of customers to bear the entire cost of the private side replacement. Utilities should also consider alleviating the financial burden for low-income and disadvantaged communities (see: Principle 2, Key Action 2). However, it is important to determine if any local or state laws would preclude the use of these approaches.
Maximize cost-efficiencies
Maximize cost-efficiencies by coordinating capital improvement projects such as water main replacements (see: Principle 3, Key Action 3), providing incentives to reduce costs, and building a skilled workforce and contractor base (see: Principle 6).
