Prioritizing Equity and Public Health: Collaborative Strategies for Lead Pipe Replacement

Low-income and black communities are particularly vulnerable to lead exposure. Not only are they disproportionately exposed to lead in drinking water, but, as analysis of a case study in Washington, DC shows, racial and income disparities exist in lead pipe replacement rates for both capital improvement and customer-initiated lead service line removal programs.

Replacing the Lead Service Line (LSL) is expensive but necessary. Most commonly, people ingest lead through drinking water from corroded lead water pipes. As cities steer the LSL replacement process, equity must be a key consideration. Lead exposure is dangerous at any level, especially for children. Employing equitable LSL replacement strategies will help ensure everyone has access to safe, clean drinking water.

Although federal funding is available for LSL replacement, it is insufficient to meet needs in communities across the country. Many federal funding options also come in the form of loans that must be repaid, which could further exacerbate affordability problems. The upcoming changes to the EPA’s lead and copper rule indicate urgent public health goals, but will compound the challenge with additional costs and compliance burdens for local governments to inspect, monitor and replace lead piping. NLC continues to advocate for grants for local water infrastructure projects.

Identifying community needs

The first step in replacing LSLs is to understand the extent of the problem. The EPA’s revision of the lead and copper rules requires cities to complete LSL inventories for all service lines in their distribution system by October 16, 2024. The EPA provides guidance on creating a service line inventory, and other tools such as ArcGIS Lead Service Line Inventory Solution can help cities create and maintain LSL inventories.

Once a community has established an inventory, it should begin creating a replacement plan and prioritizing areas for an LSL replacement program based on community vulnerability and environmental justice considerations. Environmental justice mapping tools, such as the EPA’s Environmental Justice Screen and Mapping Tool, can help identify areas of greatest need. It is important to take action to reach areas of the community where the most vulnerable populations are more concentrated: people living at or below the poverty line, historically BIPOC communities, pregnant women and women of childbearing age as well teenagers. Priority should also be given to areas with a higher concentration of youth organizations such as day-care centres, youth centers and schools. Rental housing also needs to be a focus, as tenants often earn lower incomes and non-resident homeowners have less incentive to replace lead piping on their property.

Balancing cost and effectiveness

A major challenge in creating an LSL exchange program is deciding between a partial or full exchange program. Partial line replacement means that the LSL is replaced on the public side and property owners are responsible for replacing the section of pipe on their side of the property line if they so choose. Conversely, a full line replacement program involves replacing the service line on both sides of the property line at the same time.

Partial line replacement is less expensive for cities to implement and avoids the need to force homeowners who are unwilling or financially unable to replace their lines. However, partial LSL replacement can increase the risk of lead contamination because lead particles are released during construction and digging, and the new pipe materials encourage erosion of the older lead pipes. Also, the replacement process slows down as property owners are held responsible for making decisions about replacing their pipes and making arrangements for the replacement. In rental housing, landlords are less likely to prioritize these upgrades, meaning tenants continue to be exposed to lead in their water.

Comprehensive replacement programs are the best way to eliminate the risk of lead contamination, but they still leave the cost issue to the homeowner. Some cities, like Denver, CO, subsidize full LSL removal for low-income homeowners. The program is subsidized through water bills, bonds and the sale of new connections. In some cases, however, state and local restrictions on the use of fee funds prevent water utility funds from being used to subsidize LSL replacement on private property. In these cases, state and federal grants can help. True to its name, Eau Claire, WI passed an ordinance requiring property owners to replace LSLs discovered on their land within 90 days of the trace being discovered. Homeowners can receive up to $2,600 in pipe replacement financial assistance from the city thanks to a grant from the Wisconsin Department of Natural Resources. Toledo, Ohio, has gone a step further, combining federal and state funding sources through ARPA, the EPA’s Environmental Justice Grant Program, the HUD’s Community Development Block Grant Program, and the Ohio EPA’s Water Replacement Loan Program to replace all lead pipe in the city at no cost to replace the property owner.

When programs are funded, even partially, by utility bills, cities and water companies should be careful not to drive tariffs out of reach. Low-income people are disproportionately burdened by rising electricity tariffs and should not risk having their electricity suppliers shut down due to insolvency or being forced to choose between paying utility bills and other necessities of life.

Identification of important partners

Community engagement and partnerships are helpful in raising awareness, building trust, and increasing access to LSL replacement programs. Outreach and working with public health centers, community centers, and organizations that serve BIPOC communities, low-income people, and other vulnerable populations are critical to building equitable replacement programs. Community partnerships also improve public communication about exposure risks and advance notice of construction disruptions.

The LSL Replacement Collaborative is another useful resource for cities. It provides a toolkit of LSL replacement strategies, including step-by-step instructions for conducting an equity analysis of LSL replacement programs. Adaptable to communities of any size, the Equity Analysis Guide takes into account historical development patterns and provides strategies for effective engagement and communication about LSL replacement programs.

Communities in Connecticut, New Jersey, Pennsylvania and Wisconsin can access technical assistance to address lead prevalence in underserved communities through the EPA’s Lead Service Line Replacement Accelerators initiative. Through the program, participating cities can access assistance in applying for State Revolving Funds and preparing LSL inventories, community engagement plans, and LSL replacement plans.

The replacement of LSLs requires the use of extensive manpower. Investing in LSL replacements could create thousands of jobs nationwide. But with the current workforce shortage for infrastructure jobs, cities can also turn to partners like HomeServe USA for additional assistance removing leading service lines. All NLC member cities have access to HomeServe through their membership.

Tightly timed EPA regulations, historically still insufficient federal funding, and major public health and environmental justice concerns over the continued proliferation of millions of lead pipes are putting cities in a challenging position. NLC is here to help cities find tools to inventory, monitor, and fund their lead pipe replacements.

About the author

About the author

Ayesha Mehrotra is the Program Manager for Health and Resilience at the National League of Cities.

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