The American Water Works Association (AWWA) has announced its support for the Environmental Protection Agency’s (EPA) new proposal to accelerate the removal of some 9.2 million lead service lines across the U.S., but also recognized the realities attached to such an ambitious goal.
The EPA’s newly-proposed rule on November 30 would ramp up water utilities’ annual lead service line replacement quotas from the current rate of 3% to 10%, with the target of replacing the vast majority of lead pipes within 10 years. While the $15 billion for lead service line replacements allocated by Congress in 2021 will help to fund the nationwide initiative, the AWWA warned that water bills will rise to pay for it.
“Cost will also be a significant challenge in replacing all lead service lines, especially when considered alongside competing priorities such as PFAS removal, cybersecurity upgrades, and other critical infrastructure investments,” AWWA CEO David LaFrance announced in a statement.
The average cost to fully replace a single lead service line is more than $10,000, and the EPA estimates there are more than nine million lead lines connecting homes to water systems nationwide. The total cost could easily exceed $90 billion, the AWWA warned.
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Not taking action to replace lead service lines across the U.S., however, could prove to be even more costly when it comes to health care costs. One recent study estimated that replacing lead pipes would cost 15 times less than the resulting health impacts that could develop over the next 35 years. Lead leached into drinking water from water pipes connecting homes to water mains is linked to brain damage in children and other health problems.
Beyond sheer cost, the AWWA recognized that communities and their local partners will have to overcome a number of other barriers to meet the 10-year lead pipe replacement target. For example, not every property owner is agreeable to service line replacements, even when free, and many states would not have legal access to the property without permission.
In other communities, the AWWA notes that water systems will face logistical challenges as they coordinate lead service line replacements with street improvement projects or other large capital projects, all within a tight labour market for contractors.
Lead action levels, inventories, and tap sampling
In addition to the new replacement target schedule, the EPA is also proposing to lower the Lead Action Level from 15 to 10 micrograms per litre to get systems to take action sooner to control corrosion. This means that when a water system’s lead sampling exceeds 10 micrograms per litre, the system would be required to inform the public and take action to reduce lead exposure, while also working to replace all lead pipes.
The proposed rule also seeks to improve community inventories required for locating legacy lead pipes. While water systems are currently required to provide an initial inventory of all lead service lines by October 16, 2024, the new EPA proposal would also require systems to regularly update those inventories, create a publicly available service line replacement plan, and identify the materials within service lines of unknown material. Drinking water systems would need to more frequently communicate with residents about the utility’s plans to replace lead service lines.
EPA has proposed improvements to the Lead and Copper Rule to achieve 100% replacement of lead service lines within 10 years. This rule will improve public health, create good-paying jobs, and ensure all communities have high-quality #SafeDrinkingWater. pic.twitter.com/F6UxOXThP5
— U.S. EPA Water (@EPAwater) December 1, 2023
The EPA’s proposed lead pipe rule also targets protocols that water systems must use for tap sampling. Water systems would be required to collect first litre and fifth litre samples at sites with lead service lines and use the higher of the two values when determining compliance with the rule. The EPA said this best practice is already being deployed at the local and state level in places like Michigan.
“EPA’s proposed Lead and Copper rule is grounded in the best available science and successful practices utilized by drinking water systems to protect children and adults from lead in drinking water,” announced EPA Assistant Administrator for Water, Radhika Fox, in a statement. “Cities like Newark, NJ, Benton Harbor, MI, and Green Bay, WI have all successfully gotten the lead out of their water systems. Our proposed rule applies the lessons learned to scale these successes to every corner of the country.”
Before the EPA finalizes a drinking water regulation, it publishes a proposed rule to get feedback that it will consider when developing a final rule. The proposed Lead and Copper Rule Improvements are expected to be finalized in 2024. The agency will hold a virtual public hearing on January 16, 2024.
