Priority 3
Establish equitable policies and practices
Address the disproportionate impacts of lead exposure.
Low-income, rural, and communities of color can face higher risks of lead exposure due to historical injustices such as unequal resource distribution and disinvestment, the impacts of which persist today. EPA encourages lead service line replacements to be prioritized in underserved and overburdened neighborhoods. An equitable replacement program acknowledges social and economic disparities, providing support based on the community’s need.
Key Action 1/3
Prioritize vulnerable residents and neighborhoods
Consider prioritizing locations where vulnerable individuals live or frequent, including child care facilities, neighborhoods with high numbers of children and families, as well as other locations based on socioeconomic factors, elevated levels of lead in water samples, high blood lead levels, and other indicators of increased risk.
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 October 2024. 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 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 (particularly home-based facilities) and schools as well as neighborhoods with high numbers of children and families.
- 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 in water samples which indicate water system violations of health and safety standards and may be a sign of failing infrastructure.
Be open to conducting one-off replacements
Be open to conducting one-off replacements in places where the risk of lead poisoning is known and/or extremely high. While one-off replacements will likely be less cost-effective, in certain situations, people may urgently need lead service line replacement.
Conduct inventories and replacements in parallel
A service line inventory does not need to be complete to begin the critical work of replacing known lead pipes to protect public health. A partially completed inventory may highlight neighborhoods with high concentrations of lead that can be addressed upfront.
Examples of lead service line replacement prioritization plans:
Milwaukee Water Works, WI leveraged the Area Deprivation Index
Greater Cincinnati Water Works collaborated with University of Cincinnati to develop a Prioritization model
DC Water prioritization based on presence of minority residents and median household income
Denver Water utilizes data and predictive modeling to prioritize replacements based on numerous factors such as disadvantaged neighborhoods, socioeconomic indicators, and areas with high concentrations of schools, childcare facilities, and expecting families
The Area Deprivation Index developed at the University of Wisconsin-Madison includes factors like income, education, employment, and housing quality
The Guide to Equity Analysis developed by the Lead Service Line Replacement Collaborative provides recommendations to implement an equitable program, including data sources to use in prioritization decisions
Key Action 2/3
Engage homeowners and renters on replacement
Lead service line replacement at rental properties has its own set of unique challenges, including hard-to-reach property owners, lack of incentives, and other barriers. Informing residents of the risks of exposure and what to expect from the replacement program is especially challenging when the person who pays the bills and the person who drinks the water are not the same, such as in renter-occupied properties.
Communicate directly with homeowners and renters
Communicate directly with homeowners and 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 is key for a successful replacement program. Communicating through a diversity of channels such as bill inserts, social media campaigns, websites, and door-knocking can help ensure that the people who are directly affected by lead service lines receive the message. 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.
Allow renters to provide consent to replace the lead service line
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, usually by signing a formal access form (see Ensure Full Lead Pipe Replacement for more on removing barriers for the utility to access properties). This can be challenging when landlords are unresponsive or absent, unjustly placing the burden and risk of lead exposure on renters.
Enable renters to make informed decisions
Enable renters to make informed decisions and know their risk of exposure by requiring landlords to disclose the presence of lead service lines, lead connectors, and lead premise plumbing (see Increase Transparency and Build Trust).
Work with partners in different sectors, such as housing associations
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. 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 cost.
Examples of door-knocking and renter outreach
Youngston, Ohio Mayor Jamael Tito Brown and US Environmental Protection Agency Administrator Michael Regan went door-to-door, talking to residents about lead service line replacement
Americorps volunteers in Lancaster, PA support efforts to collect inventory information
Mayor Montello along with Rensselaer Polytechnic Institute students went door-to-door to canvass in Troy, NY
College students went door-to-door to support the service line inventory in Port Byron, IL
Examples of legislation granting utilities property access
- City of Newark, NJ ordinance authorizing utilities to access properties and enabling renters to grant consent where owners are unresponsive
- Indiana legislation allowing water utilities to access properties to conduct replacements
Examples of tenant consent forms
- Newark, NJ Right of Entry Form
- Denver, CO Acknowledgement and Consent for Lead Service Line Replacement
- Flint, MI Consent to Service letter
LSLR Collaborative Webinar: Rental Properties: Overcoming Barriers to Lead Service Line Replacement
Unleaded Kids/EDF Blog: Engaging Landlords and Tenants in Lead Service Line Replacement
Key Action 3/3
Conduct replacement at no direct cost to the property owner
When utilities only replace the public portion of the service line (partial replacement), it is commonly expected that the property owner will pay to replace the portion of the line that is on their property. Many property owners, especially low-income homeowners and landlords, may be reluctant or unable to pay these costs. To avoid increasing the risk of exposure to vulnerable communities, ensure your water utility is avoiding partial replacements by taking steps to cover full service line replacement at no direct cost to the property owner.
Establish a program at no cost to the homeowner
Establish a program at no cost to the homeowner by leveraging federal, state, and municipal funding (see Make a Financial Plan). Avoiding cost-sharing practices increases customer participation in lead service line replacement programs because customers do not have to take on the 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.
If relying on rates, where allowed, spread costs across your entire ratepayer base
If relying on rates, where allowed, spread costs across your entire ratepayer base, not just those with lead service lines. Small annual increases to water rates spread across the customer-base may be more palatable to customers than costly cost-sharing of replacement, alleviating the financial burden for low-income and disadvantaged communities, especially when paired with an affordability program (see Tap into municipal resources).
Maximize cost-efficiencies
Maximize cost-efficiencies by coordinating capital improvement projects such as water main replacements (see Adopt policies and practices that increase cost-efficiencies).
Examples of replacement programs at no cost to the homeowner:
Milwaukee, WI uses Bipartisan Infrastructure Law funds to cover the costs of private-side replacement
Detroit, MI utilizes federal and state funding to pay for full lead service line replacement
Denver Water, CO uses federal funding, rates, bonds, and other sources to cover the full cost of lead service line replacement
Example of using water rates to cover replacement costs:
NJ American Water implemented a lead service line replacement surcharge for all its customer base
EPA Identifying Funding Sources for Lead Service Line Replacement
EDF’s Transparency in action map spotlights lead service line replacement programs across the country, including financial assistance for private side replacements
EDF Report: Lead Pipes and Environmental Justice. A study of lead pipe replacement in Washington, DC
EPIC Brief: Advancing Lead Service Line Programs with Low or No-Cost Policies and Practices
EPIC Brief: Good Decision-Making and Planning for Lead Service Line Cost Efficiencies
EPIC Brief: Stretching the Dollar to Get the Lead Out: Lead Service Line Contracting