making significant investments in infrastructure improvements and other measures to reduce exposure to lead in drinking water. This work is well underway, but a great deal more remains to be done. We feel strongly that, to keep water utility rates affordable for our most vulnerable citizens, additional funding will be necessary. For this reason, the GLLC’s Task Force on Lead is examining policy recommendations for innovative financing measures that we can implement to make it less costly to conduct testing and replace infrastructure. Increases in federal funding, such as the Drinking Water and Clean Water State Revolving Funds, also will be necessary.
2. Lead Service Lines: Inventories and Replacement
We agree with the proposed requirement for community water systems to conduct an inventory of their service lines to determine where lead is present, where it is not, and where there isn’t sufficient information to make a determination. We encourage EPA to define exactly what is expected of the inventory in terms of documentation and acceptable methods of determining whether pipes and other plumbing components contain lead. An improvement to the proposed revision would be to establish a deadline for completing the initial inventory and a timeframe for updating it at regular intervals. It is also important for the results of these inventories to be available to the public in a manner that is easy to access and understand. With regard to the replacement of lead service lines, we agree with the proposal to require the full replacement of lead service lines instead of partial replacement, which is currently allowed. EPA proposes to continue to allow partial replacements in certain situations (e.g., emergency repairs). Because there is evidence that partial lead service line replacement can lead to increased exposure to lead particles, at least temporarily, we urge EPA to very narrowly define what would constitute an emergency or other situation that could warrant partial replacement of lead service lines despite the potential risk to public health. We would like to see EPA propose a more aggressive timeframe for replacing all lead service lines. With the proposed new 3% annual replacement rate (coupled with changes to what counts as “replacement”), EPA estimates that it will take 33 years to replace problem lines after the 15 μg/L action level has been exceeded. We strongly urge EPA to consider following a more aggressive timeline such as Michigan’s 20-year timeframe.
3. Schools and Child Care Facilities
The GLLC’s model policy expanded upon the excellent example set by Illinois to call for all schools and all licensed child care facilities to test their drinking water for lead. We agree with EPA’s proposal to require that community water systems “sample drinking water outlets at each school and each child care facility served by the system.” To answer a question posed by EPA, we think it is preferable to have this testing requirement apply to all schools and child care facilities instead of limiting it to those that actively request testing.
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