Equity in Lead Service Line Replacement
A guiding principle of the Collaborative is that lead service line (LSL) replacement initiatives should address barriers to participation so that consumers served by LSLs can benefit equitably, regardless of income, race, or ethnicity. An equitable program will recognize that not everyone has the same societal and economic advantages, and provide support, not equally across the population, but rather as appropriate according to an individual’s circumstance. To achieve equitable outcomes, a community LSL replacement program must:
Examples of key considerations in developing an equitable replacement programs include:
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Equity and Lead Service Line Replacement See the Collaborative webinar on equity.
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- Providing logistical support: Full LSL replacement requires participation from homeowners in order to replace the portion of the LSL on private property. As such, those with less time, ability/desire to work with contractors, and personal investment in the property (e.g., landlords), may be less likely to participate in LSL replacement programs. Equitable programs may provide logistical support to such individuals and provide resources to engage renters.
- Sequencing replacement: LSL replacement programs can be costly and can take years to fully implement. As such, difficult decisions must be made about which LSLs should be replaced first. While communities may approach these decisions in different ways, it is important for all communities to consider how consumers can benefit equitably from LSL replacement programs. Other factors communities should take care to consider when making decisions about sequencing LSL replacements include efficiencies to reduce cost (i.e., replacing more LSLs for the same expense), age of inhabitants (i.e., giving special consideration to child care centers and schools), and language barriers.
- Minimizing lead exposure post- replacement: Construction to replace LSLs may temporarily increase the release of lead into drinking water during and after replacement. Efforts to minimize lead exposure post-replacement (e.g., flushing, filters) should be implemented consistently across the community and special attention should be given to factors such as provision of educational materials in multiple languages, access to replacement filters, and education of renters in addition to landlords (especially where rental turnover is high).
Potential Civil Rights Issues
A 1994 Presidential Order directs federal agencies to “make achieving environmental justice part of its mission by identifying and addressing, as appropriate, disproportionately high and adverse human health or environmental effects of its programs, policies, and activities on minority populations and low-income populations in the United States and its territories and possessions.”
Inequities arising from environmental health hazards are often presented as environmental justice or civil rights concerns. This matter is an important consideration in developing a sustainable and successful collaboration. If the LSL replacement program is in any way funded by the federal government, Title VI of the Civil Rights Act of 1964 allows a person who believes they are disproportionately impacted based on race, color, or national origin to file a complaint with the funding agency such as the U.S. Environmental Protection Agency (EPA). If the agency finds a disproportionate impact, even if the impact was not intentional, it would either require the problem be eliminated or cut off federal funds that support the program.
A 1994 Presidential Order directs federal agencies to “make achieving environmental justice part of its mission by identifying and addressing, as appropriate, disproportionately high and adverse human health or environmental effects of its programs, policies, and activities on minority populations and low-income populations in the United States and its territories and possessions.”
Inequities arising from environmental health hazards are often presented as environmental justice or civil rights concerns. This matter is an important consideration in developing a sustainable and successful collaboration. If the LSL replacement program is in any way funded by the federal government, Title VI of the Civil Rights Act of 1964 allows a person who believes they are disproportionately impacted based on race, color, or national origin to file a complaint with the funding agency such as the U.S. Environmental Protection Agency (EPA). If the agency finds a disproportionate impact, even if the impact was not intentional, it would either require the problem be eliminated or cut off federal funds that support the program.
Additional Resources
Resources on LSL replacement and equity:
General resources on equity:
Resources on LSL replacement and equity:
- Report: Lead Pipes and Environmental Justice (American University and EDF, March 2020)
- Conference Proceedings: Achieving Equity in Lead Poisoning Prevention Policy Making (Human Impact Partners, 2018)
- Presentation: Lead in drinking water: Equity considerations in LSL Replacement (EDF at American Public Health Association Conference, 2019)
- Blog: EDF considers potential health equity impacts of partial lead service line replacement (EDF 2019)
- Proposed Plan: Denver Water’s Proposed Lead Reduction Program Plan - pages 76-79, Health Equity and Environmental Justice (Denver Water, 2019)
- Report: A Water Utility Manager’s Guide to Community Stewardship - pages 55-56, Lead Service Line Replacement case study (AWWA, 2019)
General resources on equity:
- Report: Advancing Racial Equity in Your City (National League of Cities, 2017)
- Website: Repository of City Racial Equity Policies and Decisions (National League of Cities)
- Toolkit: Collaborating for Equity and Justice Toolkit (KU Center for Community Health and Development)