​Equity in Lead Service Line Replacement

A guiding principle of the LSLR Collaborative is that lead service line (LSL) replacement initiatives should consider and address barriers to participation so consumers served by LSLs can benefit equitably, regardless of income, race, or ethnicity.

Among other benefits, developing LSL replacement programs that intentionally center equity can help communities and water systems:

1. Provide equitable access to safe drinking water to all consumers to protect public health
2. Help address environmental racism and promote environmental justice in communities
3. Meet Lead and Copper Rule Revision (LCRR) requirements for prioritization of “disadvantaged consumers and populations most sensitive to the effects of lead”
4. Secure funding for LSL replacement programs

​For homes with LSLs, the service line typically contributes the greatest percentage of lead to the tap. Lead exposure can harm children’s brain development, contributing to lower IQs as well as learning and behavioral problems. Public health principles begin with prevention.

​Removal of LSLs provides an opportunity to significantly reduce the risk of exposure to lead in drinking water. While measures to control corrosion through water treatment reduce lead in drinking water in many communities, LSLs can unpredictably release potentially significant levels. ​

​An equitable LSL replacement 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. In many U.S. cities and communities, people of color are disproportionately exposed to environmental hazards, including lead, because of histories of segregation, redlining, and inequitable resource distribution.

​To achieve equitable outcomes, a community’s LSL replacement program must:

• Recognize that residents of color and residents with lower incomes are historically more likely to be exposed to other sources of lead, especially lead-based paint hazards, and that reducing further harm is a priority.
• Take steps to protect residents with lower incomes or limited access to capital so they can participate in LSL replacement.
• Make replacing LSLs serving rental properties a priority given that landlords may not be motivated to do so, and tenants are often, depending on the region, more likely to be people of color and/or of lower income.​
• Always plan for full LSL replacement and prevent partial LSL replacements.
• Be led by a truly inclusive collaboration that is intentionally framed around principles of equity. ​

​In striving for equity in LSL replacement, it is important to understand the difference between equity and equality. 

Equality means that each group or individual is provided access to the same resources or opportunities. 

​Equity means adjusting the type of access and/or the type of resources provided to a group or individual based on their different circumstances or needs.

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It is important to note that equity analyses need not be complicated processes that delay the start of LSL replacement — for many communities, a high-level equity analysis may be sufficient. For others, additional data may be useful to identify communities that historically have not benefited from public health and infrastructure investments. By providing a multitude of resources, the LSLR Collaborative hopes to aid communities of all sizes in developing LSL replacement programs to remove LSLs as quickly, safely, and equitably as possible.​​

The LSLR Collaborative developed a step-by-step guide communities can use to help consider and account for issues of equity when developing LSL replacement programs.

Check Out the Step-by-Step Guide to Equity Analysis

​Additional Resources on Equity

LSLR Collaborative Resources:

• Equity and decision-making
• Equity and funding
• Equity and plan development
• Equity and communicating about LSLs
• The LSLR Collaborative's webinar on equity
• The LSLR Collaborative’s ​resources in Spanish
  
  

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:​​

• 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)​​

​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. 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.