Step 2: What aspects of an LSL replacement program ​might have disparate impact and why?


​Water systems often design programs that offer customers flexibility based on their ability to pay for services. While income is important to consider as part of an equity analysis, it is not the only factor. Assessing a broader range of factors will strengthen the equity of LSL replacement initiatives. Careful consideration of how and why the activities in an LSL replacement program could impact populations differently based on race, ethnicity, primary language spoken, income, historic community development patterns, and other factors can help communities develop a plan that does not exacerbate existing inequities or cause new ones.

Collaborating with community groups, health agencies, and other partners is a great way to understand which aspects of an LSL replacement program might have disparate impacts and how they can be addressed. These aspects will vary between communities, but likely include:
  • Sequencing LSL replacements
  • Funding and financing LSL replacements
  • Communication strategies
  • Community disruption and construction sequencing

​Sequencing LSL Replacements
Patterns in LSL occurrence, economic and social disparities, and ongoing community-based environmental justice programs are unique to every community. LSL replacement planning is an opportunity to consider how the order and timing in which LSLs are replaced will impact customers and to use that knowledge to inform sequencing of LSL replacement. Considering these factors in LSL replacement sequencing can also help address environmental justice concerns in some communities and promote equitable outcomes from LSL replacements. For example, some customers may have multiple pathways for lead exposure, such as lead-based paint in their homes as well as the presence of an LSL, and may warrant prioritization in a replacement program.​​​
Financing LSL Replacements
LSL replacement is a critical infrastructure investment for communities where LSLs are present. The EPA estimates the cost of a full LSL replacement at $3,163 - $6,024. How the costs of LSL replacements are covered can have equity implications for communities as a whole as well as for individual households.

For example, data show that LSL replacement programs in which the property owner is expected to independently initiate and/or pay for some portion of the replacement can lead to fewer replacements overall and relatively more partial replacements in low-income communities, creating an environmental justice issue. Partial replacements do not remove the lead risk and can increase lead levels of the drinking water delivered to a home after replacement. Partial replacements also likely increase the overall cost of fully removing an LSL because someone will have to come back in the future to complete the replacement. 

However, these barriers can be overcome by addressing funding solutions at the community level.  To do so, it is important to consider the economic profile of a community, as well as the policy landscape, when determining an equitable approach to funding. 

Learn more about approaches to funding LSL replacement.
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Communication Strategies
Transparent, inclusive, and respectful communication of LSL replacement programs is crucial in creating an equitable program. The CDC’s Guiding Principles for Inclusive Communication is a valuable resource for understanding how to develop inclusive communications. Additionally, partnering with community organizations and local businesses to develop and share information may aid in reaching specific audiences.

Effective LSL replacement implementation entails effective two-way communication with the community residents. Communication needs include:
  1. Effective outreach about relevant health risks
  2. How the LSL replacement program functions
  3. Clear and readily available documentation of what residents can expect during the course of an LSL replacement (e.g., what the water utility, contractor(s), homeowner, and resident(s) will be responsible for in the replacement process), and
  4. How to access related services like pitcher filters, water sampling, and financial assistance if the community’s program does not fund the full cost of LSL replacement costs.
Communication strategies entail not only developing relevant information alongside community partners, but recognizing the most effective venues and partner organizations to facilitate information exchange. Some questions to consider are:
  • Has adequate information been presented to impacted groups to understand the full scope of the program and how it may impact public health, finances (if applicable), or other local concerns?
  • Is transparent information about the program available and easily accessible to all potentially impacted racial, ethnic, and socioeconomic groups (including in multiple languages)?
  • Is someone available to answer questions from potentially impacted groups? Do impacted groups/residents need to overcome unnecessary barriers to get answers to their questions, and if so, how can those barriers be removed?
  • Is there is a clear way for residents to raise and resolve concerns if they believe they are not receiving the services they should under the program?
  • What are the most effective communications mechanisms to reach the impacted communities?
  • How have the impacted communities responded to communications about the program? If they have not responded, why?
  • Is the communication organized so different racial, ethnic, and socioeconomic groups may be involved in program development and execution?
  • Is the impacted community integrated as true project partners in project design and implementation?

Learn more about communicating equitably about LSLs and LSL replacements.
Construction-Related Impacts
LSL replacement takes place on individual lots, streets, parking areas, and sidewalks. The process includes excavation that can require utility stoppages and have other effects on residents, such as road closures and changes to public transportation routes and schedules. It is important to fully replace all LSLs and minimize the total number of construction projects needed to accomplish this. Efforts should be made to shorten the duration of LSLR projects in a neighborhood as much as possible to help reduce the disruption experienced by communities, especially those with high concentrations of LSLs.

It is also important to ensure that proper safety precautions, such as following the AWWA Lead Service Line Replacement Standard C810-17, are taken during replacement. Unsafe procedures and incomplete remediation inside the house can result in increased lead exposure – for both the resident and potentially the workers. Excavations should be covered overnight and roads and sidewalks repaved as soon as possible to reduce traffic and pedestrian hazards in impacted neighborhoods. Projects should be designed to touch an individual neighborhood as few times as possible; construction should not keep returning each time an individual is able to pay for their own LSL replacement. ​
​Continue to Step 3:
Where are impacts anticipated?  →