Step 5: How can adverse impacts be addressed?

​Once it is known where the LSLs are and the characteristics of those neighborhoods, the datasets can be combined to help address any potential disparate impacts identified in Step 2.

By highlighting areas of a community based on known presence of LSLs, risk levels, and demographic and economic data, it is possible to see where indictors of negative health outcomes and/or greater health risk levels are concentrated. This information can aid in identifying areas to consider in prioritization of LSLs for replacement.

Considerations important to promoting equity throughout the implementation of an LSL replacement program include:

• Is the program adequately funded, staffed, and supported by relevant policies?
• Who is involved in the design of the program?
• Does the program include adequate data collection and engagement to assess progress?
• What are success indicators and progress benchmarks?
• Who can the impacted individuals and communities bring their concerns to?
• How will those impacted be informed of progress and impacts over time?
• Are there trusted community members that can serve as a liaison to facilitate program roll out and resolve issues as they arise during program implementation?

More information on considerations for program funding, integrating capital improvement plans and community investments, local policies to enable implementation and construction related impacts are listed below.

Program Funding
Given the health risks of lead exposure, LSL replacement is a critical infrastructure investment for communities where they are present. Understanding who lives in those communities and who may be disproportionately impacted by the presence and replacement of LSLs, through the process described in Step 4, provides an opportunity​​

Guide to Equity Analysis

​Step 1:
What activities does an LSL replacement program include?

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

​Step 3:
Where are impacts anticipated?

Step 4:
Who might be impacted?

Step 5:
​How can adverse impacts be addressed?

 to determine how those costs can be equitably covered. ​Communities can use available mechanisms to cover the costs of LSL replacement, including the portion of the service line on private property, in a variety of ways, including taxes (e.g., routine capital improvement planning), fees, special charges, and water rates. Some communities may also be eligible for federal or state funding subsidies.

Programs that do not require individual customers to pay directly for a portion or the full cost of replacement will likely allow more people to participate and result in fewer partial replacements at low-income households.

Learn more about approaches to funding LSL replacement.

Policies to Enable Implementation
Successful and equitable implementation of an LSL replacement program may involve reviewing and changing state and/or local policies and procedures to more rapidly reach the goal of replacing all LSLs. Not all communities see potential policy changes from the same viewpoint, recognize unintended consequences, or benefit in the same ways.

Example policies include:

1. Pursuing funding from state, federal, and philanthropic assistance programs.
2. Removing barriers to water utilities using rates for LSL replacement on the portion under private property.
3. Exploring new approaches to the community’s water rate structure to accommodate financial need and to adequately support LSL replacement.
4. LSL identification, notification, and/ or replacement into local requirements for rental properties.
5. Integrating LSL identification, characterization, and notification into local building permit and real estate transactions.
6. Notifying customers that the service line serving their home is or may be lead.
7. Providing local water system staff right of access to private property.
8. Including lead service line identification and or replacement in siting criteria for childcare and school facilities.
9. Integrating lead service line identification in lead risk reduction home visits.
10. Making lead service line replacement a condition of return-to-service when structures are renovated or returned to occupancy.

​​Construction-Related Impacts
Like any construction in an urban environment, field practices can be organized to manage the impact on residents, individuals traveling through, and neighborhood businesses and institutions affected. Coordinating other construction activities with LSL replacement can help reduce overall disruption to the community.

Wherever LSL replacement occurs, it is important to ensure that construction crews observe important health and safety precautions, such as following the AWWA C810-17 LSL replacement and flushing standard and safe paving requirements to maintain pedestrian and traffic safety within neighborhoods with ongoing work. Health and safety precautions can be written into contracts, incorporated into licensing requirements, and otherwise codified to ensure they are consistently applied throughout a community.  
 
Hiring and contracting processes are themselves opportunities to enhance the equity of LSL replacement programs, such as by ensuring local and minority-owned businesses can compete for bids. Learn more about how communities are building robust workforces for LSL replacement in an equitable manner.
 
Learn more about replacement practices.

​Integrating Capital Improvement Plans and Community Investments
As LSLs are a known public health risk, LSL replacements should be prioritized as being a health-protecting expenditure when communities prioritize projects in their capital improvement planning. Capital planning is the time for a community to consider how a capital plan may delay or accelerate LSL replacement (e.g., does construction of a new water main to foster economic development impact the resources available for LSL replacement or rate of replacement?)

​Capital planning is an opportunity for communities to establish a proactive LSL replacement program. It also allows communities to leverage other infrastructure improvements to advance the LSL replacement program’s replacement schedule by utilizing already planned infrastructure improvements to increase construction efficiency and to minimize disruption of LSLs. For example, if a portion of a water main is scheduled to be replaced, a program can take advantage of the localized shutdown, utility markings, and excavation activities associated with this planned construction to replace the entire LSL thus avoiding partial LSL replacements. Other activities that may expedite LSL replacement and reduce the cost of individual LSL replacements include planned redevelopments, road construction, and other utility work.
​
Similarly, it is important to identify what may cause impediments to replacement plans in a community. Permitting requirements in historic neighborhoods, high traffic commuting roads, and other factors may lengthen the plan review and approval period. This can result in less efficient use of resources and funds allocated for LSL replacement programs.​

​Continue to: 
Coordination and Partnership  →