Introduction and summary
Nearly 10 years ago, news broke about a health crisis brewing in Flint, Michigan, that was the result of state and local lawmakers’ deeply negligent and short-sighted decision-making.1 To save a bit of money, the city of Flint switched its water source from the Detroit River to the highly mineralized, more corrosive water of the Flint River. The results were catastrophic. Improperly treated water, running through aging water service lines into homes across the city, leached lead from the pipes, further contaminating the supply and leading to dire health consequences for thousands of residents, an estimated 8,000 to 9,000 of whom were children.2
Flint residents were unfortunately not alone in experiencing contaminated water from lead pipes. Though complete data about the prevalence of lead service lines (LSLs) is difficult to obtain, especially due to incomplete historical records on where LSLs remain, estimates suggest that every single state in the country has at least 2,800 active lead lines3—roughly 9.2 million across the country4—affecting nearly 22 million people in total, disproportionately people of color and those from low-income households.5 A report from the U.S. Environmental Protection Agency (EPA) estimated that in 2021, the bulk of the nation’s lead-contaminated infrastructure was concentrated in a few states across the Rust Belt and Great Lakes regions6—such as Illinois, New York, Ohio, and Pennsylvania—as well as some states in the South, such as Florida and Texas.7
Every single state in the country has at least 2,800 active lead lines, affecting nearly 22 million people in total, disproportionately people of color and those from low-income households.
The Biden administration, in negotiating consensus on the Infrastructure Investment and Jobs Act (IIJA)8—also known as the bipartisan infrastructure law (BIL)—made the largest investment in clean drinking water in the nation’s history and established a key goal of retrofitting and updating drinking water infrastructure across the United States.9 The IIJA’s $50 billion safe drinking water package10 includes $15 billion in grants and loans to identify and replace LSLs11 and an additional $11.7 billion to finance any drinking water infrastructure priority, including LSL identification and replacement.12 The package also creates a Lead Service Replacement Accelerators program,13 a partnership between the EPA and the U.S. Department of Labor to provide water technical assistance across select states.14 Importantly, these federal investments fall under the Biden administration’s Justice40 Initiative, which aims to deliver at least 40 percent of benefits from climate and infrastructure initiatives to disadvantaged communities, including low-income communities and communities of color, to mitigate the historic health and environmental inequities that still plague millions of marginalized people.15
Billions invested in LSL replacement projects
The total funding through the IIJA dedicated to safe drinking water projects
Billions in federal funding through grants and loans to support lead service line replacement projects
Billions in federal funding for water infrastructure, including lead service line replacement projects
Meanwhile, the Biden administration’s Get the Lead Out Partnership16—a coalition of federal, state, Tribal, and local governments; nongovernmental organizations and private companies; water utilities; and labor unions that are committed to a framework of health-based, justice-centered principles of LSL replacement17—will establish a nationwide technical support program with the goal of replacing all the country’s LSLs in 10 years. And in late November 2023, the Biden administration proposed Lead and Copper Rule improvements that would require water systems to remove and replace all lead pipes across the country within 10 years, adding critical regulatory authority to its financial investments to drive progress.18
The Biden administration, in brokering consensus on the Infrastructure Investment and Jobs Act, made the largest investment in clean drinking water in the nation’s history.
Policymakers at the local, state, and federal levels must ensure that the Biden administration’s unprecedented investments to remove LSLs are maximized to successfully improve access to safe drinking water and protect health across the country. This report examines the implementation of IIJA investments to date in Pennsylvania and Wisconsin, which are among the top 10 states with the most LSLs.19 The report highlights project and financing innovations that have successfully improved the health of children, families, and communities, and offers lessons and recommendations for other states seeking to remove lead from drinking water systems.
The Center for American Progress recommends that states leverage IIJA resources in the following ways to improve access to clean drinking water:
- Use the best available data to document the LSL landscape and track replacement progress and impact.
- Prioritize equity and environmental justice in LSL replacement strategies by targeting funds to communities disproportionately exposed to lead in their drinking water.
- Replace entire LSLs—not just the portion owned by the local drinking water authority—to minimize harm and eliminate lead exposure.
- Seek community input, invest in meaningful community engagement, and build community trust in state leaders and utility service providers to gain support and overcome potential obstacles for LSL replacement.
- Offer effective shorter-term solutions to protect communities from ongoing lead exposures as they wait for LSL replacements and offer support for accessing treatment.
The health consequences of lead toxicity are significant and inequitably distributed
There is no safe level of lead exposure at any age, but lead exposure is especially dangerous for young children, who are at a vulnerable stage of brain and biological development. Even in small doses, lead toxicity can lead to long-term negative consequences for the brain and nervous system, delayed growth and development, learning disabilities and behavioral challenges, and hearing and speech impairments.20
An April 2023 EPA report estimated that LSLs serve 9.2 million homes across the United States.21 Yet many families may be unaware that they are experiencing lead exposure through water supply because it is invisible, odorless, and tasteless, and early symptoms of lead poisoning can be difficult to detect.22 In fact, it is only through laboratory testing of pipes and fixtures or blood lead levels (BLLs) that researchers and health officials can determine whether a child may be exposed to dangerously high lead levels in their water supply. While contaminated drinking water is one significant source of lead exposure, children may also be exposed to multiple sources at once, including from lead dust from industrial sources or paint, contaminated food, and pollution in the environment. In extreme cases, children may end up hospitalized with lead poisoning, which can be difficult to detect in the short term, with signs and symptoms often not occurring until dangerous levels of lead have already accumulated in the body.23
Lead exposure not only has damaging consequences for young children’s health but can also lead to significant social and economic upheaval for their families,24 with potential longer-term impacts on family financial security or the added cost associated with caring for a child with special needs as a result of their exposure to lead.25 While children experience long-lasting health effects due to lead water exposure, adults can also suffer from cardiovascular disease, which can have adverse impacts on women’s reproductive health and others’ kidneys.26
There is no safe level of lead exposure at any age, but lead exposure is especially dangerous for young children.
Lead exposure disproportionately affects low-income communities and communities of color as a result of historic residential segregation, underinvestment in infrastructure and quality affordable housing in communities of color, economic inequality, and other effects of structural and environmental racism.27 While the federal government’s Healthy People 2020 objectives for reducing BLLs in children have been met for the overall population,28 significant disparities remain by race, ethnicity, and income. Indeed, children who live in low-income households, are immigrants or refugees, and are non-Hispanic Black are still significantly more likely to live in areas with high risk of lead exposure.29
This legacy of structural and environmental racism leads to early health disparities that snowball later into significant inequities in health, income, and life outcomes.30 For instance, non-Hispanic Black children consistently have significantly higher blood lead levels than non-Hispanic white children.31 And for Black children living in conditions of poverty, rates of exposure are even higher.32 These communities are also more likely to distrust health departments and other health services and providers given the long history of racial bias and medical abuses inflicted upon Black and Latino Americans, which may reduce their access to early identification and treatment.33
Federal investments to replace LSLs support health and economic growth
The IIJA, in conjunction with other key pillars of the Biden administration’s investment agenda, including the Inflation Reduction Act of 2022 and the CHIPS and Science Act of 2022, provides unprecedented investments and opportunities for state and local governments to rebuild and modernize core infrastructure and, in so doing, strengthen public health, environmental, and economic outcomes.34 Along with an emphasis on clean energy and the creation of good jobs, the IIJA prioritizes safe drinking water and lead pipe removal to improve public health and safety in communities across the country.
The Biden administration further strengthens rules around lead exposure
In November 2023, the Biden administration released proposed improvements to strengthen the Lead and Copper Rule to promote the replacement of LSLs.35 Building on its historic investments through the IIJA, the administration announced that it was accelerating the timeline for water systems to conduct their replacements to within 10 years. Furthermore, the administration announced that it was raising standards around water testing and LSL inventorying and that it was expanding recommended actions for water systems to protect vulnerable communities from lead and communicate lead exposure risks to the public.
Investments in safe drinking water are transformative for communities across the country with long-term benefits to children and their families. A report by Environmental Entrepreneurs and the United Association of Union Plumbers and Pipefitters estimated that a $45 billion investment to replace all LSLs in America would create 56,080 jobs annually for 10 years, building economic security for communities while also improving health.36 The report estimated that the investment would generate $53.9 billion in economic value, which, in addition to other smaller returns, would represent a 120 percent return on investment. According to a 2022 study by researchers at the Harvard T.H. Chan School of Public Health, removing all lead pipes in the United States would result in at least $9 billion in annual health benefits, with total health savings of $786 billion over the next 35 years.37 The Environmental Defense Fund estimates that every lead pipe replaced results in $22,000 in societal benefits from preventing cardiovascular disease deaths alone.38
Replacing LSLs: By the numbers
Annual job creation over 10 years with a $45 billion investment in LSL replacements
Estimated return on investment on a $45 billion investment in LSL replacements
Annual health benefits of replacing all LSLs, with total health savings of $768 billion over 35 years
Annual societal benefits from reductions in cardiovascular disease deaths for every LSL replaced
Additional examples of federal IIJA funds having community impact
- Philadelphia received IIJA funds to support improvements to the city’s water infrastructure. $500 million in federal grants and low-cost, flexible loans will allow the city to make major improvements to its water infrastructure, including replacing 160 lead service lines and 13 miles of main water lines.39
- Minnesota Gov. Tim Walz (D) signed a bill in May 2023 allocating $240 million to support lead pipe removal projects, citing the additional federal dollars through the IIJA as crucial to expanding remediation efforts and identifying where the contaminated pipes are located across the state.40
- City water leaders in Detroit cited the infusion of federal dollars as key to accelerating the timeline for Detroit’s LSL replacements—that is, the Water and Sewerage Department plan to replace 5,000 LSLs in 2023 and more than 10,000 beginning in 2024. This funding also helped protect residents from any increase in utility costs associated with the replacements.41
- The IIJA is providing Delaware’s Department of Health and Social Services with more than $28.6 million to bolster the state’s LSL replacement program and to support associated activities such as identification of the location of contaminated lines and providing technical assistance to small water systems undertaking LSL inventory or construction.42
Case study 1: Pennsylvania is safeguarding public health, advancing environmental justice, and creating good-paying jobs
Statewide efforts to replace LSLs
As of February 2023, the EPA had allocated $240.2 million in IIJA funds to the state of Pennsylvania for safe drinking water projects, including $87.3 million for LSL replacements.43 In mid-October 2023, Gov. Josh Shapiro (D) announced that the Pennsylvania Infrastructure Investment Authority (PENNVEST)44 would invest $175.7 million in 25 drinking water and wastewater projects across 16 counties funded by a variety of sources, including IIJA grants.45 Included in PENNVEST’s overall budget is approximately $150 million that must be spent on LSL replacement projects, though more lead projects can be supported if that funding runs out. Pennsylvania also participates in the Lead Service Line Replacement Accelerators program.46
As just one example of the impact of this funding, approximately $160 million of the $240.2 million in IIJA funds will support the replacement of 19 miles of lead pipes and upgrades to water facilities in Philadelphia.47 These projects to improve access to safe drinking water, including replacing LSLs, are intended to safeguard public health, advance environmental justice, and create good-paying jobs.48 Notably, the Perelman School of Medicine at the University of Pennsylvania estimated that in 2018, there were hundreds of thousands of residential lead pipes across the state, concentrated largely in neighborhoods housing older people, people of color, and low-income residents.49
Approximately $160 million of the $240.2 million in IIJA funds will support the replacement of 19 miles of lead pipes and upgrades to water facilities in Philadelphia.
PENNVEST is determined to approve projects as quickly as possible, including by conducting community outreach and providing technical assistance through field staff who work with local officials and attend town hall meetings to support community applications. PENNVEST provides funding support for every “construction ready-to-go” project, with funding packages ranging from low-interest loans to grants, contingent on an affordability assessment of each community. Field staff support community development of clean water projects prior to receiving funding, sometimes over the course of two to three years. Despite reporting no specific targeted approach to addressing equity concerns through clean water projects, PENNVEST analysis shows that in the 2022–2023 fiscal year, 67 percent of statewide grant dollars and 85 percent of loan dollars went to projects in disadvantaged communities, as determined by the Justice40 Initiative.50
Spotlight: Pittsburgh is protecting residents from the financial burden of LSL replacements
Among projects funded across the state of Pennsylvania, PENNVEST provided a grant of almost $2.5 million and a loan of $686,353 to the Pittsburgh Water and Sewer Authority (PWSA) for its LSL replacement projects.51 While PWSA began its LSL replacement program in 2016, funding from the IIJA has been essential to accelerating this work and allowing the city to realistically meet its goal of replacing all LSLs by 2026 without increasing water and sewer costs to its residents.52 As of November 2023, PWSA has inspected more than 21,000 locations and replaced more than 10,500 service lines that contained lead, including 19 replacements that were serving child care facilities.53 A $17 million investment from the city and additional support from the state also boosted this work.54
PWSA has had to put considerable effort into identifying where lead pipes exist across the city. Through a combination of historical property records, construction records, and ongoing curb box inspections, it built a comprehensive map to track where LSLs exist and track planned and completed replacement projects.55 PWSA prioritizes LSL replacement projects according to risk and equity, using public health and demographic data to consider neighborhood factors such as median income, people of child-bearing age, BLL data, and environmental justice mapping.
As part of its earlier LSL replacement efforts, PWSA encountered legal and regulatory hurdles related to private ownership of a portion of the service line running from the curb box to the water meter. This regulatory hurdle existed until 2017, when the state passed a clarifying law allowing local governments, as a matter of public health, to tap into public funding sources for citizens to be able to cover the cost of sewer and waterline repairs on private portions of service lines.56 This law paved the way for PWSA to conduct complete LSL replacements, removing residents’ cost burdens and protecting community health. Despite having the legal authority to work on private property, PWSA still needed to gain the trust of residents to complete work on the private side and educate them on the risks of lead exposure—a process that takes time and care. A group of field liaisons have been essential to this process, as has grant funding, which allows PWSA to fully cover the cost of public- and private-side LSL replacements.57
As of October 2023, PWSA’s lead service line replacement initiative has created more than 600 direct jobs, in addition to almost an equal number of indirect jobs.58 Of the more than $144 million that has been spent since work began in 2018, PENNVEST has provided $16.1 million in IIJA funding.59 In addition to replacing the publicly owned LSLs, PWSA allows residents who complete an income verification and hire a private plumber can take advantage of the Lead Line Reimbursement Program to cover up to 100 percent of the costs on the privately owned portion of the water line.60
Case study 2: Wisconsin is accelerating the pace of LSL replacement, engaging community leaders, and reaching more vulnerable families
Statewide efforts to replace LSLs
As of 2023, the EPA has allocated $129.5 million in IIJA funds to the state of Wisconsin for LSL replacements.61 In prior years, the state largely relied on funds from the federal Water Infrastructure Funding Transfer Act (WIFTA) to support its LSL replacement efforts.62 However, those funds quickly waned: As of November 2023, less than $2 million remained. Accordingly, IIJA funds are proving to be a critical lifeline for Wisconsin’s ability to fully address LSL replacements.63 In total, the EPA is set to provide approximately $373 million to Wisconsin between fiscal year 2022 and 2026. The Wisconsin Department of Natural Resources (DNR), which oversees the state’s LSL replacement projects, has already preapproved 42 municipalities to receive IIJA funding to support their LSL replacement programs.
The Water Infrastructure Funding Transfer Act
WIFTA, which passed in 2019, allowed states to transfer funds from the Clean Water State Revolving Fund (CWSRF) to the Drinking Water State Revolving Fund (DWSRF) to address eligible LSL projects. States had from WIFTA passage in 2019 through October 4, 2020, to make their WIFTA transfers and could make multiple transfers so long as they did not exceed a 5 percent cap included in the WIFTA law and they submitted an intended use plan (IUP) for public review.64 These IUPs identified which projects would be covered using the transfer, including estimated costs, a rationale for the use of the transfer authority, an evaluation of the financial impact of conducting a WIFTA transfer from the CWSRF, and an explanation for why additional funds were necessary to address a threat to public health.
Nine states took advantage of this opportunity: Illinois, Massachusetts, Michigan, New Jersey, Ohio, Pennsylvania, Rhode Island, Vermont, and Wisconsin. Wisconsin transferred more than $63 million to its DWSRF.65
The Wisconsin DNR works with individual localities to support developing bids for individual contracts from a pre-qualified list of municipalities. Homeowners then submit a contract for the project and may get all or part of the cost reimbursed to them through the program. How much a homeowner is reimbursed is expected to vary by municipality; some programs elect to pay the contract on behalf of the homeowner, while others require that the homeowner absorb the upfront costs.
Short-term investments that covered one- or two-year-long projects, through previous funding sources, were insufficient in their ability to permanently invest in their workforces.66 Resulting shortages in qualified contractors to conduct assessments and lead projects, as well as plumbers to connect the service lines inside the home, have stymied overall progress—a problem that has become more pronounced as more municipalities across the state embark on their own replacement projects. Even now, with expanded funding available to support these projects, the state must still overcome a sparsity of qualified workers to conduct replacements at scale.67
Another barrier has been identifying where lead pipes, or portions of them, still exist. These gaps in knowledge are more pronounced in some parts of the state than others. Madison, for example, replaced all LSLs in the early 2000s,68 but there are still many communities, particularly in rural portions of Wisconsin, fed by LSLs. Utilities are tracking where replacements are still needed on the public side, but there are many privately owned portions of LSLs to which contractors do not have access, hindering their ability to complete the replacement.
Wisconsin’s DNR is conducting multiple levels of outreach to engage both individual homeowners and municipalities to express the importance of their participation in the replacement program. DNR conducts this outreach through multiple mechanisms—for example, through neighborhood groups; through leveraging trusted community members who live in the area; and through printed resources such as flyers, infographics, and information on the DNR website.69
Spotlight: Milwaukee is prioritizing neighborhoods with greatest need for LSL replacement
Milwaukee, Wisconsin’s largest city, is among the state’s localities actively working on LSL replacements. The city contains nearly half of Wisconsin’s remaining in-use lead pipes, according to a recent report from the Wisconsin Policy Forum.70 In 2017, the city of Milwaukee began its program to systematically replace all LSLs, yet Milwaukee Water Works (MWW) officials have estimated that approximately 68,000 lines remain across the city, often in disadvantaged communities.71 Fortunately, IIJA funding is expected to accelerate the pace at which LSL projects can now take place in Milwaukee. Milwaukee Mayor Cavalier Johnson reported the infusion of new IIJA dollars supporting this effort has enabled him to reduce the city’s timeline to replace all LSLs from 70 to 20 years.72 MWW stated that the city planned to submit a formal request for $30 million from the state’s more than $370 million IIJA allocation.
MWW currently completes full LSL replacements, but until December 2023, the city required property owners to cover a portion of the cost for private-side replacements, serving as a barrier for some families.73 For required LSL replacements—which the city initiated in cases of emergencies, planned city projects, or due to an LSL serving a child care facility—property owners previously paid approximately $1,600, with the option to pay it all at once or over 10 years as a special assessment on their property tax bill.74 For voluntary, owner-initiated LSL replacements, the city required property owners to request a quote from a contractor, schedule the replacement, and pay 100 percent of the private-side cost up front.75
IIJA funding is expected to accelerate the pace at which LSL projects can now take place in Milwaukee, reducing the city’s timeline to replace all LSLs from 70 to 20 years.
Knowing that the owner cost has been a barrier to LSL replacements since the city began its replacement project in 2017, MWW led an effort with alders at city hall to change an ordinance so that it would cover the property owner cost for required replacements and reduce property owner requirements for initiating voluntary replacements.76 The change in ordinance passed on December 12, 2023.77 Starting in January 2024, MWW will use IIJA dollars to fully cover the public- and private-side replacement costs for properties with one to four dwelling units and for other situations in which a replacement is required and planned.78 The city will also cover the full cost of replacement for child care facilities.79
MWW has developed a scoring system to prioritize planned LSL replacement projects based on neighborhoods with the greatest need. The state’s equity prioritization plan, which it will roll out in 2024, considers instances of elevated BLLs in children, the concentration of LSLs in a given area, and the Area Deprivation Index,80 a mapping tool that identifies relative socioeconomic conditions of various neighborhoods.81 In accordance with the new ordinance, the city will fully cover public- and private-side LSL replacement costs for the 2,200 planned projects for 2024.82 The affected communities often have aging or more deteriorated housing infrastructure that leaves their residents vulnerable to exposure to lead poisoning. However, by and large, these are also communities with the greatest distrust in the state and in health professionals, as a result of a history of racial bias and abuse of people of color within the medical system.83 For instance, some parents in disadvantaged neighborhoods have reported being caught in the position of fighting to retain care of their children if they can only afford housing that is subsequently deemed unsafe for their children to live in.84
Lead exposure’s lasting consequences for Milwaukee children
Young children are especially vulnerable to absorbing lead through a variety of inputs, including water, soil, paint, and other substances, and as with most cases of lead poisoning, the effects of exposure may not become evident until damage has already been done.85
One Milwaukee mother involved in the parent advocacy arm of the Coalition on Lead Emergency (COLE)86 said that she only became aware of her son’s lead poisoning because his kindergarten teachers requested his medical records, noting that he was struggling to meet benchmarks for his 5-year-old age group.87 Now, at 17, her son still suffers from the impacts of his exposure to the toxin, including cognitive delays, behavioral issues, and vision and hearing problems. Another parent involved in the organization has a 10-year-old son whose highest recorded BLL was 45µg/dL—about nine times higher than the level that is considered elevated and that may require medical attention for adults.88 The child of another parent involved in the group was hospitalized with a BLL of 70µg/dL and remains nonverbal.89 These devastating and long-lasting impacts of lead poisoning underscore how essential and lifesaving LSL replacement is.
Studies of pregnant women find that toxins from lead exposure can be passed to the developing child through the mother, increasing the risk for miscarriage, small birth size, prematurity, or damage to the infant’s organs, including their kidneys and brain.90 COLE plays a crucial role in reaching Milwaukee families as early as possible to prevent exposure to lead: The organization conducts lead tests on birthing mothers and helps supply new mothers with a lead testing kit and a water pitcher with filters, in addition to other cleaning aids, upon their discharge from the hospital.91 COLE also supports families who have already been exposed to lead and is working to lower the BLL threshold for receiving medical treatment.
Remaining challenges to LSL removal
While both Wisconsin and Pennsylvania are making great strides in using the influx of IIJA dollars to push for LSL replacements, both states face challenges to success. These include navigating ownership barriers associated with the private side of water service lines, gaining community trust to carry out replacement projects, and finding workers to complete LSL replacements amid ongoing labor shortages.
Full LSL replacements on both the public and private side are essential to protecting communities from lead exposure. However, legal and financial barriers associated with water service line ownership have slowed this process. In Pennsylvania, a previous rule required that entities completing private-side LSL replacements (for example, a public utility or contractor) be responsible for future maintenance and upkeep costs for 20 years after replacement.92 By overturning that rule and ensuring that entities are not responsible for maintaining private-side water lines in the future, the state was able to encourage many more municipalities to apply for project funding and embark on LSL replacement projects.93 Communities have also varied in their approaches to distributing the cost of public- versus private-side LSL replacements. Removing as many barriers as possible for community members, including by covering the full cost of LSL replacements, is important for advancing this work and protecting as many communities as quickly as possible.
Overcoming the challenge of shared ownership of LSLs
One challenge in removing LSLs has been the shared ownership between private property owners and portions of the service lines operated by public entities. Typically, the water authority and the property owner jointly own a water service line, and they split the cost of any needed LSL replacement—which must involve the entire service line to be effective—proportional to ownership. This can create a significant financial cost to the property owner; but replacing only a portion of the line may only provide a false sense of safety and is ineffective at reducing overall lead levels94 and, in some cases, may only exacerbate the problem.95
Some communities such as Newark, New Jersey, have attempted to overcome the financial cost issue by using bonds that provide public funds to cover LSL replacement on private property, along with a city ordinance permitting replacement of lines on private property without requiring homeowners’ permission.96 Using this strategy, Newark has successfully replaced its LSLs and achieved a reduction in overall exposure to lead. The city presents a model that other communities across the country can repeat to alleviate the cost burden on private citizens.
Even when the full cost of LSL replacement is covered, cities and states face challenges in gaining the trust and permission of owners to carry out replacement projects on private property. LSL replacement can be an invasive process, requiring teams to tear up sections of a sidewalk and street. Furthermore, many properties that need LSL replacements are occupied by renters, and municipalities may encounter unresponsive property owners and landlords. Working with residents to gain trust and educate them on the risks of lead exposure is a hand-to-hand process that takes time and follow-through but is critical for gaining the community trust necessary to carry out LSL replacements.
Finally, both Pennsylvania and Wisconsin are experiencing workforce shortages, which is presenting another barrier to LSL replacement. Municipal officials in Milwaukee said these workforce shortages have impeded timely LSL replacements, especially as a greater number of municipalities surrounding Milwaukee have begun LSL replacement work.97 The shorter-term nature of pre-IIJA investments was ineffective at building up the workforce (particularly through sustained higher compensation), but longer-term investments through the IIJA may prove helpful in attracting and retaining qualified workers. Additionally, the law includes funding for apprenticeship programming that can provide job training and economic investments in communities. As one individual from Wisconsin’s DNR noted, paid training for community members to become construction workers and lead risk assessors to support LSL projects brings jobs and revenue into these communities.98 IIJA apprenticeship programs hold promise to support better health and economic outcomes in disadvantaged communities, in particular. According to one COLE member, investments for apprenticeship programs have brought work and community revitalization and built community trust.99
Building on successful models and partnerships for community involvement, the White House released “Guiding Principles to Reduce Lead and Protect Families and Communities.”100 Along with fostering community engagement, developing a unionized workforce, and prioritizing overburdened and underserved communities, these principles stress the importance of replacing entire lead service lines, including the portion owned by the water system and the portion owned by the homeowner, to avoid creating a financial burden for residents.
Lead remediation efforts pay off in big dividends
A recent cost-benefit analysis of Michigan’s 2018-revised Lead and Copper Rule, which stated that all lead-contaminated service lines in Michigan must be replaced by 2041, found that LSL replacements more than pay for themselves in economic benefits.101 The analysis estimated that replacing more than 400,000 lead service lines in accordance with the rule would reduce exposure to as many as 420,800 newborns and generate nearly $3.25 billion in future benefits across lifetime earnings, savings in health expenditures, and education spending. This amounts to a return on investment of $2.44 for every dollar spent on LSL replacements. Notably, more than 150,000 nonwhite Michigan children, who disproportionately face the consequences of lead exposure, would benefit from LSL replacements—36 percent of all children affected; in total, 78,400 would be Black or African American, or 19 percent of all children affected. Meanwhile, more than 105,000 children—25 percent of all children affected—would be in households with incomes below the federal poverty level. In projecting estimates based on proactive replacement of LSLs, researchers found a net societal benefit of nearly $2 billion.
IIJA dollars to remove and replace lead service lines around the country are solving problems that communities have struggled to address for decades. The experiences of Pennsylvania and Wisconsin in leveraging these dollars to date provide the following lessons and recommendations for other states seeking to remove lead from drinking water using newly available federal funding.
1. Use the best available data to document the LSL landscape and track progress and impact
Although the federal government banned new lead pipes in 1986, the EPA did not until recently require water utilities to inventory them or systematically replace them.102 Among the White House’s guiding principles to reduce lead in drinking water is the importance of using innovative data, modeling, and mapping to guide lead mitigation.103 Accordingly, the Biden administration’s proposed Lead and Copper Rule improvements (LCRI) would require water systems to regularly update the inventories that the rule currently requires be completed by October 16, 2024.104 States should devote funding to creating an inventory of remaining LSLs to prioritize where to focus resources and replacement projects so that they are benefiting communities and neighborhoods with the greatest need. These inventories should also be used to help inform communities of their risks via public and easy-to-understand educational materials.105 LSL inventory data are critical for enabling any course corrections and demonstration of return on investment. States and communities should also develop impact trackers to document outcomes such as health benefits, economic impact, and job creation, and should evaluate and report equitable implementation, such as Pennsylvania’s analysis of funding in disadvantaged communities.106
2. Prioritize equity and environmental justice in LSL replacement strategies by targeting funds to communities disproportionately exposed to lead in their drinking water
LSL remediation efforts must prioritize populations that are most exposed to unsafe lead. Given the legacy of structural racism and segregation in America, this largely means prioritizing vulnerable communities, including low-income communities and communities of color. As states produce plans for distributing funding from their state revolving fund, their prioritization frameworks and LSL selection criteria should center equity along with efficiency and capacity. For example, Wisconsin’s equity prioritization plan considers instances of elevated BLLs in children, the concentration of lead service lines in a given area, and the relative socioeconomic conditions of various neighborhoods.107 States could also use the Biden administration’s Climate and Economic Justice Screening Tool to target LSL replacement funding to disadvantaged communities.108 The tool, developed to support the implementation of the Justice40 goal and initiative, identifies disadvantaged census tracts in all 50 states; the District of Columbia; and the U.S. territories using data on socioeconomic, environmental, climate, and other burdens. In addition, water utilities should provide consumers with information on LSL replacement projects in multiple languages and at a sixth-grade reading level, along with opportunities to comment and provide input, as they implement projects.
3. Replace entire LSLs—not just the portion owned by the local drinking water authority—to minimize harm and eliminate lead exposure
States and communities should implement protocols and supports to fully replace LSLs, including the portion on private property. Moreover, they should address all parts of potentially contaminated plumbing, including faucets and fountains, that may pose a public health risk, particularly in schools and child care facilities where children spend significant amounts of time. While states must commit to full LSL replacements in order to access IIJA funding, lessons from Wisconsin and Pennsylvania highlight legal and financial barriers that many states will need to address to complete LSL replacements at scale. For example, Pennsylvania’s law allowing municipalities to conduct work on private property and Milwaukee’s recently passed ordinance that addresses LSL replacement costs for consumers are important for facilitating complete LSL replacements. Particularly given that many consumers are already hesitant to allow work on private property, states looking to carry out this work should remove as many barriers to consumers as possible, including any cost responsibility for the private-side replacement.
4. Seek community input, invest in meaningful community engagement, and build community trust in state leaders and utility service providers
Community buy-in and input is critical to success, and states looking to carry out LSL replacement work must invest resources into educating, working with, and building trust in affected communities. Milwaukee conducts outreach through neighborhood groups and trusted community members. Likewise, Pennsylvania outreach workers provide the type of critical support needed to prepare communities to apply for resources and overcome distrust and skepticism, particularly given that LSL replacement requires entry into private property.109
Pittsburgh’s PWSA Community Lead Response Advisory Group is one example of how a municipality can seek vital community input and feedback to best serve customers, and its dedicated team of field workers has been effective at building buy-in among residents.110 Outreach efforts in the form of town halls and virtual lunch and learns have helped broaden the impact of IIJA dollars by encouraging and helping communities across the state to apply for and benefit from available funding.
PENNVEST’s experiences have also demonstrated the importance of offering technical support to increase community uptake, especially as LSL replacement projects can often take two to three years before they are ready for funding. PENNVEST’s free technical support pilot program pairs communities with a consulting engineer to help them develop their LSL replacement projects and apply for project funding, ensuring that they are construction-ready when they do so. Despite initial hesitation from many local officials about accepting the technical support, the project has been a success.111
5. Offer effective shorter-term solutions to protect communities from ongoing lead exposures as they wait for LSL replacements and offer support for accessing treatment
With millions of LSLs still in operation around the country, the significant cost associated with removal, and the serious harm inflicted on those exposed, every effort must be made to protect communities from lead exposure as early as possible and treat those who have already been exposed—for example, by lowering the threshold exposure level to receive medical treatment. States and communities should make certified lead water filters and tap sampling accessible to customers who are waiting on LSL replacement work. They should also publish and distribute LSL inventories and education materials to allow individuals to assess whether they are affected by an LSL and understand their risks and to seek treatment in cases in which they have already been exposed.
For instance, PWSA makes free lead test kits available through its website to all its customers who would like to test lead levels in their home drinking water; provides public education and community outreach on the health risks of lead exposure; and shares information on obtaining discounts on water pitchers that are certified for lead removal.112 With funds from IIJA, Milwaukee now covers water filters prior to LSL replacements and provides voluntary water testing before and after the replacement. States and communities also should promote accessible and affordable blood lead testing in places that children frequent, including schools and child care facilities as well as physician offices, particularly in high-risk areas with LSLs.
Safe drinking water is a fundamental human right that millions of Americans do not have. An aging water infrastructure, coupled with historically underfunded initiatives to correct environmental injustices, has exposed disadvantaged communities to high levels of pollution and toxic metals such as lead that have severe and lasting health consequences, particularly for young children. The Biden administration’s funding for LSL replacements and technical assistance through the IIJA provides a historic opportunity to protect Americans from dangerous chemicals and improve access to safe drinking water. The IIJA, together with the EPA’s proposal to strengthen the Lead and Copper Rule, creates an unprecedented chance to eliminate harmful LSLs in all communities.
Safe drinking water is a fundamental human right that escapes millions of Americans.
The recommendations offered in this report represent the next steps to protect vulnerable communities through short-term support as LSL replacements take place, supporting best practices in line replacement, and building community buy-in for LSL replacements through strong local partnerships. These administration investments and policies represent the most significant action ever taken by the federal government to eliminate lead pipes—a move that will improve public health and economic security and ensure safe drinking water for generations to come.
The authors would like to thank David Ballard, Kevin DeGood, Andrea Ducas, Emily Gee, Cathleen Kelly, Emma Lofgren, Marquisha Johns, Will Roberts, and Madeline Shepherd, along with interviewees in Pennsylvania, Wisconsin, and at the EPA, for their insights and feedback in the development of this report. The authors would also like to thank Erin Grant and Anuja Gore for their invaluable fact checking.