Navigating Customer Access, Funding, and LCRI Requirements for Lead Service Line Replacement

Are we truly prepared to provide safe drinking water to our communities? With aging infrastructure and the presence of lead service lines, this question demands urgent attention. Community leaders, local governments, and utilities must tackle the challenges of customer access, funding, and LCRI requirements head-on to ensure the health and well-being of their constituents.

In a recent CDA webinar, Alexis Woodrow, Lead Reduction Program Manager at Denver Water, and Marcus Elmer, Vice President for CDA, shared important insights on replacing lead service lines to ensure safe drinking water.

This session offered vital strategies and insights for effectively replacing lead service lines, equipping stakeholders with the tools they need to drive meaningful change in water safety. Additionally, we explored the LCRI requirements that impact these efforts.

Below we outlined how Denver Water approached customer access, funding and the LCRI requirements.

Understanding Copper's Role in Water Infrastructure

The Copper Development Association (CDA) is a nonprofit organization representing the global copper industry. Our mission is to unite North American copper and alloy semi-fabricators, along with producers from mining companies, to promote the proper use of copper in various applications. This commitment includes advocating for copper's role in replacing lead service lines, as copper is recognized for its safety, reliability, and sustainability.

Copper is the preferred material for service lines as it offers a safe and durable solution for both domestic plumbing systems and broader infrastructure needs. Copper's long lifespan and resilience against permeation make it an excellent choice for in-ground applications. Additionally, copper is infinitely recyclable without losing its inherent properties, which is essential for creating sustainable communities.

Denver Water: A Commitment to Safe Drinking Water

Denver Water is Colorado's oldest and largest water utility, serving about a quarter of the state's population, with just 2% of its water supply primarily from mountain snowmelt. It currently provides water to around 320,000 taps, with an estimated 20-28% potentially linked to lead service lines. Lead was commonly used until the early 1950s when copper became the preferred material for service lines. Although lead was banned in 1972, service lines from the main tap to the first fitting are the customer's responsibility, meaning Denver Water does not own these lines.

Key Aspects of Denver Water’s Lead Reduction Program

Denver Water’s lead reduction program includes five key components:

1. Public Inventory: A publicly accessible list of known and suspected lead service lines.
2. Increased pH Levels: Adjusted to 8.8 to reduce corrosion and improve water quality.
3. Lead Service Line Replacement: Targeting 64,000 lines, replacing around 5,000 annually, focusing on underserved areas.
4. Customer Support: Providing filters and cartridge replacements until lines are replaced.
5. Extensive Outreach: Educating the public on safe water usage and the importance of filters.

In 2022, Denver Water received $76 million from the bipartisan infrastructure law via the Colorado State Revolving Fund. This funding enables them to boost their replacement efforts significantly, with a plan to replace an additional 3,000 lead service lines from 2023 to 2025, ensuring safe drinking water for all communities served.

Challenges with Galvanized Service Lines

Denver Water has a significant amount of galvanized piping in its inventory, often beyond property lines, making replacement challenging, especially regarding the position of copper pipes. Documenting historical materials is difficult, and federal funding restrictions could hinder replacing galvanized lines with uncertain lead status.

Copper Supply Amid Rising Demand

A significant concern voiced by stakeholders is the availability of copper, especially in light of growing clean energy technologies. The good news is that there is sufficient copper to replace lead service lines, even with the EPA estimating around 12 million lines in total (including galvanized lines). Domestic manufacturers are ramping up production to meet this demand, understanding the industry's needs while adhering to regulations like the Build America, Buy America Act.

Manufacturers like Mueller Streamline in Tennessee, Cerro Flow in Missouri, and Cambridge-Lee in Pennsylvania—are investing in technology and capacity to ensure they can support the growing requirements for copper service lines.

Insights from Denver Water: Addressing Lead Service Line Challenges

Denver Water’s Unique Position: Denver Water has a unique position due to its history with the 2012 exceedance, leading it to operate under a variance for the lead and copper rule revisions. This variance enables them to implement optimal corrosion control and manage their lead reduction program, which includes replacing lead service lines and providing filters. Each water utility faces distinct challenges, but Denver Water benefits from a variance allowing it to replace customer-owned lead lines at no cost. This effort aligns with the lead and copper rule revisions, emphasizing community engagement and best practices for managing lead in drinking water.

Community Engagement Strategies

Effective communication is crucial for addressing public health issues like lead exposure. Denver Water uses various strategies, including direct outreach and social media, to inform customers about lead service lines and best practices. They prioritize engaging historically overlooked communities by partnering with trusted local organizations to enhance outreach and effectiveness.

Key Priorities for Transitioning to New Standards

As Denver Water navigated lead and copper rule changes, communication was a key priority to prepare customers for significant updates. Distributing over 100,000 filters required proactive messaging about the reasons for these changes. Additionally, a pH increase in the distribution system, starting in March 2020, necessitated clear communication with stakeholders, especially in the commercial and industrial sectors, for successful implementation.

Collaboration and Internal Support

The program's success relies on the contributions of dedicated individuals at Denver Water and contractors. It's crucial to communicate the importance of the lead and copper rule revisions to all staff, ensuring everyone understands the why and how for the program to succeed.

Building Trust Through Transparency

Trust is essential in community engagement. Denver Water’s ambassador program partners with trusted organizations, particularly in Hispanic and Latino communities, to share resources like water filters and educational materials. Transparency also plays a key role; the utility maintains an accessible online presence for information on initiatives and water quality. Additionally, Denver Water shares experiences with other utilities to encourage collaboration and help them avoid challenges.

Funding Strategies for Lead Service Line Replacement

The sheer scale of this initiative, estimated at $15 billion for nationwide efforts, can be overwhelming. Navigating the complexities of funding and advocacy is critical for success.

Innovative Funding Solutions

Denver Water is dedicated to replacing lead service lines and offering long-term filters at no cost to customers. Launched in 2020, this 15-year program is estimated to cost around $670 million. To manage expenses while keeping water rates stable, Denver Water spreads costs across all customers, financing over 30 years through debt and cash funding.

Federal support includes $6 million, with $40 million in principal forgiveness to ease financial pressures. Additionally, a partnership with Metro Water Recovery contributes $22.5 million to the program, helping avoid costly environmental impacts from orthophosphate treatment..

Challenges in Lead Service Line Replacement

Denver Water faces numerous evolving challenges in replacing service lines. Typically, this involves one or two excavations—one in the street and another at the meter. They often use trenchless technology to replace old lead lines with new copper ones, but many homes are over 120 years old, complicating the process.

Launched in 2020, the program faced initial delays due to the pandemic, as homeowners were hesitant to allow in contractors. PPE protocols were implemented to ensure safety for all. 

Aging infrastructure complicates underground utility detection, making it crucial to develop standard operating procedures. Working in tight crawl spaces and navigating city permits adds to the complexity, particularly concerning asphalt restoration costs.

Customer dynamics vary, as some are uncooperative, requiring careful management of site safety. Groundwater intrusion after heavy rain poses additional challenges, necessitating effective restoration strategies.

Lastly, compliance with federal funding requirements, including American Iron and Steel and Build America, Buy American (BABA) regulations, is critical as changes in labor and materials tracking arise.

Insights for Other Utilities

For other utilities considering similar projects, it’s vital to understand the reimbursement landscape for federal funding. From a budgetary perspective, consider the American Iron and Steel requirements and the potential administrative costs tied to receiving federal funds. Interestingly, Denver Water found that bid pricing from contractors does not vary significantly between regular and federally funded work—though restoration costs tend to be higher in federally funded areas.

Some costs, such as those related to meters and fittings, are non-reimbursable and can account for 10 to 15% of replacement costs. It's crucial to prepare for these additional expenses when budgeting for such initiatives.

Watch the full webinar here: