ENVIRONMENTAL FINANCIAL ADVISORY BOARD
Members
Thomas Liu, Interim Chair
Brent Anderson
Aurel Arndl
Lori Beary
Janice Beecher
William Cobb
Edwin Crooks
Hope Cupit
, Lisa Daniel
Marie De La Parra
Yvefte Downs
Heather Himmelberger
Jeffrey Hughes
David Kane
Suzanne Kirn
Pamela Lemoine
James McGoff
G. Tracy Meban, II
Chris Meister
Joanne Throwe
Jeffrey Walker
Jennifer Wasinger
Richard Weiss
Michael Shapiro
Designated
Federal Official
CCT 1 8 2017
The Honorable E. Scott Pruitt
Administrator
United Stales Environmental Protection Agency
1200 Pennsylvania Avenue, N.W,
Washington. DC 20460
Dear Administrator Pruitt:
The Environmental Financial Advisory Board (KFAB or the Board) is pleased to
present the enclosed report, "Financing Lead Risk Reduction". The report was
prepared alter considerable discussion among board members surrounding the news
about Flint, Michigan and other cities which struggle to pay for lead service line
replacements. According to the Pew Charitable Trusts, "removing leaded drinking
water service lines from the homes of children born in 2018 would protect more
than 350,000 children and yield $2.7 billion in future benefits. or about SI .33 per
dollar invested."1
In coordination with several U.S. EPA offices, the Board was charged with
identifying and recommending options for improving infrastructure through
innovative public and private sector financing. I !.S. EPA also asked the Board to
identify tools to finance lead risk reduction projects nationally, regionally, and
locally. The need for financing lead risk reduction was expanded beyond just lead
service lines to include lead paint removal projects.
in order to better understand what financing mechanisms could be proposed, EFAB
first reviewed the effectiveness of existing financing and funding programs and
identified gaps and barriers in utilizing these existing resources. Our report
identified new financing approaches that go bevond conventional measures and
recommends a more holistic approach that considers multiple sources of lead hazard
contamination through framing lead in the context of resiliency.
The Board reviewed current constraints and barriers to lead remediation and
assessed the gaps in existing financing and funding mechanisms. The Board also
provided a summary of man)' of the better known and frequently used lead
remediation programs and highlighted unique and noteworthy state and local
programs that were seen as worthy ease studies. Also included in the report is a job
impacts summary.
Innovative and Cost Effective Environmental Protection

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Lastly, we recommend new approaches lo financing and funding lead risk reduction
acti\ hies through existing programs such as the Drinking Water State Revolving
Loan fund ("SRI- ). a widespread and successful federal-sktle-loeal partnership that
already broadly uses the capital markets to expand slate low interest and low
transaction cost loan capacity, water infrastructure pooled loan financing program.
"PACEVtax lien financing, and the linked deposit loan program. These financing
options are examples of looking at lead risk reduction opportunities that go beyond
traditional funding mechanisms and support using more innovative approaches.
We hope this report is helpful to you and the US EPA .staff and would be pleased lo
discuss our analysis and summary in further detail.
Sincerely.
,v-'' ' w /«
{	J-
I "
Tom Liu, Interim Chair
Bnvironmental Financial Advisory Board
Enclosure
cc: Mr. Bam' Breen. Acting Assistant Administrator
Office of Land & Lmergcncs Management ((>1.1 Ml
Ms. Nancy Beck. Acting Assistant Administrator
Office of Chemical Safety and Pollution Prevention (OCSPP)
Ms. Sarah Dunham. Acting Assistant Administi not
Office of Air & Radiation (OAR)
Mr. Michael Shapiro. Acting Assistant Administrator
Office of Water (0\\ l
1 The Pew Charitable Trusts, 10 Policies to Prevent and Respond to Childhood Lead Exposure. August 30,2017.

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Environmental Financial Advisory Board
EFAB
Financing Lead Risk Reduction
Mike Shapiro
Designated Federal
Official
Members
Thomas Liu, Chair
Brent Anderson
Aurel Arndt
Lori Beary
Janice Beecher
William Cobb
Edwin Crooks
Hope Cupit
Lisa Daniel
Marie De La Parra
Yvette Downs
Heather Himmelberger
Jeffrey Hughes
David Kane
Suzanne Kim
Pamela Lemoine
James McGoff
G. Tracy Mehan, III
Chris Meister
Joanne Throwe
Jeffrey Walker
Jennifer Wasinger
Richard Weiss
This report has not been reviewed for approval by the U.S. Environmental
Protection Agency; and hence, the views and opinions expressed in the
report do not necessarily represent those of the Agency or any other
agencies in the Federal Government.
October 2017
Printed on Recycled Paper

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FINANCING
LEAD RISK REDUCTION
REPORT
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Table of Contents
Part 1: Introduction of EPA Charge	Page 4
Part 2: Summary Observations, Opportunities and Options for Financing Lead Risk Reduction Page 4
Part 3: Framing the Issue of Lead	Page 5
A.	Understanding the Concerns of Lead Paint	Page 6
B.	Constraints and Barriers to Remediating Lead Paint	Page 6
C.	Understanding the Concerns of Lead Service Lines	Page 6
D.	Constraints and Barriers of Lead Service Lines	Page 7
E.	Private Owned Plumbing	Page 7
F.	Financial Considerations	Page 8
Part 4: Assessment of Existing Financing/Funding Mechanisms and Identified
Gaps and Barriers	Page 9
A.	Federal and State Funding and Financing Programs	Page 9
B.	Utility rates and charges	Page 10
C.	Regulatory Constructs and Water Rates	Page 10
D.	Local Codes, Ordinances and Rebates	Page 11
E.	Tax Credits	Page 11
F.	Lack of Data	Page 11
G.	Insufficient Program Coordination	Page 12
H.	Insufficient Public Outreach and Education	Page 12
I.	Lack of Financing Clarification in Federal Law	Page 12
J. Incomplete Research	Page 12
Part 5: New Approaches to Financing/Funding Lead Risk Reduction Activities with
Existing Programs	Page 13
A.	Direct Financing Through the State Revolving Fund Program	Page 13
i.	Exhibit 1 - Direct Financing through the State Revolving Fund Program	Page 14
B.	Water Infrastructure Pooled Loan Financing Program	Page 15
ii.	Exhibit 2 - Water Infrastructure Pooled Loan Financing Program	Page 15
C.	Linked Deposit Loan Program	Page 16
iii.	Exhibit 3 - Linked Deposit Loan Program	Page 17
D.	Institutional Debt	Page 18
E.	"PACE"/Tax Lien Financing Program	Page 18
iv.	Exhibit 4 - "PACE"/Tax Lien Financing Program	Page 20
F.	Point-Of-Sale Funding	Page 20
G.	Impact, Green or Environmental Social Governmental (collectively ESF) Investment	Page 21
H.	Tax Credits	Page 21
I.	Infrastructure Trusts	Page 22
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Part Six: The Opportunity of Achieving Financing and Implementation Scale	Page 23
A.	Opportunities to Link Lead Abatement and Resilience and Broad Scale
Infrastructure Investment	Page 23
B.	Co-financing: Linking Lead Mitigation to Energy Efficiency and Human Health Programs	Page 24
C.	Integrated Planning: Achieving Financing Efficiencies through Strategic Project Selection,
Planning, and Staging	Page 25
Part Seven: Conclusion	Page 25
Appendix A: Existing Funding Sources	Page 27
Appendix B: Summary of Financing Alternatives Based Upon a Number of the Criteria for
Both Providers of Capital and the Borrowers/Owners	Page 50
Appendix C: Significant Case Studies	Page 51
Appendix D: Lead Abatement Industry Employment Data	Page 64
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Part One: Introduction to EPA Charge
US Environmental Protection Agency (USEPA) charged the Environmental Financial Advisory Board
(EFAB) with identifying and recommending options to improve infrastructure by encouraging innovative
private and public financing. USEPA asked EFAB to specifically identify tools that can be used to finance
lead-risk reduction projects nationally, regionally, and locally. The hazard of lead contamination impacts
all populations in urban, suburban, exurban and rural communities throughout the United States,
regardless of household income levels.
USEPA's charge asked the EFAB to review the effectiveness of existing financing and funding programs
and options, and identifies gaps and barriers to success in these resources. Finally, USEPA asked EFAB to
identify potential new approaches, beyond conventional financing of mitigation by taking a more holistic
approach, one that considers multiple sources of both lead hazard and contamination, and funding
sources.
Part Two: Summary Observations, Opportunities and Options for Financing Lead
Risk Reduction
Below we provide an assessment of the current lead abatement financing landscape as well as
opportunities for expanding the current funding and financing programs. We will begin with a brief
summary of the issues impacting lead abatement as well as the opportunities and options for moving
forward.
•	Existing financing programs provide an excellent foundation for expanding lead abatement
programs. Though there is a critical need for new and innovative lead abatement financing
approaches and tools, there is a financing foundation in place through existing programs such as the
State Revolving Loan Fund Program, the linked deposit program, and PACE energy financing. The
first step in creating new financing tools should be to clarify the potential for existing mechanisms to
be expanded and modeled for lead abatement. Federal and state leaders can play a critical role in
this regard.
•	There is a critical need for better coordination. Until there are no new cases of lead poisoning and
all testing levels are zero, there is still a need for better organization and coordination within every
state to address lead contamination issues. Though there are examples of very effective programs
across the state, the ubiquitous and insidious nature of the lead contamination problem will require
myriad programs working in concert across multiple infrastructure financing processes and projects.
Federal and state leadership and coordination would be invaluable in this regard.
•	Lead abatement and reducing lead exposure must become much more of a policy and financing
priority. The adverse impact of lead on human health requires a more concerted effort by public
leaders to make the issue more of a priority. Specifically, there needs to be prioritization for lead
removal programs, better education to inform homeowners about the hazards of lead, and the
funding and financing tools available for supporting lead abatement activities.
•	Existing federal funding programs can be improved by modeling state programs. Federal funding
and reimbursement systems should be modeled after successful practices set up by other states. In
other words, what is working should be scaled and modeled at the local, state, and federal levels.
Specifically, eligibility for funding should be based on public-health goals and financial needs.
•	Existing funding and financing systems are too myopic. Though there are a variety of funding
programs available, these programs are often only applied to specific lead abatement issues or
sources of lead, whether they are from paint, pipes, or fixtures. Though targeted resources will
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always be necessary and a reality, it is essential that they are supplemented and strengthened with
programs that are holistic in nature and able to be implemented based on unique community and
homeowner needs.
Part Three: Framing the Issue of Lead
Lead poisoning is entirely preventable. Lead poisoning often results in no obvious symptoms and can go
unrecognized until serious damage has occurred due to accumulation in the brain, nervous system, red
blood cells, and kidneys. Air, soil, dust, food, paint, cosmetics, cookware, batteries, water, etc. can
expose humans to lead. Once lead enters the human body it accumulates in bones, blood, and tissue. If
the problem is caught in time, before permanent damage occurs, the source of lead can be removed and
the accumulated levels of lead in the body will start to recede.
Generally, lead exposure has a greater impact on children, which tend to show signs of severe lead
toxicity at lower levels than adults. The outcome is particularly debilitating on developing brains,
resulting in permanent intellectual and behavioral problems. According to the Centers for Disease
Control and Prevention (CDC), approximately 535,000 children between the ages of one to five are
currently diagnosed with elevated blood lead levels (EBL) of 5mg/dl or higher, although any EBL is a
cause for concern1. Even low levels of lead poisoning in children can cause learning disabilities,
decreased intelligence, speech problems, hearing loss, hyperactivity, attention deficit disorder, and even
aggressive and violent behavior. Higher levels of lead exposure can reduce motor control and balance,
developmental disabilities, organ damage, coma, convulsions, and even death. Though children are
most at risk, even adults with low levels of lead exposure may experience impacts such as fatigue,
impaired concentration, depression, and an increased risk of cardiovascular disease, and early mortality.
High levels of lead exposure in adults can also cause hearing loss, anemia, miscarriages or stillbirths,
seizures, and death.
Lead is a significant public health concern in cities with older infrastructure. The primary sources of
concern are lead-based paint from dwellings built before 1978 and drinking water as a result of
corrosion of household plumbing fixtures and lead-containing service lines (the pipes connecting the
household to the water main.). In addition to these sources, the soil around homes and public places,
including schools, childcare facilities and playgrounds can also become contaminated with lead from air
pollution or lead paint chips generated by improper remodeling projects. While lead was removed from
gasoline several decades ago, it can still be present in the soil near roadways.
A. Understanding the Concerns of Lead Paint. The federal government banned the use of lead-
based paint in 1978, following studies that showed a strong connection to severe health
problems (particularly in children under the age of six). However, exposure to lead from lead-
based paint remains a significant and widespread environmental hazard in many states. Millions
of dwellings still contain lead-based paint on their walls and windows. When the paint is not
flaking or chipping into "bitable" and ingestible pieces it is not considered a hazard, but it may
be difficult to keep the home in this condition long-term. If lead-based paint is removed
through scraping it is an immediate hazard. Scraping and sanding creates a very harmful dust
that can be inhaled. It is essential that lead-based paint is removed through proper procedures
to protect residents. However, paint peels much more easily from window frames because of
the friction caused by frequent opening and closing. Lead poisoning can be prevented by
screening children at risk and correcting these hazards, especially in older dwellings.
1 https://www.cdc.gov/mmwr/preview/mmwrhtml/mm6213a3.htm
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Although the nationwide decline in lead paint poisoning since the 1978 ban is considered a
public health success story, until there is zero exposure, children will remain at risk and there is
a need to expand efforts to eliminate all exposures to lead.
B.	Constraints and Barriers to Remediating Lead Paint. In 2008, EPA issued the Renovation, Repair
and Painting Rule (RRPR). This rule requires contractors working in pre-1978 homes to be
certified as lead-safe and therefore to utilize specially approved practices to control and clean
up the dust resulting from any home remodeling. The RRPR covers all renovation activity
including small projects when more than six square feet of painted surface inside or twenty
square feet outside are disturbed. While it is good that this rule covers even small painting
projects or even a single window replacement, homeowners and landlords may not be aware
that they should work only with a lead-safe certified contractor or may take a Do-lt-Yourself"
(DIY) approach.
As a result, some states are proactively addressing potential contamination problems beyond
the RRPR. For example, Maryland strengthened its prevention, control, and enforcement
policies following the CDCs recommendation for increased action and advocacy. Maryland's
Lead Law requires pre-1978 rental dwelling units to be registered to reduce the potential for
children to be exposed to lead paint hazards by performing specific lead-risk reduction
treatments prior to each change in tenancy. When coupled with required blood level testing in
children, the Maryland law can significantly reduce the lead poisoning risk. Maryland also
revised its Lead Testing Targeting Plan, effective March 28, 2016, to define the entire state as
"at-risk" for exposure to lead and required that children born on or after January 1, 2015 be
tested for lead exposure at ages one and two.
Even with the RPPR adoption, there are vast differences among the states related to regulations,
including testing requirements and enforcement. For example, even if state regulations require
physicians to perform blood lead level tests on young children, the results are not always sent to
the state Health Department for action, follow-up, tracking, or action. Many states wrongly
believe that lead from paint or dust is no longer an issue, especially when compared to the issue
of lead in service lines such as Flint, Michigan.
C.	Understanding the Concerns of Lead Service Lines (LSLs). Many policy measures have been
implemented over the last several decades to manage lead exposure within the nation's
drinking water systems. These measures include the 1996 amendments to the Safe Drinking
Water Act (the Lead and Copper Rule) and the 1988 Lead Contamination Control Act.
Unfortunately, an estimated 6 million or more lead service lines remain in use nationwide by
more than 11,000 community water systems serving as many as 22 million Americans.2 The
crisis in Flint heightened national awareness of the issue prompting many utilities to examine
whether or not they had lead exposure from drinking water service lines or plumbing and to
consider actions they should take. It also prompted advocacy, including the American Water
Works Association (AWWA), which champions a policy of "eliminating all lead service lines" from
community water systems.3
2	Cornwall, David A. and Brown, Richard. National Survey of Lead Service Line Occurrence. Journal AWWA (Vol.
108 No. 4) April 2016.
3	https://www.awwa.org/publications/connections/connections-story/articleid/4081/together-lets-get-the-lead-
out.aspx
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D.	Constraints and Barriers of Lead Service Lines. One of the biggest constraints to replacing lead
service lines is the cost associated with full replacement of the lines. In Flint, Michigan, for
example, lead service lines were connected to galvanized pipe and after almost a century of use,
the iron rust absorbed the lead at very high levels. When Flint decided not to continue corrosion
control measures, the iron rust fell off, carrying a significant amount of lead with it into the
water system. To date, Flint has removed 800 lead-tainted pipes but must replace another
28,000 before its system is fully upgraded.
Although the high cost of pipe replacement is probably the biggest barrier facing communities,
another is that cities do not always know where their old pipes are buried, what material they
are made from, and/or do not have records in readily available format. Many systems, like Flint,
were put in place many decades ago before GIS mapping was available. As a result, many
communities do not have accurate information regarding location, type of pipe, service data, or
condition. Even though newer technologies are available, many cities across the country still
need to conduct an inventory of their existing infrastructure assets. Asset management requires
capital, capacity, and technology, and might also reveal a much bigger lead concern than
originally imagined. Such was the case in Washington, D.C., which began replacing lead pipes in
the early 2000s and discovered the extent of the lead problem had been greatly
underestimated.
Even if a utility desires to replace all of its lead service lines, additional barriers may exist when
homeowners are unwilling or unable to pay the cost of replacing their portion of the service line.
In only a few locations do water utilities own the service line running to the home. Some
communities experience an "unwillingness to pay" for the cost of full service line replacement,
which typically involves private property. Typically, this type of replacement necessitates
coordination between a private plumbing company and a utility to complete the entire
replacement. Understanding the type of plumbing in the household may create additional
delays and costs. These problems are primarily mitigated when a utility owns the entire service
line, but this ownership system is less common than mixed ownership of the service line. When
the extent of lead in service lines is unknown, water quality testing for lead is another means of
determining the extent of the contamination. This testing is not without its own challenges,
however, as utilities must rely on homeowners to be willing to take the tests and to understand
how the test should be administered. There is no guarantee that a test was taken from the
correct location or using the correct procedures. Testing can also be expensive to conduct and
often requires qualified personnel to administer. When high lead levels are found, filters are
sometimes used by communities to reduce lead levels, but filters must be routinely replaced
and are not a permanent solution to the exposure risk.
E.	Privately Owned Plumbing. It is important to note that in addition to privately owned LSLs the
plumbing and appurtenances within buildings, particularly those built decades ago, will have
lead content as well as lead solder. Therefore, even if LSLs are totally removed, exposure to lead
will still prevail until the plumbing is replaced.
While state and local plumbing codes and environmental regulations restrict lead within the
plumbing and fixtures, often these requirements do not require immediate retrofit of plumbing
and fixtures containing lead, thus elimination of those lead sources require either voluntary
owner action or required retrofits in connection with building renovations or when building
permits are issued related to the property. In addition, there is no utility or other public
ownership interest in private plumbing and therefore utility sponsored activities will not
mandate owner action. Given the absence of utility ownership, the likelihood of utility
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sponsored funding or financing programs is diminished and property owners will need to look to
direct government and/or private sector sources.
F. Financial Considerations. For residential and rental building owners alike, there are a number
of financial considerations that affect their decision to address lead exposure, whether related
to lead in water supply and plumbing or lead based paint. First and foremost, is the issue of
cash-flow. Typically, owners do not have a substantial price reduction at the time of purchase
for these issues. They are disclosed, but given the commonality of the issue, they are not
addressed from a pricing perspective. With the exception of demolition or renovation, these
issues are not addressed from a reserve perspective either. Homeowners and rental building
owners rarely establish a reserve account to address building environmental issues. (Not so
related to radon and malfunctioning septic systems). Conversely, during renovation or
demolition, building environmental issues often are part of the budget and are addressed
through the capital improvement budget.
Second, investment in addressing lead exposure rarely leads to a significant return on
investment. Houses where the lead issues have been fully resolved command similar prices to
those properties with unabated problems. Moreover, the market values properties on
numerous factors which outweigh an investment in lead reduction. Similarly, investment in lead
abatement in rental units shows a poor return on investment. Rents, like home values, are
controlled by the market. Landlords price for what the market will bear. Tenants will make
decisions based upon what they can afford. An investment in lead abatement will not allow the
landlord to increase rents significantly.
In both of these instances, owners have little financial incentive for addressing lead issues.
However, the decision becomes more complex where lead abatement is part of improvements
that enhance the value of the property in ways the market will recognize. For example, replacing
all of the old plumbing in a house as part of an extensive renovation can improve the overall
value of the property. The value creation results from the overall appeal of the renovated
property, with the comfort of knowing that all of the plumbing issues are resolved. Similarly, in a
rental context, an owner may see value creation through renovation. For example, a freshly
renewed property with new lead-free plumbing fixtures will likely command higher rental rates,
and such higher rates justify the necessary capital improvements.
Another financial consideration, particularly in the context of renovation, is the cost of funds.
Many public financing sources have very low (2% to 3%) interest rates. The difference between
this amount and traditional sources is minor for individual homes. However, for renovation of
larger rental properties, these savings could be sufficient to have the owner consider additional
sources of low cost funds to address lead exposure. These lower cost funding opportunities
would be most attractive when the lead abatement funding has the dual benefit of reducing
lead exposure as well as enhancing the value of the property as set forth above.
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Finally, owners need to consider the costs of gaining access to non-traditional funding sources.
If the funding benefit is low and the application process and approval complex, owners will not
be enticed even by low cost funds and make their decisions based upon a known process and a
known cost. Of concern, particularly with rental property owners, is the cost of delay which,
depending on the application period and the scope of the work, could lead to unoccupied
property(ies) for extended periods. Since these funds are a minor component of the capital
stack, the costs of delays could quickly outweigh any lead abatement costs.
Part Four: Assessment of Existing Financing/Funding Mechanisms and Identified
Gaps and Barriers
Ultimately, consumers pay, either directly or indirectly, for lead mitigation and remediation. Direct
payment means those fees and charges, including payments to remediation firms, are paid by
individuals. Direct payments do burden some consumers, particularly low-income households. In
contrast, taxpayer or utility ratepayer-supported initiatives help spread costs over a wider base through
indirect means. Indirect payment through tax or ratepayers recognizes that, in the end, lead mitigation
and remediation saves tax or ratepayers money by avoiding large, unnecessary costs due to poor health,
disability, social disruption, incarceration and early death. As a challenge that imposes society-wide
costs, lead mitigation and remediation calls for a portfolio of solutions; no one option will work for all
communities because the nature of the problem and the community addressing it will vary widely.
While lead contamination is geographically dispersed and often found on private property, it can be
likened to a "superfund"-type problem. As an environmental and health threat, lead presents a difficult
challenge because it is often found on private property and may be mixed ownership between the utility
and the homeowner. As we mentioned above, this mixed ownership creates a particular challenge for a
utility because replacement may need to be coordinated between a homeowner and the utility because
partial replacement of service lines (replacing only that portion owned by the utility) can actually worsen
the lead problem. For this reason, remediation will require new models of shared responsibility,
coordination, and funding between utilities and customers.
Lead contamination is an entrenched, harmful, and insidious public health problem in the United States.
The most effective public funding and financing programs are those that support those actions that
quickly, efficiently, and effectively remediate lead exposure, especially among the most vulnerable
populations. Eligibility for funding is often based on public-health goals and financial needs. Before
determining what innovative mechanisms can be recommended and implemented, it is important to
look at existing programs for lead hazard reduction and infrastructure investments to determine gaps.4
Later in this report we provide recommendations and options for scaling the lead mitigation and
remediation financing.
A. Federal and State Funding and Financing Programs. As with most large-scale public health,
infrastructure, and economic need, addressing lead exposure will end up being a public funding
and financing systems. To that end, federal programs from the following agencies constitute the
most widely used and well-known programs:
•	Department of Housing and Urban Development (HUD)
•	Department of Agriculture Rural Development (USDA/RD)
•	Environmental Protection Agency
•	Department of Energy (DOE)
4 Please refer to Appendix A for a more detailed list of some of the more widely used funding sources for lead
hazard reduction and infrastructure investments.
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•	Economic Development Administration (EDA)
•	Center for Disease Control (CDC)
These agencies offer a variety of programs to help local communities mitigate lead exposure
from paint and lead service lines. Though these programs often serve as the foundation for
many other state and local lead funding programs, there are constraints to their use. For
example, most federal programs require a local match, and though the programs cover a range
of housing types they are mostly geared towards single-family and multi-family residences. In
spite of these potential limitations, federal programs can address multiple community needs.
For example, while most federal programs target safe housing repairs, DOE weatherization
funds can pay for the replacement of lead-based painted windows and doors, while the EDA
focuses on job creation and private investment in economically-distressed areas. Although the
DOE and EDA programs do not specifically target lead, both are well suited for lead removal
projects.
Perhaps the most widely used federal funding source is the Community Development Block
Grant (CDBG) program. Using a set formula that considers many factors such as population,
poverty and the age of housing, almost all U.S. states (except Hawaii) are then able to provide
smaller communities an opportunity to use these funds to preserve affordable housing, provide
services, and to create and retain jobs. Many states that receive funding from HUD and DOE use
the funds to create programs that target lead paint concerns, lead service lines, or home
weatherization needs that are specific to their state's needs to protect children, pregnant
women, low income households, and seniors. Some states, such as New York, use their funds to
establish incentives to encourage lead mitigation and remediation.
Though grant funds are obviously highly sought after, federal and state loan sources are more
widely used, like the Drinking Water State Revolving Fund, Rural Utility Service (RUS) or the
Federal Housing Authority (FHA) loans. Grant programs are also common. These programs, like
the one found in Phoenix, Arizona's Lead Hazard Control Program, help homeowners, landlords
and tenants in targeted areas who are in the low-to-moderate income level, must include a child
under age six or pregnant resident, and the residence must be constructed before 1978.
B.	Utility rates and charges. Perhaps the most direct way to finance lead abatement projects is
through on-bill financing of regulated private and publicly owned utilities. Specifically,
ratemaking treatment by regulators can provide incentives or disincentives to address lead in
drinking water systems. State public utility commissions are in the process of identifying various
models for recovering the cost of replacing lead service lines. A potential barrier to the
expanded use of utility revenue to financing lead abatement, especially to underserved
communities, is that certain states have "anti-donation" clauses which limit or restrict
state/local government/utility funding of certain expenses related to individuals or subclasses of
the community or utility customer base. For example, New Mexico's state constitution states
with respect to the construction of any railroad that "neither the state nor any county...or
municipality...shall directly or indirectly lend or pledge its credit or make any donation to, or in
aid of any person, association or public or private corporation."
C.	Regulatory Constructs and Water Rates. Investor owned utilities routinely fund capital
investments and recover the associated financing costs from customers in utility rates. Low cost
loans, grants or property tax credits, when available, are funded through taxation. Therefore, a
"zero cost" lead replacement solution is not really "zero cost" when citizens are taxed to
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support it. If taxpayer supplied capital, like grants, are available to investor-owned utilities, then
such a funding vehicle should be used to replace service lines. Investor owned utilities routinely
recover infrastructure costs associated with restoring other parties' assets. While water utilities
do not own the roads, sidewalks, driveways, patios, etc. these are often dismantled or disrupted
to replace infrastructure projects. The cost and work of restoring these assets are properly
capitalized and collected in utility rates. This has two important advantages. First, it allows the
utility to complete the work, which is a more efficient and thorough approach than relying on
individual homeowners to make arrangements for the work and the financing. Second, recovery
of lead service line replacement through water rates spreads the cost to the entire customer
base, just as the costs of other localized projects such as main replacement, pump stations, and
storage tanks are spread out to the entire customer base.
D.	Local Codes, Ordinances and Rebates. Though not technically a funding source, local codes and
ordinances, as well as local fee rebate programs, can be effective tools for encouraging lead
mitigation and remediation. Specifically, these tools have the potential to move citizen and
ratepayer action either through statutory requirement or financial incentives. Madison,
Wisconsin, for example, passed an ordinance that required property owners to replace their
portion of the lead service line. Homeowners who choose not to comply can be charged a
monetary penalty that can be quite high. Disparities in local regulations may be a significant
barrier to addressing lead issues through codes and ordinances. Model codes and ordinances
are useful in this regard, particularly the disclosure of lead risk. The most effective ordinances
address both single-family and multi-family housing, as well as penalties for noncompliance.
Rebates have been used to promote lead service line remediation. In Boston, Massachusetts,
property owners are eligible to participate in a lead replacement credit of up to $2,000 towards
the cost of the replacement. Menasha, Wisconsin also provides rebates to property owners of
50% of the replacement cost for the homeowner's portion of the service line, although the
rebate has a cap.
E.	Tax Credits. Federal tax credits are not an existing funding source to mitigate lead, though they
have been used within the federal and state tax structure to incentivize certain investments by
individuals, businesses and investors. State tax credits, however, have been used successfully for
lead mitigation. In Massachusetts, for example, property owners who receive a letter of Full
Compliance are eligible for a state tax credit equal to the cost of the lead removal expenses, or
$1,500, whichever is less. Rhode Island is another state that authorizes an individual to take a
credit against their personal income tax liability for residential lead removal or lead hazard
reductions under certain conditions.
Key Gaps and Barriers. Though each of the above programs has their own unique opportunity and
barriers, there are a few common issues that have prevented many of them from being used to the
maximum extent possible.
F.	Lack of Data. In many communities, lead contamination may not be well known or mapped.
The available data also may not be readily accessible. The high cost of gathering and developing
accessible information sharing platforms can be a barrier to action.5
G.	Insufficient Program Coordination. Programs exist at all levels of government and
fragmentation is a challenge. Information sharing and coordination can help facilitate
5 See http://www.civicmapper.com/2016/ll/15/lead-pipe-mapping/

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implementation of remediation projects by lowering costs to participating agencies and
providing an opportunity for prioritizing resources to the highest priority projects. States could
establish a central information source on remediation for all forms of lead contamination.
Engaging the nonprofit sector and public health agencies will be important as well.
H.	Insufficient Public Outreach and Education. More attention is needed to public outreach and
engagement on lead issues. This may involve developing materials in alternative format and
languages and identifying appropriate means of communication, including community forums
and online resources. Working with community organizations may increase the effectiveness of
these efforts.
I.	Lack of Financing Clarification in Federal Law. Federal law and rulemakings regarding lead
contamination in various media (paving, soil, and water) should be clarified. In particular,
requirements for testing for lead exposure in public and private schools should be clarified.6
J. Incomplete Research. Research is needed to ensure that programs are cost-effective.
Evaluation and performance metrics ensure that resources are devoted to the most cost-
effective programs. The Environmental Finance Centers and others can be deployed to identify
the most effective and efficient practices.
6 Recommended revision to the lead and copper rule of the SDWA can be found
here: https://www.epa.gov/sites/production/files/2016-01/documents/ndwaclcrwgfinalreportaug2015.pdf
12

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Part Five: New Approaches to Financing/Funding Lead Risk Reduction Activities
with Existing Programs
As we described above, there is a foundation for financing lead abatement in place. Next we address
some of the opportunities to modeling other successful financing programs as well as building new and
innovative programs, tools, and processes. We address innovative financing opportunities that have the
potential to be applied to lead abatement. These include: The State Revolving Fund (SRF) Program; the
federal-state-local water infrastructure pooled loan financing program that harnesses the capital
markets to expand low-interest loan capacity; the "PACE" tax lien financing program; the linked deposit
loan program; and, innovative public private financing.
A. Direct Financing Through the State Revolving Fund Program. Given the success of SRF
programs throughout the U.S., there is an opportunity to directly fund lead mitigation and
remediation efforts under the Drinking Water SRF program. Existing Drinking Water SRF
programs are a widespread and successful federal-state-local loan partnership that already
broadly uses the capital markets to expand state low interest and low transaction cost loan
capacity. More specifically, the SRF program can provide direct funding via the capital markets
to a municipality which aggregates approved homeowners' funding requests and secures the
aggregate loans with its general obligation or other security pledge. This financing approach
offers two important benefits:
•	A below-market interest rate: as required under the SRF program which is also
attractive to homeowners; and,
•	Economies of scale relating to the bond issuance costs: SRF programs are pooled
financing, which allows fixed issuance costs to be spread across all borrowers and a
potentially large funding base, which exists in most states. This assumes that
participating homeowners provide their personal credit to secure the loan as opposed
to an assessment on their property (also discussed in the "Adopting a PACE/Tax Lien
Financing Program" recommendation below). Furthermore, current SRF program
requirements under the Federal Drinking Water SRF program would still need to be
met.7 The schematic in Exhibit 1 below explains how the program would work.
Generally, the SRF program has the potential to offer two financing benefits to address tax
restrictions. First, the SRF program can provide loan financing to a non-governmental person
from an SRF tax-exempt bond financing, in an amount equal to the lesser of:
(a)	$5 million, or
(b)	5% of the bond proceeds under the "private loan test" requirements of the current
tax code.
If these limits are exceeded, the entire SRF bond financing may be deemed taxable and subject
to higher rates and the issuer subject to certain penalties. Furthermore, once the tax-exempt
bond proceeds are loaned to municipalities, there may be restrictions on the loan rate that the
7 Since most SRF programs in the U.S. provide funding for their borrower needs by leveraging in the municipal
capital markets on a tax-exempt basis, SRF programs have various tax restrictions pertaining to the issuance of
bonds, the use of bond proceeds as well as other restrictions in order to maintain the tax-exempt status of its SRF
financing. Though this report considers these tax requirements on a general level, SRF programs should engage
tax counsel to review, analyze and opine on all tax requirements relating to this financing recommendation.
13

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municipality can charge to the homeowners. However, SRF program assets that are "not
attributable" to a tax-exempt financing - such as Federal capitalization grant monies and
servicing fees - may not be subject to these limitations.
Second, the SRF program can provide loan financing through the issuance of taxable bonds,
which in the current market may only be a slightly more expensive option than tax-exempt
financing. More importantly, unlike a tax-exempt financing, a taxable bond financing typically
does not involve any tax or financing restrictions (such as the limitation on the municipality's
loan rate to the homeowner). Additionally, in the current market, the taxable rates, especially
for highly-rated SRF programs, will typically be lower and thus more attractive when compared
to the homeowners' alternative cost of funds.
Exhibit 1 - Direct Financing through the State Revolving Fund Program
Bond
Repayments
A
Loan Repayments'1'
7k
Loan Repayments'1'
Loan Repayments'1'
Loan Repayments'2'
Loan Repayments'2'
Loan Repayments'2'
Bondholders
Municipality
Homeowners
SRF Program
Municipality
Homeowners
Municipality
Homeowners
(1)	Backed by municipalities' general obligation pledge
(2)	Backed by homeowners' credit
In addition to the increased funding available for qualified homeowners described in the loan
financing scenarios above, this financing strategy benefits the SRF programs by increasing the
borrower diversity of the SRF loan portfolio (which is important to maintain the SRF program's
ratings and to address any borrower concentration concerns) and by increasing the SRF
program's efficiency and funding capacity (which is achieved by converting available monies to
long-term loans and leveraging the corresponding loan repayments). While the first financing
opportunity described above tends to favor larger SRF programs with a relatively large asset
base and tax-exempt financings, the second financing opportunity can benefit all SRF programs
It is important to consider that for this financing recommendation. It assumes the active
participation of the local government/utility/SRF borrower in the following:
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(a)	Aggregating homeowner loans,
(b)	Securing it with the municipality's general obligation or utility revenue pledge,
(c)	Seeking funding through the SRF program, and
(d)	Tracking homeowner loan repayments.
Furthermore, the local government/utility/SRF borrower is assuming the full credit risk
associated with the homeowner not making their loan repayments. Given the limited staffing
and resources at the local level, as well as the associated credit risk related to each homeowner
loan, the local government/SRF borrower may not be able or want to serve in this function,
especially with relatively smaller, less financially sophisticated local governments.
B. Water Infrastructure Pooled Loan Financing Program. In addition to expanding the impact of
the SRF program, there is also the opportunity to establish a water infrastructure pooled loan
(non-SRF) financing program as:
i.	an extension of the existing SRF program to increase funding/loan capacity; and/or,
ii.	a separate program to fund the borrowers' SRF ineligible water projects.
A water infrastructure pooled loan financing program - a state-level general water financing
program which offers prospective borrowers low cost, fixed rate long-term loans - can be easily
structured/modeled after the existing SRF program. As with the "Direct Financing through the
State Revolving Fund Program" recommendation above, the program funding would be
provided through bond financing on a tax-exempt or taxable basis. Additionally, this approach
offers: (i) a potentially lower cost of funds - relative to the borrowers' alternative cost of funds,
especially for lower-rated borrowers, (ii) economies of scale relating to the bond issuance costs
- similar to SRF programs as discussed above, and (iii) a new funding program - which provides
economical as well as expanded funding capacity. This is described in schematic in Exhibit 2
below.
Exhibit 2 - Water Infrastructure Pooled Loan Financing Program
Loan Repayments
State Water
$

Infrastructure Pool
Loan Financing
Program
Bond Repayments
Bondholders


Loan Repayments
Loan Repayments
Loan Repayments
Municipality
A
Municipality
B
Homeowner
1
Homeowner
2
Please note that this structure relies upon the credit strength of the underlying borrowers. If
additional credit strength is needed, the state can consider the use of additional enhancements
such as double-barrel structures (i.e., using a revenue pledge and a second security pledge such
as sales taxes), state-aid intercept and bond insurance.
15

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If equity funding (e.g., contributions and grants) is possibly available as with the SRF program,
these monies can be used in various ways (i.e., as interest subsidy or a zero percent loan, etc.) to
make the water infrastructure pooled loan financing program that much more financially
attractive for prospective borrowers. Even without equity funding but using the SRF program
structure as a basis (which would be relatively simple and easy to achieve), a state still has the
ability to efficiently structure a market-rate pooled loan program which would be:
•	Highly-rated: based upon the SRF program's strong underwriting standards,
management and monitoring expertise; and
•	Economical: based upon cost savings from the pooling of bond issuance costs.
In addition to providing additional financial assistance to meet the state's funding needs, the
state program can also charge borrower fees (upfront origination and/or on-going service fees)
which can provide a source of revenues to the state to defray its administration costs and/or
provide additional funding for borrower loans.Since SRF programs are well-recognized for their
strong management, underwriting standards and monitoring activities, this new financing
program could also be managed by the state's SRF program using the SRF programs' proven
legal documentation and program policies. This approach should also help achieve high ratings
since the rating agencies generally credit SRF programs with strong management oversight.
However, there may still be challenges associated with this financing recommendation. First,
depending upon state law and administrative rules and policies, a state and/or SRF program may
need statutory authorization to create and administer such a financing program. Second, to
increase the appeal of this program to prospective borrowers, program objectives and
administrative guidelines need to be developed and prioritized and then implemented.
Accordingly, administrative and staffing challenges at the state/SRF program level will need to
be considered and addressed. Specifically, if SRF programs can run these new lending programs,
it would need to be made clear how they would function differently than traditional SRF lending
tools.
C. Linked Deposit Loan Program. The third lending-based financing opportunity is the linked
deposit program. Generally, a "linked deposit loan" program is a financial arrangement where a
municipal entity agrees to invest monies (in instruments such as certificates of deposit) with
participating financial institutions and, in turn, agrees to accept a less-than-market rate of
return (with the interest rate differential being equal to the market rate less the investment
rate). The principal amount of the investment is then loaned to qualified individuals for specified
purposes at a less-than-market rate (i.e., market rate less the interest rate differential) with the
participating financial institution servicing the loan.
This financing approach offers:
•	A lower cost of funds - relative to the homeowners' alternative cost of funds; and,
•	A relatively simple funding structure for the municipal entity since no debt and debt
issuance costs are incurred, if offers administrative ease, and the municipal entity is not
involved with loan servicing. Plus homeowners only have to deal with the participating
financial institutions. Please see the schematic in Exhibit 3 below.
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Exhibit 3 - Linked Deposit Loan Program
Homeowners
Municipal Entity
Participating
Lender/Bank
Less-than-Market
Investment
Return
Less-than-Market
Rate
Linked deposit programs have been used effectively in a number of states and could be applied
to lead mitigation effectively. For example, Iowa offers low-interest loans through participating
lenders to homeowners for the replacement of inadequate or failing septic systems. Linked
deposit is managed through the SRF program by the Iowa Finance Authority (IFA), Iowa's On-site
Wastewater Assistance Program (OSWAP). According to Iowa law, all septic systems, regardless
of when they were installed, must have a secondary wastewater treatment system following the
septic tank. Eligible applicants must own an existing home with a septic system in an area not
served by a public sewer. Approved systems include both a septic tank and secondary treatment
system such as a leach field. All projects are certified and inspected by the local county
sanitarian and approved by the Iowa Department of Natural Resources (IDNR). Loans are made
through linked deposits with participating lenders. Loan amounts start at $2,000 with terms up
to 10 years and a 3% interest rate. The loan can fund 100% of actual costs. One of the benefits
of the linked deposit system is that the borrower can use his/her own lender. The deposit does
not guarantee the loan nor is it collateral for the loan. It is only to reduce the interest rate
charged to the borrower.
To start the financing process, the homeowner works with the county to determine the
appropriate system. The homeowner then contacts his lender for a loan and the lender
originates loans using their normal underwriting criteria and loan documents. After the loan is
approved, the project is constructed. The county sanitarian inspects the completed system and
the IDNR gives final approval. If it is a new lender, a deposit account in the name of IFA is
created. IFA deposits funds equal to the principal amount of the loan at 0% interest into their
deposit account at the participating bank. Annually, IFA withdraws from its deposit account an
amount equal to the principal repayment of the outstanding loan. As a result, the amount in the
deposit account will equal the principal outstanding on the loan. The applications, approvals and
payments are all completed via an online system. All deposits and withdrawals are made
through Automated Clearing House (ACH). Since the program's inception, Iowa has funded
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1,840 loans and deposited almost $15 million with 294 participating lenders.8 Additionally, Iowa
uses the same structure to finance soil conservation and manure management projects.
The Ohio Water Development Authority's Water Pollution Control's Loan Fund Linked Deposit
Program works in a similar manner. In addition to decentralized systems, this program also
funds "agricultural or forestry best management practices" and other non-point source pollution
control projects for individuals, as well as for private entities and governmental agencies. The
maximum loan amount and repayment rate is set according to the participating bank
agreement. For the borrower/homeowner, the interest rate would be the current bank rate for
similar loans less a maximum of 500 basis points or 5%, with maximum maturities of 10 years
and 20 years for private borrowers and public borrowers, respectively, subject to a useful life
limitation. For OWDA, the interest rate would be the US Treasury note/bond yield less 500 basis
points with a 0% interest rate floor.9
D.	Institutional Debt. Institutional (bank) debt can be used to reduce lead exposure. This typically
occurs as part of an investment to address renovation of single and multi-family residential
units. Like the impact funds, there is an underwriting process. However, the underwriting
process is more attuned to smaller projects (single family homes) and the investment rate of
return (interest rate) is typically less than that desired for an impact fund. As part of the
underwriting process for multifamily units, particularly large ones, the bank may well require a
Phase 1 Environmental Assessment10 which will include building health issues. Since the real
estate is collateral for the loan, the bank may well require the owner to address environmental
issues, including lead exposure, as a condition to making the loan. Because institutional debt is
less expensive that other capital (mezzanine financing or equity), an owner is encouraged to
address these issues if possible.
E.	"PACE"/Tax Lien Financing Program. An alternative to utilizing borrower-backed revenue
financing, as in the previous recommendations, is "PACE" (Property Assessed Clean Energy) or
tax lien financing. The major advantage of this approach is that PACE is a proven and highly-
secured financing structure.11 Since 2008, the PACE program has enabled local governments and
municipalities to finance over $3.7 billion in energy efficiency, renewable energy or water
conservation projects on privately owned residential (as well as commercial, agricultural and
industrial) properties12. Generally, the municipality creates the PACE special assessment/tax
district and arranges for funding (e.g., internal funds, municipal bonding and/or third-party
financing, etc.) which is typically fixed rate debt with repayment terms between 5 and 20 years.
An integral feature of the PACE program is that PACE assessments (which are repaid in
installments on the homeowners' property tax bill) are voluntary contractual assessments levied
on properties in order to finance the acquisition and installation of eligible clean energy
improvements (which can also increase homeowners' property values). Furthermore, the PACE
8	See:
http://www.iowasrf.com/program/other_water_quality_programs/onsite_waste_water_assistance_program.cfm
9	See: http://www.owda.org/owda-doc/Program%20lnfo/NotesWPCLFIink%202011Mar.pdf
10	Phase 1 Assessments are typically not part of a residential underwriting process.
11	Important caveat: a general discussion of the PACE program is provided below. However, state and local laws
vary and PACE programs are dependent upon state and local requirements as well as the specific PACE program
structure/details.
12	See: www.pacenation.us/pace-market-data
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assessment has an equal lien status with property taxes but a senior lien status to mortgages
and any other non-tax liens. Furthermore, a PACE assessment constitutes a lien against the
entire property and not just the specific improvement installed and funded from the
assessment. The assessment also remains with the property, irrespective of any intervening
sales, until it is fully paid. Therefore, in the event of a property foreclosure or mortgage default
and unlike most residential mortgages, there is no acceleration of the assessment and the new
home purchaser would generally take over the assessment payments. Please see the schematic
in Exhibit 3 below.
A PACE/tax lien financing program for lead mitigation purposes like the existing PACE program
could provide immediate funding for the upfront costs associated for such work and also
provide flexible repayment terms and conditions (e.g., lower monthly/semi-annual payments,
relatively competitive interest rates, etc.). The municipality benefits since the PACE/tax lien
financing program can assist in reducing the lead mitigation concerns in the community. With
respect to default levels for PACE financings, reports have varied with respect to the default
risks but generally appear in line with property tax default levels.13 Also in a default, only the
accrued but unpaid portion of the PACE loan is at risk. Unlike the general PACE financing
program, the homeowner may not realize the same type of property value increases as a result
of a PACE/tax-lien financing program for lead mitigation.
To be clear, there are opponents to the PACE financing program. The Federal Housing Finance
Agency, which regulates Fannie Mae and Freddie MAC, two large insurers in the mortgage
market, as well as the Mortgage Bankers Association have voiced their concerns that because of
the higher lien status for PACE assessments (relative to mortgages), there would be less money
to pay them back in a foreclosure.14
Another potential barrier to expanding PACE to lead abatement is that Fannie Mae and Freddie
Mac do not currently provide financing for properties with existing PACE assessments, which
may negatively affect residents with respect to any future refinancing. Furthermore, on April 5,
2017, S.838 - also known as the PACE Act of 2017 - was introduced in the United States Senate
that if passed would define PACE assessments as a mortgage loan and subject the assessment to
the Truth in Lending Act rules and municipalities and contractors to additional requirements.15
As a result, there may be compliance concerns with implementing the current PACE-type
financing program.
13	See: http://aceee.org/blog/2017/03/what-wall-street-iournal-got-wrong and "Energy-Saving Loans are Turning
Bad," The Wall Street Journal, August, 16, 2017
14	See: https://www.mba.org/servicing-newslink/2017/january/servicing-newslink-tuesday-l-17-17/mbanow-mba-
expresses-concern s-on-pace-loans).
15	See: https://www.congress.gov/bill/115th-congress/senate-bill/838)
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Exhibit 4 - "PACE"/TAX LIEN FINANCING PROGRAM
Loan Repayments
Property Assessment Installments/Payments'2'
Homeowners
Municipality
External Funding'11
Bondholders
Other Third Party
Entities
(1)	If internal funds are not available
(2)	Voluntary contractual assessments on same lien as property taxes
Finally, states governments may need to create the necessary legislation for such a program and
provide the authority for the municipalities to create a special assessment/tax district. In turn
municipalities would then pass needed ordinances to create the assessment zones as well as
establish the creation of the lien and project funding options. To assist states and municipalities
in establishing a PACE program, the Department of Energy on November 18, 2016 released
"Best Practice Guidelines for Residential PACE Financing Programs".16 There is always a risk that
new legislation may change the PACE financing landscape going forward.
F. Point-Of-Sale Funding. One relatively common financing approach for addressing property
improvements such as those associated with lead abatement is through point of sale financing.
In fact, it is not unusual for property improvements to be funded as part of the transfer of
property ownership, typically by the current owner/seller, although a portion of the
improvement cost is sometimes covered by the new owner/buyer. This is typically accomplished
via 1) pre-closing completion of the improvements, 2) establishing a reserve or escrow account
to fund the improvements or 3) a combination of 1) and 2). The need for the required
improvement can be triggered by governmental code requirements, mortgage providers, and
real estate transfer practice or buyer demand. In each of these cases the need for a specific
improvement is often identified via a property inspection, sometimes by a government
employee or agent or a certified individual.
In the environmental/public health/utility services area such circumstances have occurred
regarding radon mitigation and malfunctioning septic systems connection to public water/sewer
systems, among others. Applying this approach in connection with lead mitigation would help to
diminish property owner resistance to removing lead within private property because funds
16 See: https://www.energy.gov/eere/slsc/downloads/updated-guidelines-residential-pace-financing-programs
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would be available from the sale proceeds, eliminating the need to incur debt or tap other
assets.
Although a process including inspections, funding and ultimately completion of improvements
could be imposed by state or local governments under their public health powers, there may be
an opportunity to establish such a process in connection with the standard practices of the real
estate market. In some cases, real estate brokers and mortgage providers have been the
primary entities to monitor and enforce sale requirements for improvements and/or
establishing reserves for such improvements. Accordingly, an effort to communicate with and
educate the real estate and mortgage professionals about lead hazards and the potential for
mitigation could lead to increased lead mitigation as properties are sold. There apparently is
already some activity of this nature in connection with lead-based paint removal. To be clear,
this type of financing option is applicable only to point-of-sale transactions and therefore would
not address those properties that are not in the market. That being said, this is a common
financing process that could be very effective for mitigating lead issues, assuming appropriate
regulatory and educational efforts are in place.
G.	Impact or Green or Environmental Social Governmental (collectively, "ESG") Investment. ESG
Funds have become more popular over the past decade and this is a developing financial sector.
The objective is to obtain a financial return and at the same time achieve specific ESG objectives.
These funds can work well for large projects and are underwritten to a specific financial
outcome. In the case of a large project, the investment analysis and investment decision
benefits from: 1) a strong likelihood of repayment (typical sponsors would be governmental or
large corporations); 2) a credit worthy borrower; 3) potential collateral; and 4) a single
underwriting event.
However, currently these funds are not well-suited for reducing lead exposure in private
residences and rental buildings. Because of the relatively small size and wide diversity of
borrowers, there will be multiple and potentially expensive underwriting. Similar to the
individual loans that were responsible for the housing crisis, there would need to be a way to
bundle a large dollar amount of individual loans together in order to create enough scale to
make green bonds work. Since lead exposure generally affects lower socio-economic
circumstances there is a greater likelihood of credit issues. For the same reason, it will be
difficult to obtain collateral, particularly where any such security will be subordinate to existing
first position financing. The investment incentive for the fund is minimized because funding
must be at rates that are below other alternatives. Despite these challenges, lead mitigation and
remediation offers the virtual guarantee of large avoided social costs (unnecessary health issues,
premature death, costs of crime and incarceration) that should be appealing to an ESG investor
if the financial and credit issues can be appropriately addressed.
H.	Tax Credits. Several States such as Colorado, Massachusetts, and Missouri offer tax credits to
encourage owners to address brownfield issues. Senator Schumer has introduced federal
legislation consistent with this concept. Massachusetts and Rhode Island already have tax credit
programs, but the amounts of credit are generally low ($1,500 in MA). By analogy, this could be
used to encourage owners to address reducing lead exposure. The amount of the tax credit
varies by state, from 50% (CO, MA) to 100% (MO). There are restrictions on eligible costs and
who can apply (typically, the polluter cannot take advantage of the credit). Finally states like
Massachusetts and Colorado allow transfer of the tax credits to other taxpayers. This allows the
owner to monetize the total amount of the tax credit more quickly. From an owner perspective
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tax credits do not ease any cash flow issue. The tax credits are beneficial because they are a
direct offset against some or all of the costs. Finally, the tax credits are established strictly to
encourage addressing a public problem. As a result, there is essentially no underwriting
process. An owner either qualifies for the tax credit or not.
I. Infrastructure Trusts. Infrastructure trusts are often discussed as a way to fund America's
crumbling infrastructure. But existing and proposed infrastructure trusts can take many forms
and structures and fund many different things. Whether an infrastructure trust would be a
vehicle for financing lead abatement depends on its scope of work, its capitalization, the
payback structure, and how it defines infrastructure.
Some have a defined geographic scope. For example: Continental or Regional (European
Investment Bank), National (India's Infrastructure Investment Trust), state/multi-state (New
York Works, West Coast Infrastructure Exchange-proposed) or city (Chicago Investment Trust).
Other infrastructure trusts are topical and fund only one type of infrastructure. For example, the
National Highway Trust Fund supports only transportation related infrastructure. Other funds
focus on energy or water. Another distinction in the scope of infrastructure trusts is whether
they fund brownfield (renovation of current assets) or greenfield (creation of new assets)
projects or both. A trust that would cover lead abatement would have to have brownfield assets
in its scope.
Capitalization. Some infrastructure trusts are an evolution of the concept of a public-
private partnership (P3) expanded to include multiple sources of private capital by creating a
fund. These funds offer a wider pool of investors, liquid shares, and various tax advantages
than a P3. Typically, they leverage public and private capital to generate more investment.
Some leveraged funds seek capital on a project-by-project basis while others capitalize the
entire fund portfolio.
Other infrastructure trusts are private investment vehicles that place their capital in specific
projects with limited risk and good returns. For example, recent IRS private letter rulings
seem to open the door for REITs to make infrastructure investments in addition to their
traditional focus on real estate investments.
Payback. Payback can come from a stream of revenue generated by a project itself (e.g. the
cost savings from energy efficiency), a revenue stream related to a project (e.g. the Highway
Trust Fund is capitalized with funds generated by the gas tax), or a source of capital that has
no relation to the infrastructure projects it funds. For example, the America Infrastructure
Fund (HR 1669) currently proposed in Congress is capitalized by selling bonds to private
companies. In exchange for purchasing these bonds, the companies will be able to bring
back a portion of their overseas earnings, one-time, tax free. The bill has secured some
bipartisan support in Congress.
Definition of Infrastructure. The definition of infrastructure funded by an infrastructure
trust varies from trust to trust and would partially determine whether a particular trust
would be a potential source of funding for lead abatement activities focused on lead
drinking water pipes or peeling paint and paint dust in older homes. For example, the
proposed American Infrastructure Fund defines infrastructure as transportation, energy,
communications, water and education. This would probably cover drinking water pipe
replacement and might cover some paint related hazards, such as window replacement, as
an efficiency measure under the energy focus. But other peeling paint hazards might not be
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included. A trust that included environmental improvements could provide more flexible
and comprehensive funding.
The Chicago Infrastructure Trust (CIT) defines infrastructure as: "the basic physical and
organizational structures needed for the operation of a society or enterprise". It further
divides this into "hard" and "soft" infrastructure. Soft infrastructure is the "underlying
organization that supports the quality of our daily lives, including government, economic
development, social structure, culture, sports and recreation". Hard infrastructure
"represents the underlying physical systems that support our economy, such as air, surface
and water transportation, energy, water management, communications and the
environment". The CIT addresses both the hard and soft infrastructure opportunities. This
definition would seem to include all facets of lead abatement. In conclusion, infrastructure
trusts are a potential vehicle for funding lead abatement. Depending on the structure, a
trust might fund specific components of lead abatement or it could be designed to provide
comprehensive lead abatement funding, including both paint and drinking water related
hazards.
Part Six: The Opportunity for Achieving Financing and Implementation Scale
Finally, we address the opportunity and potential benefits for linking multiple financing and
infrastructure programs and processes to achieve lead abatement and mitigation at scale. To do so, we
demonstrate the link between lead abatement and the infrastructure financing challenge of our time:
community resilience. Specifically, the challenges associated with mitigating lead pollution in America's
urban areas are representative of the country's broader infrastructure financing issues. The need for
investment in our nation's civic infrastructure - especially infrastructure that will make communities
more resilient to climate impacts and other environmental shocks - is significant and widespread. This
challenge is particularly daunting for cities that are already economically disadvantaged and/or
vulnerable to adverse climate impacts and other natural hazards.
However, the need to repair or replace deteriorating infrastructure - water and wastewater systems,
transportation networks, hospitals and schools, housing - presents an opportunity to upgrade these
assets in a way that makes communities more economically, socially, and environmentally resilient.
Likewise, investment in housing and water infrastructure upgrades can be leveraged to simultaneously
advance lead abatement goals, particularly since lead pollution tends to be higher in urban areas that
also have some of the greatest need for infrastructure investment. By integrating lead remediation into
broader infrastructure investment programs, governments at all levels can enhance the scale and
efficiency of lead abatement financing.
A. Opportunities to Link Lead Abatement and Resilience and Broad Scale Infrastructure
Investment. Resilience is the capacity of an entity - individual, community, organization, or
natural system - to prepare for disruptions, to recover from shocks and stresses, and to
adapt and grow from a disruptive experience.17 As communities around the country are
coming to recognize, building local resilience to natural and economic shocks requires
comprehensive, integrated planning and financing approaches that build the adaptive
capacity of these interrelated systems. Such an integrated approach seeks opportunities to
simultaneously achieve infrastructure and other community goals across multiple sectors,
including transportation, housing, water and wastewater infrastructure, green
17 Judith Rodin. 2014. The Resilience Dividend: Being Strong in a World Where Things Go Wrong. Public Affairs.
23

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infrastructure, energy, and data management. Lead abatement can be effectively and
efficiently embedded into these planning and financing efforts, via two main opportunities:
co-financing; and, integrated planning and staging.
B. Co-financing: Linking Lead Mitigation to Energy Efficiency and Human Health Programs.
Making communities more resilient, especially to the systemic and acute impacts of climate
change, will require investment in myriad infrastructure systems, including water
management (e.g. sea level rise, tidal flooding, storm water management, wastewater
management, and drinking water), transportation, energy, data and information access, and
housing and the built environment. In many cases, investments in these areas will have the
secondary benefit of achieving lead reduction goals, for example when aging drinking water
infrastructure is upgraded with lead-free pipes. A particularly promising co-financing
opportunity is in the area of housing retrofits and upgrades. A sufficient, sustainable, and
affordable supply of housing is necessary for any community to be considered resilient. Yet
affordable housing is in vanishingly short supply in many urban areas, where housing costs
are rising and only a quarter of families in need of affordable housing receiving assistance.
Low-income families are more prone to inhabit older housing, which puts them at greater
risk for lead exposure.
Retrofitting older residential buildings is essential for safeguarding human health. Because
lead paint is predominantly found on windows and doors, these should be targeted for
limited remediation dollars. Coincidentally, replacing old windows and doors is also one of
the more effective ways to improve residential energy efficiency. This means that property
owners may be able to finance such upgrades by taking advantage of the various energy
efficiency tax credits and financing programs that are available across the country (such as
the federal residential energy efficient property tax credit and various state-based
programs, including PACE, which offers long-term private financing for energy efficiently
upgrades to residential and commercial buildings.)
In addition to leveraging energy efficiency financing to achieve lead abatement goals, there
may be opportunities for further financing innovations. For example, public housing
authorities and other large property owners could use cost savings achieved through energy
efficiency upgrades to invest in additional rehabilitation needs, such as soil amendment
where lead levels are high. Federal and state energy efficiency financing programs might
consider explicitly integrating lead abatement into program requirements, perhaps
awarding bonus points or premiums to projects that achieve both goals.
Another financing opportunity for housing retrofits could lie in the area of health care, given
the clear connections between lead exposure and adverse health outcomes. Lead paint on
antiquated windows and doors is a significant source of legacy lead exposure, and replacing
those windows and doors is the primary mechanism for mitigating the associated health
impacts. In addition, retrofitting windows and doors is one of the most effective
mechanisms for making homes more energy efficient, and there is a well-established
industry associated with providing retrofit services. However, the door and window
replacement costs are often financially prohibitive for many households. However, given the
direct connection between retrofits and improved health, there is a potential linkage
between energy retrofits and healthcare financing, specifically via Medicare and Medicaid.
In other words, there is a very compelling case for enabling subsidized healthcare financing
to cover the costs of energy retrofits for low- to moderate-income homeowners and renters.
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In addition to improving health outcomes, home energy retrofits would have the added
benefit of reducing home heating and cooling costs.
C. Integrated Planning: Achieving Financing Efficiencies through Strategic Project Selection,
Planning, and Staging. Given the critical state of our country's essential infrastructure, lead
abatement often takes a backseat to other pressing infrastructure financing needs at the
local and national level. For this reason, it is prudent and perhaps even essential to embed
lead abatement into broader infrastructure project prioritization, planning and staging
processes.
It has been demonstrated that one of the most powerful ways to reduce infrastructure costs
is to select the right combination of projects and implement them in appropriate stages.18
This may be as straightforward as timing road repairs with needed sewer line upgrades, or
addressing lead contamination when drinking water pipes are due for replacement. While a
seemingly obvious way to achieve efficiencies and reduce costs, for many municipalities this
integrated approach to planning, financing, and staging projects represents a new way of
doing business.
As communities seek to move toward resilience, they will need to invest in an array of
structural, environmental, and social infrastructure projects - and it is precisely this diversity
that presents innovative investment opportunities. Specifically, cities can bundle together
infrastructure investment projects and community assets, creating an investment-ready
portfolio that can then be shopped around to private and public finance entities. These
project portfolios may be designed to advance multiple community priorities and resilience
needs, for example storm surge barriers, green infrastructure networks, food security,
climate-ready transportation infrastructure - and lead remediation. By advancing resilience
infrastructure investment in this holistic way, cities can lay the groundwork for efficient
large-scale capital flow and for long-term economic development.
Part Seven: Conclusion
Lead paint and lead service lines remain a national problem. Although we have made great strides
limiting the exposure to lead, it continues to be a costly problem that continues to impact the health of
millions. Continued education and funding for existing lead mitigation programs should be continued
and remain intact. In addition, the EPA should promote the utilization of the Drinking Water State
Revolving Loan Program, water infrastructure pooled loan (non-SRF) financing, tax lien financing, or a
linked deposit loan program to help address the funding gap for lead mitigation. There are a number of
other financing mechanisms that can be used to address lead concerns, such as institutional debt as well
as tax credits which are currently used successfully by several states to encourage owners to replace
lead based systems. Another opportunity not widely used but shows promise is infrastructure trusts,
such as Chicago's, that can be set up to finance lead abatement if set up properly.
Lastly, lead mitigation should be seen in a broader context of resiliency that helps communities prepare
for recovery from some type of stress or shock. As a growing trend towards integrated planning and
financing for better and stronger infrastructure, there is an opportunity to link lead mitigation efforts to
energy and improved human health programs.
18 McKinsey Global Institute. Infrastructure productivity: How to save $1 trillion a year. 2013.
http://www.mckinsev.com/industries/capital-proiects-and-infrastructure/our-insights/infrastructure-productivitv
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26

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Appendix A - Existing Funding Sources
Funding Resources
Lead Hazard Reduction and/or Infrastructure Investments
Funding Source
Funding Department
and Grant Identifier
Funding Description
FEDERAL GRANTS
Housing and Urban
Development


Office of Lead Control
and Healthy Homes
(OLHCHH)


Lead-Based Paint
Hazard Control (LBPHC)
Grant
The purpose of the LBPHC grant program is to
identify and control lead-based paint hazards in
eligible privately-owned housing for rental or owner-
occupants. The LBPHC program is open to all
jurisdictions, urban, suburban, or rural. There is a
10% grantee match for the LBPHC program.

The Lead Hazard
Reduction (LHRD)
Grant
The LHRD grant is targeted to urban jurisdictions
(either alone or through a consortium) that have at
least 3,500 pre-1940 occupied rental housing units.
There is a match requirement of 25%.

The Healthy Homes
Supplement Funding
The Healthy Homes Supplement funding can be used
to address lead in drinking water, provided the
hazard is identified through the use of the Healthy
Homes Rating System and any associated technical
assessment results. Projects costing $5,000 or
greater require prior Government Technical
Representative review and approval.
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Funding Source
Funding Department
and Grant Identifier
Funding Description
FEDERAL GRANTS
USDA, Rural
Development - Rural
Housing Service (RHS)


Single Family Housing
Repair Loans and
Grants
The Single-Family Housing Repair program, also
known as the Section 504 Home Repair program,
provides loans and grants to very low-income
homeowners in rural areas to repair, improve, or
modernize their dwellings or to remove health and
safety hazards. To obtain a loan, homeowner-
occupants must be unable to obtain affordable
credit elsewhere and have very low incomes,
defined as below 50 percent of the area median
income. Grants are available only to homeowners
who are 62 years old or older and cannot repay a
Section 504 loan. The regulations provide a liberal
interpretation of "owner."

Multi-Family Housing
Direct Loans
This program provides competitive financing for
affordable multi-family rental housing for low-
income, elderly (62 or older), or disabled individuals
and families in eligible rural areas. This program
assists qualified applicants that cannot obtain
commercial credit on terms that will allow them to
charge rents that are affordable to low-income
tenants, the elderly and disabled individuals.
Borrowers must have the legal authority needed to
construct, operate, and maintain the proposed
facilities and the services proposed.

Housing Preservation
& Revitalization
Demonstration Loans
& Grants
This program restructures loans for existing Rural
Rental Housing and Off-Farm Labor Housing projects
to help improve and preserve the availability of safe
affordable rental housing for low income residents.
Eligible applicants are current multi-family housing
project owners with Rural Rental Housing and Off-
Farm Labor Housing loans. Borrowers must continue
to provide affordable rental housing for 20 years or
the remaining term of any USDA loan, whichever is
later.
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Funding Source
Funding Department
and Grant Identifier
Funding Description
FEDERAL GRANTS
Department of Energy


Weatherization
Assistance Program
(WAP)
The WAP does not specifically fund lead hazard
reductions, however, WAP funds weatherization
work including repair and replacement of damaged
windows and doors, which may mitigate lead-based
paint hazards. WAP does not fund individuals
directly. WAP provides funding for states, territories,
and Native American tribes.
FEDERAL GRANTS
Economic Development
Administration (EDA)


Economic
Development
Assistance Program,
Public Works and
Economic Adjustment
Assistance Program
Provides strategic investments on a competitive
merit basis to support economic development,
foster job creation, and attract private investment in
economically distressed areas of the United States.
EDA solicits applications from applicants in order to
provide investments that support construction, non-
construction, technical assistance, and revolving
loan fund projects.
FEDERAL GRANTS
Center for Disease
Control (CDC)


Lead Poisoning
Prevention - Childhood
Lead Poisoning
Prevention
The Centers for Disease Control and Prevention
(CDC) funds cooperative agreements to support
childhood lead poisoning prevention activities
including: blood lead testing, surveillance, and
targeted population-based interventions. This is a
competitive grant that requires awardees to work
closely with other agencies, partners, and other
stakeholders serving children to ensure that a
comprehensive system of referral, follow-up and
evaluation is in place for lead-exposed children. This
program does not fund removal of lead hazards like
lead-based paints or lead containing pipes.
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Funding Source
Funding Department
and Grant Identifier
Funding Description
STATE
GOVERNMENT
GRANTS
State Administered,
Indian Tribes, and
Alaska Native Villages


Community
Development Block
Grants (CDBG)
Under the State CDBG Program, states award grants
to smaller units of general local government that
develop and preserve decent affordable housing, to
provide services to the most vulnerable in our
communities, and to create and retain jobs. 49
States and Puerto Rico participate in the State CDBG
Program. HUD continues to administer the program
for the non-entitled counties in the State of Hawaii.
HUD distributes funds to each State based on a
statutory formula which considers population,
poverty, incidence of overcrowded housing, and age
of housing. HUD does not provide CDBG assistance
directly to individuals, businesses, nonprofit
organizations, or other non-governmental entities.

Arizona
Arizona
Department of
Housing (ADOH)
ADOH administers CDBG and HOME funding for
programs through units of local government and
non-profit agencies that provide rehabilitation to
certain property types owned and occupied as the
primary residence of low-income homeowners.

Maryland
Maryland
Department of
Housing and
Community
Development -
Lead Hazard
Reduction Grant
and Loan Program
The Maryland Department of Housing and
Community Development provides funds to assist
homeowners and landlords lessen the risk of lead
poisoning and preserve the housing stock by
reducing or eliminating lead-based paint hazards.
Applicants must be:
•	A Maryland resident. If an owner-occupant
the dwelling to be repaired must be a
principal residence.
•	Residential rental properties and licensed
residential childcare facilities.
There are no income limits for this program. The
financial assistance provided (grant or loan) will
be based on the applicant's ability to repay.
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Grants are available in certain target areas. This
program funds lead hazard reduction activities
in owner-occupied single-family homes and
rental properties if the units meet the minimum
program requirements.
Funding Source
Funding Dept. and
Grant Identifier
Funding Description
STATE
GOVERNMENT


GRANTS



Massachusetts


Assistance Program
for Lead in School
Drinking Water
This cooperative program helps Massachusetts
public schools voluntarily test for lead and copper in
drinking water. Under this program, the
Massachusetts Department of Environmental
Protection, along with program partners including
the University of Massachusetts Amherst and the
Massachusetts Water Resources Authority, provided
technical assistance and lab analysis to help public
schools sample their taps and water fountains, and
to identify results that show lead and copper
contamination over the action level. The Program
includes an educational component that provided
schools with the information necessary to establish
and implement sampling programs, and to take
remedial actions to address elevated lead and
copper levels. Note that this program does not fund
lead pipe removal.

Michigan


Department of
Health and Human
Services
Grants for lead safety work are available for repairs,
which may include new windows, doors, painting,
special cleaning or plumbing repairs. Owner
occupied housing is eligible for an average of
$10,000 or more. Owners may be asked to pay a
small fee. Landlords may be provided with an
average of $10,000 or more. Landlords will be asked
to contribute a small portion of cost. There is no cost
to tenants, but the landlord's permission is needed
before starting work.

New Hampshire


New Hampshire
Housing
Grants are available for the removal of hazardous
lead paint from homes and apartments where a child
under the age of six resides. The grant particularly
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targets New Hampshire's pre-1978 housing, where
lead-based paint hazards are much more likely to be
found. The grant also targets those who are most in
need, mainly low-income families and properties
with: an "order of Lead Hazard Reduction," or
owner-occupied units referred for an environmental
investigation, or units occupied by a child with
elevated blood lead levels, or units occupied by
children under six years old or pregnant women.
Funding Source
Funding Department
and Grant Identifier
Funding Description
STATE
GOVERNMENT
GRANTS



New York
New York State
Energy Research
and Development
Authority
(NYSERDA),
Assisted Home
Performance
Program with
Energy Star
New York State
Division of Housing and
Community Renewal,
HOME Program
The NYSERDA does not specifically fund lead hazard
reductions, however, they fund weatherization work
which may mitigate lead-based paint hazards.
The Assisted Home Performance with Energy Star
offers two incentives for eligible New York home
owners. The first is a subsidy for up to $4,000 to pay
up to 50% of the total cost of the approved efficiency
improvements in a one family home or $8,000 in
two-to-four unit residential homes with income-
eligible residents. The second incentive offers low
interest rate financing for the balance of the cost of
the efficiency improvements through selected
lenders. In older homes, high levels of lead based
paint can be found in and around the windows. By
removing old windows, you remove a high lead
content from a home but also improve the energy
efficiency with windows that are better sealed.
The program provides funds to acquire, rehabilitate,
or construct housing, or to provide assistance to low-
income home-buyers and renters. Rehabilitation
standards include: soil treatments for lead hazards,
exterior lead hazards, lead-containing components,
interior walls and ceilings, and hazardous materials.
Funds may only be used for residential housing. Any
private for-profit or not-for-profit entity that can
demonstrate the capacity to develop and operate a
qualifying project is eligible to apply for HOME
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project funding. Units of general local government
that have not been designated by HUD as
participating jurisdictions and not-for-profit
corporations that meet certain administrative tests
may also apply as local program administrators.
Jurisdictions which receive HOME program funding
directly from the federal government may not apply
for New York State HOME Program funds. All areas
of the State are eligible.



Funding Source
Funding Department
and Grant Identifier
Funding Description
STATE
GOVERNMENT
GRANTS



Ohio
Ohio Healthy
Homes and Lead
Poisoning
Prevention
Program
The Ohio Department of Health's Ohio Healthy
Homes and Lead Poisoning Prevention Program
(OHHLPP) was awarded more than $2.9 million from
the U.S. Department of Housing and Urban
Development (HUD) to perform lead-hazard control
work on properties housing one or more children
less than six years of age. The grant enables
OHHLPPP to conduct lead hazard control and
healthy homes work in 18 Ohio counties.
Specifically, the funds are used for the identification
of lead hazards in units occupied by children who
have been lead poisoned or are at-risk of becoming
lead poisoned; the remediation of the lead hazards
through appropriate control or abatement
procedures; and, ancillary activities such as training,
outreach, and casework.
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Funding Source
Funding Department
and Grant Identifier
Funding Description
STATE
GOVERNMENT
GRANTS



Wisconsin
Wisconsin
Department of
Administration
HOME Homebuyer
and Rehabilitation
Program
The Department of Administration (DOA) CDBG
Housing Program works with qualifying
homeowners to assess hazards in their homes,
including lead service lines. The 0% interest loan
would cover the costs for addressing all hazards, not
just lead lines. Repayment on the loan is deferred
until the home is sold or no longer the homeowner's
primary residence.
This program was established to provide essential
home purchase assistance and necessary home
rehabilitation, and other vital improvements for
dwelling units occupied by low-and-moderate-
income households. The source of funds is the U.S.
Department of Housing and Urban Development
(HUD) HOME Investment Partnerships Program
(HOME), and the American Dream Down Payment
Initiative (ADDI) program.
The Wisconsin Department of Administration,
Division of Housing awards these funds to local units
of government (village, city, town, or county), the
governing body of a federally-recognized American
Indian tribe or band in the State of Wisconsin and
local housing organizations, a public agency or
nonprofit organization, or faith-based or religious
organizations, as long as the funds are not used to
support inherently religious activities. This program
is on a biennial funding cycle.
UTILITIES
Ordinances


Madison, Wl
Water Utility
Madison's Common Council passed an
ordinance that requires property owners to replace
their side of a water service line if it is a lead pipe.
The penalty for non-compliance was a fine of $50-
$1000 per day. Property owners who refused to
comply with the city's lead service replacement
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ordinance were turned over to the city attorney's
office. Customers who discover a lead service line
can still receive reimbursement for half the cost of
replacement up to $1,500. Customers can also apply
for financing through the city to help pay for the
remainder of the cost.
The Wisconsin's Public Service Commission did not
use rate-payer dollars to fund customer
reimbursements, but the Madison Water Utility was
able to use revenue generated by renting space on
top of water towers to cell phone companies for
their antennas.
During the program, the entire cost to replace the
private-side portion was $1,340 on average. The
average cost to replace the utility side during the
program was $1,997.
REBATES

There are utility rebate programs to promote
installation of renewable energy sources, and energy
efficient measures that can be used to finance lead
remediation and replacement of windows, for
example. Below is a list of two such programs.

Boston, Massachusetts
Boston Water and
Sewer
Commission(BWSC)
Boston property owners are eligible to
participate in the Lead Replacement Incentive
Program if all of the following conditions are
met:
•	The property is served by a two-inch or
smaller water service pipe, which
contains lead.
•	The water and sewer account for the
property is active and not delinquent.
•	The property owner agrees to have the
work done by BWSC, and the work
presents no extraordinary physical
obstacles.
The estimated cost of the private lead water service
replacement will be determined after an initial
review of the property. Eligible property owners may
qualify for a credit of up to $2,000 towards the cost
of the replacement by enrolling in this program.
Property owners will have the ability to pay for the
lead service replacement either in a lump sum
payment or interest-free over a 48-month period as
part of the water and sewer bill.
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Menasha, Wisconsin
Menasha Utilities
Menasha Utilities will provide rebates to property
owners of 50% of the cost to replace the owner's
portion of the lead service up to $1,000. If the
homeowner qualifies for energy assistance based on
family income, Menasha Utilities will give a rebate of
75% of the cost to replace the owner's portion of the
lead service up to $1,500.
PRIVATE SOURCES

No private sources of funding have emerged specific
to lead mitigation programs or efforts. However, in
a general sense, there are two categories of private
funds that could be applied to lead mitigation:
property owner funds or funds available from other
private sources. In the case of the latter, the funding
could be of two types: funding (loans) that need to
be repaid and funding (grants) that is not repaid to
the provider.

Property Owner
Funding
Other Private Funding
This funding would be derived from property owner
savings or investments, but is unlikely to be
affordable to a broad range of water utility
customers, particularly for low and middle-income
owner-occupied property. However, the use of such
funding could be facilitated by combining owner
funds with other private sources discussed below.
Other Private Funding could be available from
investor owned utilities, banks, infrastructure trusts
and philanthropic organizations such asfoundations,
each of which is discussed in more detail in the
section of the report on financing lead abatement. It
is likely that bank and Infrastructure trusts funding
would be provided as loans. Philanthropic sources
would likely provide grants. Investor owned utility
sources could be made available either as grants,
loans or a combination of the two. As in the case of
banks, the interest rate on loans could be set at
below market levels.



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Funding Source
Funding Department
and Grant Identifier
Funding Description
BOND MARKET

States and local governments have the authority to
issue tax-exempt and taxable bonds, including
general obligation bonds, revenue bonds, and
private activity bonds in order to raise funds to
finance specific infrastructure needs. While most
governmental bonds are issued for capital projects
with a public purpose and are backed by the full faith
and credit pledge of the issuer, or backed by a
specific revenue pledge from the issuer, private
activity bonds are issued by or on behalf of a state or
local government as a means of providing special
financing, most often for a private user, and are not
backed by the pledge of the government. Private
activity bonds can be issued by states in conjunction
with the low-income housing tax credits as a
financing source for lead remediation in affordable
housing and historic rehabilitation projects. General
obligation bonds can also be issued by either a state
or local government for development, renovation,
and preservation of affordable housing and any lead
remediation work involved therein and for
replacement of public lead service lines.



LOANS

Although there are some contracting companies
who provide loans for lead removal as part of home
improvement projects, there are better known
public (federal and state) loan sources available as
noted below.

Drinking Water State
Revolving Fund
(DWSRF)
The DWSRF is a financial assistance program to
help water systems and states to achieve the health
protection objectives of the Safe Drinking Water Act.
EPA awards grants to each state for their DWSRF
based upon the results of the most recent Drinking
Water Infrastructure Needs Survey and Assessment.
The states contribute an additional 20% to match
the federal grants. The DWSRF could be used to
finance replacement of public lead service lines, or
used to finance replacement of private lead service
lines in privately owned community water systems
as low-interest loans or principal forgiveness loans.
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Federal Housing
Authority 203k
Refinance Loan
This loan allows current homeowners the
opportunity to rehabilitate and improve their
homes. The FHA 203k Refinance Loan allows owners
to cash out up to $35,000 for the home
improvement project, and the mortgage balance can
exceed the current appraised value of the home.
FHA 203k loans follow the eligibility guidelines of the
standard FHA mortgage. Projects eligible for an FHA
203k Loan include projects for the removal of lead-
based paint, and restoring windows or doors.

Title 1 Insured Loans for
Property
Improvements
and Manufactured
Housing
Loans on single family homes may be used for
alterations, repairs, and for site improvements.
Loans on multifamily structures may be used only for
building alteration and repairs. The property owner
must have a good credit history and the ability to
repay the loan in regular monthly payments. Both
large and small improvements can be financed. A
property owner may apply at any lender (bank,
mortgage company, savings and loan association,
credit union) that is approved to make Title 1 loans.

Mass Housing Get the
Lead Out Loan Program
(Massachusetts)
Get the Lead Out loans are administered by local
rehabilitation agencies. Owner-occupied properties
are eligible for 0% deferred interest loans with no
closing cost, the loan payments are deferred until
sale or refinance of the property, flexible
underwriting guidelines for owner occupant families
of 1-4 in which a child under the age of six resides,
or owner occupants who are court ordered to de-
lead a property (must be child's permanent
residence). Owner-occupants without a child under
the age of six who opt for preventative lead
abatement to increase the livability of their property
must meet standard underwriting guidelines to take
advantage of the 0% deferred rate.
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Massachusetts Water
Resources Authority
(MWRA)
The Local Water System Assistance Program
provides up to $100 million in 10-year zero-interest
loans to communities solely for efforts to fully
replace public lead service lines and private lead
service lines from the community water main all the
way to the home or business. Each community will
develop its own program, tailored to their local
circumstances. Eligible communities must be part of
the MWRA. MWRA has a total of 50 water
communities, of which 45 will be eligibleforfinancial
assistance under the Lead Service Line Replacement
Loan Program.
The interest-free loan will be repaid to the MWRA
over a ten-year period, beginning one year after the
original quarterly funding distribution date.

Wisconsin Department
of Natural Resources
(DNR), Environmental
Loans Private Lead
Service Line (LSL)
Replacement Funding
Program
The Wisconsin DNR established a two-year program
(SFY 2017 and SFY 2018) to assist disadvantaged
municipalities in replacing lead service lines on
private property for projects that result in full LSL
replacements. Municipalities have three years from
the date of their loan closing to expend funds for the
LSL program. Funding for LSL replacement on private
property is in the form of principal forgiveness,
which means no debt is incurred for these funds. The
program is intended to assist individuals in
disadvantaged municipalities since user rates cannot
be used to replace the private portion of the lead
service line.
LOCAL
GOVERNMENT



Phoenix, Arizona
Lead Hazard
Control Program
This program helps homeowners, landlords and
tenants in targeted areas control hazards from lead
in paint, soil and dust. Residents must have a low-to-
moderate income level to qualify for assistance, the
inhabitants must include a child under the age of six
or pregnant resident, and the residence must have
been constructed before 1978. The program is also
a source of information about prevention of
childhood lead poisoning.

Alameda County,
California
Community
Development
Free Lead Paint Repair Grants are available to
owners of pre-1978 residential property in Alameda
County. Some restrictions apply. The funds available
through this program may only be used for lead
hazard control and healthy homes work. Grants are
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Agency, Free Lead
Paint Repair Grants
given for up to $10,000 per unit for lead hazard
repair work.

Colorado Springs, CO
This program allows eligible homeowners located in
the City of Colorado Springs to qualify for a grant or
qualify for a 0% deferred payment loan to make
necessary improvements to their home. The funds
are primarily used to repair/replace substandard or
failing housing conditions and make energy
efficiency improvements. Improvements can include
repairing or replacing a roof, windows, doors, hot
water heater, furnace, flooring, plumbing, electrical
and more. Lead-based paint testing may be
performed on homes built before 1978.
For these loans, monthly payments are NOT
required, interest does not accrue, and the loan does
not need to be paid back until there is a transfer of
title (e.g. home is sold). The loan is immediately due
and payable if the home is sold, ownership is
transferred, the homeowner fails to occupy the
property, or fails to pay property taxes or property
insurance. Loans are secured by a Deed of Trust on
the property.

Chicago, Illinois
New Markets Tax
Credit
The program was designed to reduce childhood lead
poisoning by making more than $12 million available
to replace windows and address other lead hazards
in approximately 2,000 affordable rental units in
apartment buildings in Chicago over two years from
2007 to 2009.
The program combined a $6 million grant from the
City of Chicago Department of Public Health with $6
million private capital raised by Delta
Redevelopment Institute through federal New
Market Tax Credits Program from five lenders and
investors. A total of $12 million was available to
replace windows and remove deteriorating lead
paint in more than 2,000 affordable housing units.
The City funds originated from grants made by the
United States Department of Housing and Urban
Development.
Qualifying landlords were able to borrow the
required funds for approved lead abatement work,
but once half the loan plus interest has been paid
back, the other half would be forgiven. This not only
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removed the lead hazards from paint but also
improved the energy efficiency of their buildings.
The program was available to buildings with four or
more units that offer affordable rents as defined by
HUD. A lead hazard, defined as any chipping or
peeling lead-based paint or lead-based paint on a
friction surface, such as a window, had to be present
in the building. The city inspected the buildings
identified for the program for these hazards.
During the program 10% of the $12 million in public
and private funds allocated to the program were
spent and only 10% of the projected units were
abated. This did not generate enough income to
cover the cost of setting up and administering the
program.

Greensboro North
Carolina
Housing
Rehabilitation
Programs
Rehabilitation loans, both deferred and repayment
loans are available at 3% interest for the actual cost
of rehabilitation, but the cost of repairs cannot
exceed $43,400. Awardees can take up to 20 years
to repay the loan.
All homes constructed prior to 1978 will be tested
for the existence of lead-based paint hazards. Any
home that tests positive for lead-based paint may
have a lead-paint remediation grant approved that
will not exceed $20,000. If the cost to remediate lead
is greaterthan $20,000, the additional cost would be
a part of the rehabilitation loan and must be
approved by the property owner.
Loans for low income households will be made at a
3% interest rate with payment deferred until a
change in owner's status. Moderate income
households may finance rehabilitation costs through
a 3% interest rate amortizing loan for a term of up to
20 years. All loans have a maximum amount of
$60,000. The maximum contract for actual
rehabilitation work cannot exceed $52,173.
RENTAL HOUSING
IMPROVEMENT
PROGRAM

The Rental Housing Improvement Program (RHIP) is
designed to assist owners or purchasers of individual
rental housing properties of seven or less units. The
RHIP provides a deferred payments loan for a
portion of the cost of rehabilitating eligible rental
housing properties.
All homes constructed prior to 1978 will be tested
for the existence of lead-based paint hazards. Any
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home that tests positive for lead-based paint may
have a lead-paint remediation grant approved that
will not exceed $20,000. If the cost to remediate lead
is greaterthan $20,000, the additional cost would be
a part of the rehabilitation loan and must be
approved by the property owner.
All housing units must require a minimum of
$5,000.00 of structural or other code repairs to be
eligible for assistance. All properties must be used
exclusively for rental housing. Single housing
conversions are not eligible. Condominiums,
townhomes and manufactured homes that are held
with a title and not a recorded deed are not eligible
for program assistance.

Dallas, Texas
Home Repair
Program
Eligible residents are located in the Dallas city limits,
are purchasing or have owned their home for at least
two years, have a household income less than the
Applicable Median Family Income limits (80% less for
repairs or reconstruction), pay property taxes and
have current insurance, and have valid deeds.
Repairs include all major systems such as roof,
electrical, plumbing, heating, ventilation and air
conditioning.
•	Major System Repair - deferred loan which
is forgiven a percentage annually as long as
the owner remains in the home.
•	Reconstruction - a no-interest, deferred
payment loan due upon death of borrower
and/or at transfer of ownership. Amount
due is the lesser of lien amount or 75% of
market value as determined by the previous
year's Dallas County Appraisal District
appraisal.




Boulder, Colorado
Low Interest Home
Repair Loan
Homeowners in the City of Boulderthat need repairs
can receive low-interest loans for health and safety
repairs and energy conservation measures of up to
$25,000 for single family homes. Repayment of the
loan is deferred for 15 years or until the awardee
sells their home, whichever comes first.
To qualify for home repair loans, the applicant must
own and occupy the home, it must be the primary
residence, and the applicant must live in the home
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for one year. The home must be located in the City
of Boulder. The applicant must demonstrate a
financial need. Applicant assets cannot exceed
$50,000 (excluding the value of the home). Some
retirement assets are exempt. The amount of
interest you are charged is based on your annual
income.

New York City
Department of
Housing
Preservation and
Development
(HPD)
Primary Prevention
Program
This Program gives owners the means to make their
buildings lead-safe through low-level interim
treatment work. Treatment concentrates on friction
surfaces - door jams, window sills and wells, and
cabinets. The common areas and fire escapes are
also treated. Buildings owners apply for forgivable
loans valued at $9,000 to $10,000 per apartment,
the average cost of lead treatment work. Some units
may receive up to $10,000 to $11,000 in conjunction
with other moderate rehabilitation work. Owners, in
turn, hire contractors who are trained in EPA
certified courses in lead treatment and HPD inspects
the work.

Washington DC
Single Family
Residential
Rehabilitation
Program (SFRRP)
Single Family Residential Rehabilitation Program
(SFRRP) administers loans and/or grants for minor
home repairs that address building code violations,
repair roofs, remove threats to health and safety,
and modify and/or eliminate barriers to accessibility
for persons with mobility or other physical
impairments.
Under the SFRRP Program loans and grants, not to
exceed a total of $75,000, per household are
available. The household identifies its own licensed
and certified contractors to carry out the work
subject to development of an initial scope of work
and approval of the contractor's bid.
The program provides financing through low or 0%
amortized loans for up to 20 years and deferred
loans (not payable until the home is sold, transferred
or refinanced). Eligible applicants must own and live
in their homes as their primary residence for at least
three years, be current on all District and federal
taxes, have an acceptable credit report and payment
history, have current homeowner's insurance, and
have household incomes that are no greater than
the levels set by the program.
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TAX CREDITS



Federal Tax Credits
While no federal tax credits (Tax Credits) (other than
the New Market Tax Credits) were identified as an
existing funding source, tax credits have been used
within the federal and state tax structure to
incentivize certain investments by individuals,
businesses and investors.
Tax credits directly offset the taxes payable by a
qualifying entity, rather than reducing the taxable
income, thereby allowing the entity to reduce the
cost of the qualifying investment and recover the
investment cost more quickly than otherwise
possible under the tax code. Tax credits can be
structured in two ways: 1) nonrefundable credits
which are limited to the total taxes payable in the
year of the tax credit's related expenditure and 2)
refundable credits which are credited against
current taxes with any residual tax credits paid to the
taxpayer in addition to the full refund of any tax
deductions and estimated tax payments. The latter
is important when promoting investments by lower
income individuals such as those that are often
concentrated in older urban areas where lead
exposure is more prevalent.
Tax credits can be made available to individuals,
businesses or investors. In the case of individuals,
improvements such as lead line removal (potentially
in conjunction with water utility efforts), lead paint
removal or containment, point of use treatment
systems, plumbing fixture replacements, among
others could be financed by the property owner,
whether owner occupied or rented. Similarly,
businesses could make such investments for
property it owns, whether owner occupied or
rented. It such cases the most obvious approach
would be a tax credit offsetting the individual or
business taxes. Recognizing the concentration of
lead exposure in older urban areas, which also
typically see a concentration of poverty and lower
income levels, the tax credit should be refundable to
enhance the incentive for mitigation.
With regard to investors, the primary tool would be
tax credit bonds (TCBs). That approach involves
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either loans to or the purchase of publicly issued
bonds from utilities for the sole purpose of lead
mitigation. The banks and other financial
institutions, as well as individual investors, would
receive a tax credit to offset some or all of the
taxable interest on the loans or TCBs and
consequently accept lower interest rates on such
loans or bonds, akin to tax exempt rates, making the
lead mitigation efforts by a utility more economical
and affordable. Alternatively, the tax credit could be
paid to the utility as a direct offset to the taxable
interest paid to the lender or bondholder, like the
Build America Bonds (BABs) issued in 2009-10. It is
also possible that a local bank or other financial
institution could be incentivized by a tax credit to
provide loans to homeowners and businesses in its
service/market area for lead mitigation expenses,
thereby driving down the multiyear impact to the
borrower.
The following appear to be potential barriers to the
implementation of a tax credit program: tax credits
will require Congressional approval which will raise
budget and deficit considerations, the impact of the
Federal Budget sequester has soured the
attractiveness of BABs to the issuer (public)
community, and while there has been much
discussion about Public-Private Partnerships (P3s)
for infrastructure investments, lead mitigation
programs do not appear to be conducive to design-
build-own-operate structures which are one of the
bases for P3s.
STATE TAX CREDITS



Massachusetts
Department of
Revenue
Property owners who receive a Letter of Full
Compliance are eligible for a State Tax Credit equal
to the cost of the de-leading expenses, or $1,500,
whichever is less. To qualify as full compliance de-
leading for purposes of claiming the de-leading
credit, all of the following requirements must be
met: a dangerous level of lead in the accessible
structural materials of the residential premises is
established by a licensed inspector, following de-
leading by an authorized person the owner obtains a
letter of compliance from a licensed inspector, and
the owner completes Massachusetts Schedule LP
and encloses it with the tax return
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Property owners who receive a Letter of Interim
Control are eligible for a State Tax Credit of up to
$500. This $500 amount applies toward the $1,500
limit. To qualify as interim control for the purpose
of claiming the de-leading credit, all of the following
requirements must be met: 1) a dangerous level of
lead in the accessible structural materials of the
residential premises is established by a licensed risk
assessor, 2) the premises are de-leaded using
interim control measures performed by an
authorized person, and the owner obtains a letter of
interim control from a licensed risk assessor which
certifies that the costs of instituting interim control
measures are costs necessary to achieving full
compliance, and 3) the owner completes
Massachusetts Schedule LP and encloses it with the
return. The owner should also retain the letter of
interim control.
Only "residential premises" qualify forthe Lead Paint
Tax credit, including single-family homes, individual
units in an apartment building, condominium units
(common areas and individual units), or individual
units in multi-family homes. Owners are entitled to
claim a Lead Paint Tax Credit in the taxable year in
which compliance is certified or in the year in which
the payment for the de-leading occurs, whichever is
later. Nonresidents and part-year residents qualify
for this credit only if the property is residential and
located in Massachusetts. This property does not
need to be a principal residence located in
Massachusetts.

Rhode Island
Division of
Taxation
An individual is entitled to a credit against his or her
Rhode Island personal income tax liability for
residential lead removal or lead hazard reduction if
he or she: obtains a housing resources commission
regulated certificate of conformance for mitigation,
or obtains a department of health regulated lead
safe certificate.
The tax credit is equal to the amount actually paid
for the required lead removal or lead hazard
reduction up to a maximum of $1,500 per dwelling
unit for mitigation and up to $5,000 for abatement.
Each Claimant may only claim relief for mitigation or
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abatement efforts for three separate dwelling units.
A "dwelling unit" means a single unit providing
complete independent living facilities for one or
more persons, including permanent provisions for
living, sleeping, eating, cooking, and sanitation.
Credit distributions will be provided first to
claimants with a household income of $35,200 or
less during the year for which the claim was filed.
The household income amount will be increased July
1st of each year by a percentage equal to the cost of
living adjustment provided for social security
recipients. Secondly, distributions will be provided
to claimants who rent or lease dwelling units to
individuals whose household income was $35,200 or
less during the year for which the claim was filed.
The household income amount will be increased July
1st of each year by a percentage equal to the cost of
living adjustment provided for social security
recipients. All other claims will be paid once all
applicants listed above have been paid.
INFRASTRUCTURE
TRUST



Chicago, Illinois
Infrastructure
Trust
The Chicago Infrastructure Trust was created in April
2012 by executive order of Mayor Emanuel and City
Council resolution. The Trust's purpose is to assist
the people of the City of Chicago, the City
government and its sister agencies in providing
alternative financing and project delivery options for
transformative infrastructure projects. The Trust
provides focus and leadership to maintain a pipeline
of executable projects that will meet Chicago's
infrastructure needs and attract private
investment. The Trust could be used to finance lead
remediation projects.
The Chicago Infrastructure Trust pursues projects
that leverage private sector resources through
alternate financing and procurement methodologies
such as joint ventures, private equity, public private
partnership (P3) investments, and state, federal and
private grants. The benefit of alternate financing
and procurement methodologies is that they enable
Chicago to address infrastructure needs beyond the
capacity of public funding sources.

New Jersey
NJEIT is a partnership between the New Jersey
Environmental Infrastructure Trust (NJEIT) and the
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Environmental
Infrastructure
Financing Program
(NJEIFP)
New Jersey Department of Environmental
Protection (DEP). NJEIFP eligibility consists of two
components:
•	The project sponsor must (a) be either a
local government unit or hold a permit
to operate a public water system and (b)
satisfy the program's credit worthiness
requirements.
•	The project must (a) be a clean water or
drinking water project as set forth in the
Program Funding Tab above and (b)
satisfy NJEIFP program requirements.
Short-term loan interest rates are 0% for terms up to
three fiscal years. Long-term loan interest rates vary
but the majority is equal to 25% of the market rate.
The effective interest rate for a majority of long-
term loans issued in May of 2016 was 0.59% for
terms of up to 30 years.
Eligibility applies to projects that address federal
safe drinking water health standards. This includes
replacement, source development and
rehabilitation, treatment to comply with primary/
secondary drinking water standards, storage to
prevent contamination from entering the water
system and transmission lines/distribution systems
to prevent contamination or to improve pressure to
safe levels.
Philanthropic
Organizations/NGOs



Rebuild Together
Rebuild Together has a network of local affiliates
that provide free home repairs to low income home
owners, which can include removal of lead-based
paint as part of the repairs. Each local affiliate has
its own eligibility requirements and application
process.
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Many sources of funding are not specifically targeted
to lead hazard reductions but fund activities that can
reduce exposure to lead (e.g. window replacements
performed under a grant targeted at energy
efficiency may reduce exposure to lead by removing
deteriorating paint on window frames). The sources
of funding are diverse, covering loans, grants, tax
credits, etc. on the federal, state, and local
government levels. Majority of the funding sources
are specifically for low-income home owners. There
appears to be fewer funding sources for public
spaces such as schools and hospitals.



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Appendix B: Summary of Financing Alternatives Based Upon a Number of the
Criteria for Both Providers of Capital and the Borrowers/Owners
Criteria
Environmental
Impact Funds
Revolving
Loan
Funds
HUD/Related
Financing
Institutional
Debt
Tax Credits
Sponsor/Borrower
Criteria





Low Cost of Capital

X
X

X
Eases Cash Flow

X
X
X

Ease of Application

X
X
X
X
Increases Value


X
X

Collateral Required


X
X

Delay Associated
with Program

X
X


Program/Lender
Criteria





Existing Program
for Lead Exposure
Reduction

X
X
X

Existing Concept
for Lead Exposure
Reduction
X



X
Financial
Underwriting
X
X
X
X

Creditor
Underwriting
X
X
X
X

Collateral
Underwriting
X

X
X

Available to Small
Users

X

X
X
Investment
Expectation
(L/M/H)
H
L
L
M
L
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Appendix C: Significant Case Studies
New England
New England states have some of the oldest housing in the United States. Over one-third of New
England housing was built before 1950, and this is where deteriorating lead-based paint is most likely to
exist (Source: U.S. Census Bureau, 2010-2014 American Community Survey 5-Year Estimates).
City/State: Massachusetts
Issue: Lead Paint Law
Background: Massachusetts has one of the strictest lead paint laws in the United States. Under the
Massachusetts Lead Paint Law, buyers of property are entitled to have the property inspected, and the
law imposes a mandatory obligation to de-lead if there is a child under six- years-old residing in the
rental premises. A property owner or real estate agent cannot get around the law simply by refusing to
rent to families with young children. They cannot refuse to renew a lease to a pregnant woman or a
family with young children just because a property may contain lead hazards. This would be a violation
of the Lead Law, resulting in serious penalties.
Financing/Funding Approach: There are several programs that offer financial assistance for de-leading
such as a lead paint removal tax credit to those property owners who receive a Letter of Full Compliance
that is equal to the cost of de-leading expenses or $1,500, whichever is less. Only residential premises
qualify for this tax credit. Massachusetts also offers a program called "Get the Lead Out" that provides
low cost financing to owners of 1-4 family properties to remove lead paint. For owner occupants who
meet the income guidelines, they can receive a 0% deferred payment loan not due until the sale,
transfer or refinancing of the property. Non-profits are eligible for 0% fully amortized loans for
properties being rented to income eligible households. Investor owners are eligible for 3% fully
amortizing loans on properties that are being rented to income eligible households.
Also available is a Home Improvement Loan Program (HILP) that offers low interest loans to de-lead
owner occupied family homes and residential condominiums that have been the borrower's principal
residence for a minimum of one year. The loans range from a minimum of $5,000 to a maximum of
$25,000 per home for a loan term of 5-15 years.
Effectiveness: The effectiveness of this program was not available for this report.
Concerns or Barriers: Only a small percentage of homes built prior to 1978 have been inspected and/or
de-leaded. Although the mandate calls for stripping dangerous levels of lead from houses with young
children, residences that have been deemed lead-safe do not stay that way forever.
Case Study Takeaway: Even though Massachusetts is considered to be one of the strictest states when
it comes to lead paint and best financing for de-leading, there are still several cities, including Boston,
that still struggle with high incidences of lead poisoning.
Program Links:
https://www.masshousing.com/portal/server.pt/communitv/home owner loans/228/get the lead ou
t
City/State: Rhode Island
Issue: Lead Paint
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Background: The Ocean State is home to many historic and older homes, with about 70% of housing
stock built before 1978. Rhode Island is unique for taking a daring step in 2006 by suing the paint
industry to seek money for lead paint mitigation. At one point, Providence, Rhode Island was even
dubbed the lead paint capital of the United States. It was a landmark case lawsuit that was later
overturned, citing that the paint industry could not be held responsible. In 1999, when Rhode Island first
sued, more than 2,300 children under six-years-old were found to have dangerously elevated levels of
lead. By 2014, the number dropped to 217, or just less than 1 percent of all children tested statewide.
But this is still 40% above the national rate.
Financing/Funding Approach: The LeadSafe Homes Program provides forgivable loans to mitigate the
hazards of lead-based paint. It is available to homeowners and landlords at no cost to qualifying
customers. Funding is forgiven after five years for homeowners and after ten years for rental investment
properties. The program started by a competitive grant given to Rhode Island Housing by the US
Department of Housing and Urban Development (HUD) since 1998. This grant is very precise about how
the program should be run, and also requires a 10% match from Rhode Island State.
Effectiveness: This is a very popular and well managed program. It has been very effective in mitigation
efforts and uses the payback to ensure there is money to continue the program if federal funding
becomes reduced or eliminated.
Concerns or Barriers: To manage the LeadSafe program, Rhode Island relies on federal funds. Although
the program is well organized and effectively managed, the loss of federal grant funding will significantly
impact the program and will require them to utilize only the funds available from loans being paid back.
Rhode Island was hard hit by the economic crisis of 2009 and lost much of the anticipated loan
repayment due to many short sales on the housing stock, so not as much is available as originally
anticipated. Without federal funding, this program will be forced to change the program requirements
to possibly those with elevated lead poisoning tests or severely restrict eligibility.
Case Study Takeaway: This program is noteworthy because of the partners involved in providing the
effective education and outreach efforts that are part of the program. Although they run their program
with federal funds, they are unique in offering a loan program to put money back into the program
instead of issuing a grant like many other states do with their HUD funding.
Program Links: http://loans.rhodeislandhousing.org/LeadSafe Homes/
Northeastern Region
City/State: Cincinnati, Ohio
Issue: Replacing lead service lines in the City of Cincinnati to prevent drinking water contamination.
Background: Although the City of Cincinnati stopped installing lead service lines in 1927, approximately
15,000 lead service lines remain on the public side and as many as 27,000 may remain on the private
side. GCWW has been removing lead service lines from the water system since 1971 through a partial
lead service line removal program in association with its water main capital improvement program.
Since this program only removes the public portion of the lead service line, GCWW has encouraged
customers to remove the private portion of the line. However, the cost to remove the private portion of
the line (averaging $3,000 per line), City's Municipal Code limitations to ownership, and affordability
have been the biggest obstacles to private line removal and improved drinking water quality.
In response to recent research documenting the health risks of partial lead service line removal, GCWW
provides filter pitcher kits to customers impacted by public lead service line replacement due to a water
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main replacement or a leaking line. In addition, GCWW created an Enhanced Lead Program in 2016 and
assigned a program manager to unify all initiatives under the Enhanced Lead Program, including water
sampling and testing, communications and outreach, lead service line replacement, records, information
technology, and customer service.
Financing/Funding Approach: GCWW has a long-term goal to replace all publicly owned lead service
lines over time through its Capital Improvement Program and to help establish programs to assist
customers to remove their portion of the service lines within the same timeframe. In 2016, as part of
the Enhanced Lead Program, the City of Cincinnati Council approved GCWW expanding its current
Capital Improvement Program budget to include projects dedicated to removing lead service lines,
rather than just replacing the public portion of the lines when water mains are replaced or service line
leakage is identified.
This accelerated public lead service line replacement program is a 15-year capital improvement program
with $9.7 million estimated to be budgeted annually for this program. In addition, GCWW plans on
incentivizing property owners to voluntarily replace the private portions of their service lines with a
combination of grants and loans. GCWW would either remove the private lead service line with its own
contractor or coordinate with the property owner's contractor who would do the private portion
replacement work. GCWW would also have a list of approved contractors for the property owners to
contact should they perform the work themselves.
To fund the private portions of the lead service lines with grants and loans, GCWW plans to establish a
new fund that will be capitalized from capital-related surplus monies funded from revenues. This fund
will be utilized to provide both grants and loans to customers for this program. Customers will have the
option to fund the non-grant portion on their own. A revolving loan program will be established utilizing
this fund. Property owners will be responsible for repaying their loans into the fund through special
property tax assessments on their tax bills.
Effectiveness: The GCWW private lead service line replacement program is still under development. If
the private lead service replacement funding program is approved later this year by City Council, it will
offer grants and up to ten-year loans to all GCWW customers with lead service lines. GCWW intends to
offer a greater proportion of grant funding to qualifying senior citizens and low-income customers.
Concerns or Barriers: As mentioned above, GCWW intends to capitalize the public portion of the lead
service line replacement. A financial consideration for GCWW is to ensure that it maintains sufficient
liquidity for the utility after the transfer of the capital-related surplus monies to this new fund.
Repayment of special property tax assessments will go back into the revolving loan fund. Another
consideration is the ability of any utility with outstanding debt to transfer monies out of its indenture for
this purpose. Given the criticality of ensuring the provision of safe drinking water to its customers, the
City and GCWW have concluded that this is a lawful public water system purpose.
Program Links:
http://www.cincinnati-oh.aov/water/lead-information/
http://www.cincinnati-oh.aov/water/lead-information/links-and-additional-information/
City/State: New York City
Issue: New York City and its borough's face issues with lead levels in school drinking water, including
lead levels in school drinking water and drinking water in household plumbing that exceed EPA
guidelines.
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Background: Under Mayor de Blasio's administration New York has accomplished remediation removal
of 500 properties throughout Brooklyn, Queens, Manhattan, The Bronx, and Staten Island. These five
boroughs with a land coverage total of 138 acres include 300 underground storage tanks. This
remediation process began in 2014, and is still underway. On Earth Day April 22, 2017, these
accomplishments were shared through media sources.
Financing/Funding Approach: Collaborative efforts were undertaken, Public Private Partnerships
established, with a private investment that represented 8.2 billion in new construction and funding from
the NYC Office of Environmental Remediation for new pre-development grants.
Effectiveness: All work to date has been accomplished 18 months ahead of schedule with a current 75%
completion rate.
Concerns or Barriers: Not Available. Information was not available on concerns with these various
projects and whether they directly addressed lead abatement.
Case Study Takeaway: The New York City Office of Environmental Remediation and NYC Volunteer
Cleanup Program have a collaborative agreement with New York State, which allowed for the cleanup of
577 formerly blighted lots in need of remediation, vacant for over 10 years, and located predominately
in New York City flood zones. The New York Volunteer Cleanup Program as of December 2015 has
enrolled 375 cleanup projects, creating over 10 billion in private investment. The cleanup programs have
thus far created 3,700 permanent jobs and 3,600 affordable housing spaces, creating tax revenue
estimated to be more than $960 million. The recycling of soil is included in the land abatement process.
However, there was no direct mention of lead removal contained in the information.
Summary: The information regarding the New York City and its boroughs clean-up program has many
benefits to the community, including increased access to affordable housing, removal of blight in
communities through the lead cleanups, new job creation and retention, and increased tax revenue for
the City, but does not mention addressing lead abatement specifically.
Unfortunately, there appears to be no successful lead abatement project in the school systems,
especially within the NYC school district system. There are numerous articles on the high levels of lead in
the schools, providing locators to a specific school for review. Reports located do not show cases of lead
abatement being started or accomplished within the school system.
Similar procedures for financing, funding, and collaborative efforts could be developed and
accomplished to address the lead issues within the school system by creating public private partnerships
focused on accomplishing long-term new job creation and sustainability within the various NYC
communities.
Program Links:
http://wwwl.nvc.gov/office-of-the-mavor/news/237-17/onenvc-mavor-environmental-remediation-
500th-propertv-achievement-75-goal
http://www.nyc.gov/html/oer/html/home/home.shtml
http://wwwl.nyc.gov/site/hpd/about/press-releases/2017/04/04-18-17.page
New York City Environmental Resource Page http://wwwl.nyc.gov/nyc-
resources/categories/environment/environmental-protection/index.page
NYC Interactive Capital Projects Dashboard http://www.nyc.gov/html/ops/capital/html/map/map.shtml
https://www.nytimes.com/2016/09/01/nyregion/lead-tests-on-new-york-city-schools-water-may-have-
masked-scope-of-risk,html?_r=0

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http://www.wnyc.org/story/wnyc-map-lead-contamination-water-fountains-nyc-public-schools/
City/State: New Jersey (Trenton and Newark)
Issue: Aging infrastructure leads to higher lead levels that were found in low income housing and some
area schools.
Background: Lead contamination of the drinking water in some New Jersey schools has raised concerns
about New Jersey's aging water infrastructure. State lawmakers are considering forming a task force to
study what improvements the water system needs. The Utility and Transportation Contractors
Association agrees that this study would be extremely valuable to ensure water quality over the long
term. Lead contamination was found in the drinking water supply at dozens of schools in the state's
largest school district, and now federal funding to help remediate lead hazards in low-income
housing are headed to the city. Newark and Trenton are two of 11 cities in New Jersey recently found
to have a high proportion of young children with elevated blood lead levels.
Financing/Funding Approach: Funding for the infrastructure improvements, in part, will be relied
upon by the ratepayers. There is already in place an Environmental Infrastructure Trust that can fund
some of the cost. Trenton and Newark, NJ are to receive millions of dollars in federal funding from the
Department of Housing and Urban Development (HUD) to help combat the lead issue. This funding is
being awarded from the Lead Hazard Reduction Demonstration program. The program granted
Newark $3 million, and the city picked up an additional $400,000 from Healthy Homes Supplemental
funding. Trenton received a little over $2.1 million to assist with the reduction of lead in the homes.
Concerns or Barriers: It is noted that about 25% of the water in urban areas leaks out of old pipes.
There is a concern that the leaking can reduce the flow from taps if there is not enough water in
reservoirs in the summertime to make up for it. Replacing all the old pipes would cost billions. The funds
will only remediate lead hazards in 150 low-income housing units in Newark, and 145 in Trenton.
There are nine more cities that need assistance. Although the issues in the schools are not severe, it
still causes stress on the families concerned about the health of their children.
Case Study Takeaways: Federal funding is critical in enhancing efforts in Newark and Trenton to
reduce lead hazards in public schools, public housing, and making certain the homes are safer for
residents in the area. In the state of New Jersey, children in 11 cities were reported to have higher
blood lead levels than those children in Flint, Michigan, which experts said was in large part caused
by exposure to paint in old homes. The known potential health impacts of lead poisoning can be
devastating to a child, so having an obligation to secure the resources needed to update the aging
housing and infrastructure in these communities is necessary.
Lead was also found in some schools' drinking water. This will prompt several legislation
proposals that would require more testing and provide funding to remediate lead issues. Experts
have sited that the amount of exposure through paint in the home is at a much higher rate than
through the amounts found in some schools' drinking water. There is a lot more to do in terms of
providing the necessary funding to replace lead pipes, not only in the public utility sites but the
private homes and public buildings as well.
Program Links: http://www.newsworks.org/index.php/local/new-iersev/93500-new-iersey-considers-
study-of-aging-water-infrastructure
http://www.nj.com/essex/index.ssf/2016/06/millions_of_federal_dollars_headed_to_newark_trent.ht
ml
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Mid-Atlantic Region
City/State: Pittsburgh, Pennsylvania
Issue: Replacing lead service lines to prevent drinking water contamination.
Background: Pittsburgh exceeded the lead limit for the first time in July 2016. The City's water authority
has nearly $1 billion in debt. Pittsburgh suffers from decades of inadequate maintenance of their
infrastructure, leading to periodic pipes breaking and significant signs of disrepair. Although there is
currently no detectable lead in the water, the Pittsburgh Water and Sewer Authority (PWSA) are
concerned about lead being picked up in corroded service lines that carry water from the mains beneath
the street into residences and from soldered pipe joints and interior plumbing. It is estimated that 25%
of its 80,000 PWSA customers get their water through lead service lines, and the City is unsure of exactly
where many of those lines are located. To prevent an immediate health crisis from occurring, water
filters will be given first to residents whose lines test at or above 10 ppb for lead, and then to other
homes, schools, and community centers while PWSA begins replacing lines.
Financing/Funding Approach: The anticipated total cost to solve the city's problem is in the hundreds
of millions of dollars. A first step in a long-term solution will begin with the "Safe Water Plan" program,
which will spend $1 million to provide free lead filters to every PWSA and Pennsylvania American Water
Co. customer in the city. Peoples Natural Gas has volunteered to pay for half of the initial $1 million
program costs in a joint venture, with the city and PWSA each paying a quarter of the remaining costs.
Along with the free filters, the Urban Redevelopment Authority (URA) of Pittsburgh is looking to
restructure and borrow $1.5 billion to upgrade its water system, and will spend an estimated $411
million over the next ten years to replace the city's lead pipes. URA is also proposing a "Replace Old Lead
Line Program" that will spend $500,000 in loans to low-income property owners at 3% interest to cover
the costs of replacing their lead service lines. The average cost of replacing a service line ranges from
$3,000 to more than $10,000. The PWSA is expected to annually replace an estimated 1,450 lead service
lines it owns and in the public right of way.
Effectiveness: The programs in Pittsburgh are new and are just beginning implementation. If the URA
loan program is approved, it will offer loans up to $10,000 with repayment schedules up to 10 years.
The program would be offered to borrowers with incomes below 120% of the area median income.
Concerns or Barriers: There is some opposition raised about charging low interest instead of no
interest, as the burden would be on low-income families. There are questions about the County health
department data that shows a decline in the percentage of children in Pittsburgh with elevated blood-
lead levels and an audit will be done to confirm that it is not the progress made in cleaning up lead paint
that could potentially be concealing the effects of lead in the water. Criticism of Pittsburgh officials has
been expressed regarding the city's plans to replace only the public portion of the lead service lines as
the disruption can cause more lead to be released from the remaining lead pipes.
Case Study Takeaway: Pittsburgh is trying to be proactive in their approach before the situation
escalates to a major public health crisis. The city has a very expensive problem and is working with
multiple entities to finance a solution. A notable aspect of this case is their efforts have a special
program targeted to helping low-income families pay for the replacement.
Program Links: http://pittsburghpa.gov/safepgh2o/
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City/State: Washington, DC
Issue: Replacing lead service lines in the District of Columbia (the "District") to reduce the ingestion of
lead through drinking water.
Background: In 2003, EPA directed DC Water to replace lead service lines at a rate of 1% per year.
From 2003 to 2007, lead service replacement work was focused in locations/areas with higher
concentrations of these lines. The public portions of all customer lead service lines on entire blocks were
replaced to maximize removal of these lead service lines. In these cases, homeowners were given the
opportunity to replace the private portion of the service line in conjunction with the replacement of the
public portion of the service line. Lead service lines were also replaced in conjunction with emergency
water main and sewer lateral repairs. In these instances, lead service replacements were limited to the
public portion of the service line which ends at the property line.
In 2008, in response to research indicating that partial lead service line replacements are not effective in
reducing lead levels over the short term at the tap, the accelerated replacement program was
discontinued and the approved approach recommended (1) lead service replacements in conjunction
with DC Water's water main replacement/rehabilitation projects, (2) full lead service replacements only
- ahead of DDOT's Paving Schedule, and (3) public-side replacements through customer initiated
requests (customer provides documentation that private-side had been or will be replaced). This
program allows for full lead service replacements at properties where the owner wants to replace their
lead service line but the address is not scheduled to receive service line replacement under any other DC
Water capital improvement project (the "Demand/Voluntary Program").
In 2009, DC Water modified its lead service line replacement policy to encourage full line replacements
and to save costs. Under the modified policy, DC Water agreed to continue to replace the public portion
of the lead service line with copper tubing in conjunction with water main replacement projects, where
the water service must be replaced to connect to the new water main. The Demand/Voluntary Program
was continued. When DC Water performs a lead service line replacement (full or partial), the utility
provides the customer with pitcher filters and cartridges for a six-month period as a precautionary
measure to mitigate initial increased levels of lead, which taper off in a few months. For partial
replacements, DC Water also conducts extensive outreach to encourage flushing and use of filters for six
months after the replacement.
Financing/Funding Approach: Since the inception of the lead line replacement program through
September 30, 2016, DC Water has expended $151.8 million on its lead service line (public portion)
replacement program and currently has $18.5 million budgeted in its Fiscal Year 2017 - 2026 Capital
Improvement Program. DC Water currently estimates that there is approximately $300 million of lead
service line replacement work left to do in the District for just the public portion of the lines.
To encourage full lead service line replacement, DC Water offers homeowners the opportunity to
replace the private portion of the lead service line at a special rate in conjunction with the public portion
replacement. DC Water competitively bids the work and contracts with a company to do the work. The
rates offered by DC Water often result in savings on permitting and work coordination with the
contractor. The property owner can get estimates from other contractors to compare costs. The DC
Water contractor rate is $100 per foot of pipe replaced on private property plus $500 to connect inside
the house. DC Water provides payment options for this work, including full payment prior to the work,
full payment after the work is completed, and four monthly payment installments. For the
Demand/Voluntary Program where the private-side replacement work is solely negotiated between the
homeowner and the contractor, the prices are slightly higher. We have been informed by homeowners
that the contractor is charging $125 per foot of pipe that needs to be replaced, plus a $600 penetration
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charge. DC Water is not involved (other than to have the data reported back to the utility to update its
database). In the vast majority of cases, these costs are still significantly lower than if an outside
plumber/contractor were used. Under both alternatives, DC Water will also send an inspector free of
charge to inspect the work at the property, including in the home.
Effectiveness: DC Water's special rate offer to property owners has helped increase the amount of
private portion lead service line replacement work that has been done in the District. The level of
interest has varied considerably by neighborhood with the wealthier neighborhoods experiencing higher
levels of subscription. DC Water estimates that the higher income areas have had over 40% subscription
levels while the lower income areas have had less than 20% subscription levels.
Concerns or Barriers: DC Water has not implemented a program yet to provide increased financial
assistance to lower income customers to facilitate the replacement of their portion of the lead service
lines. The current special rate incentives have not been large enough to address the cost of these
replacements from an affordability perspective, as evidenced by the lower than desired participation
rates. In addition, the District still has a significant number of lead service lines that have not been
replaced, as reflected by the $300 million DC Water estimate of remaining work on the public portion of
these lines.
Program Links: https://www.dcwater.com/lead-pipe-replacement https://www.dcwater.com/lead
Midwestern Region
City/State: Flint, Michigan
Issue: Replacing lead service lines to prevent drinking water contamination.
Background: In 2015, the drinking water in Flint became contaminated with lead after the city changed
its water source and failed to guard against pipe corrosion. To date, residents are still advised to drink
only filtered tap water or bottled water. Flint has replaced 850 of an estimated 20,000 lead and
galvanized steel residential water lines with copper piping since last year and plans to replace 6,000
water lines in 2017, finishing all replacements by 2020. The City provides free bottled water and water
filters and Michigan has spent $167 million since 2015 trying to address their health and infrastructure
issues from the lead crisis.
Financing/Funding Approach: Michigan's legislature voted to send $100 million in federal funds to Flint
for lead pipe replacement and other infrastructure upgrades. Most of their replacement plans are being
paid through federal and state funding, but it will not be enough to alleviate Flint's water crisis. To
complete the lead replacement by the end of 2019, $70 million more will be needed, much of which
may have to be passed down to residents.
Effectiveness: Flint is probably the most well-known case study regarding lead pipes resulting in
drinking water contamination. Their situation brought national attention to the issue and raised the
profile of lead in water issues across the country. It also spurred greater scrutiny from regulators as well
as pressure from residents to reduce lead in drinking water. The analysis of what went wrong serves as
guidance on remediation and recommended policies for other states.
Concerns or Barriers: Flint is replacing the lead pipes and switching to the Karegnondi Water Authority,
but there are still major concerns with the way the city originally handled this crisis and whether they
are equipped to take back responsibility. Even with lead levels decreasing and improvements being
made, the water is still not safe to drink without a filter, and it is recommended still that residents drink
bottled water. Many people are either home bound or lack proper transportation to go to pick up
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stations to get bottled water. The effects of this crisis will linger for some time, including a general lack
of confidence in the government to handle the situation that still exists.
Case Study Takeaway: The story in Flint showed many things, including that many cities do not know
where their lead pipes are buried so replacement is not easy with financing in hand. Flint also brought
recognition that too few children in Michigan are screened for lead through routine blood tests,
investments in education and public health are critical, coordination and good communication are vital,
and follow-up on children with elevated blood levels is imperative.
Program Links: http://www.cnn.com/2016/03/04/us/flint-water-crisis-fast-facts/
City/State: Illinois
Issue: Replacing lead service lines in Illinois' disadvantaged communities to prevent drinking water
contamination.
Background: The federal capitalization grant for drinking water state revolving fund programs requires
that 20% of the available funds be used to provide additional subsidization for eligible loan recipients in
the form of principal loan forgiveness. In addition to providing additional subsidy to disadvantaged
communities, the Illinois EPA Bureau of Water is currently utilizing its principal forgiveness capacity to
fund projects that reduce or eliminate lead from potable water by removing and replacing lead service
lines and related equipment and appurtenances that are likely sources of lead contamination. To qualify,
a public water system must have lead service lines connected to its system, currently at the time of
application be on an increased lead monitoring schedule which requires sample collection every six
months, and have a history of two or more lead action level exceedances.
Financing/Funding Approach: Lead service line replacement ("LSLR") principal forgiveness is available
for all applicants up to a maximum amount of $4,000,000 for communities with a median household
income ("MHI") less than 70% of the State average. MHIs are based on the 2010 - 2014 American
Community Survey 5 Year Estimates released in December 2015. For other recipients, principal
forgiveness is available up to 50% of the initial loan amount up to a maximum amount of $1,000,000.
LSLR principal forgiveness is available for State FY2017 loan recipients until all allotted funds are
expended. Any remaining funds may be expended for non LSLR disadvantaged community principal
forgiveness.
Concerns or Barriers: No concerns or barriers. This program is focused on the public portion of
community lead service lines. The private portion of lead service lines is not funded by this program.
Program Link: http://www.epa.illinois.gov/topics/grants-loans/state-revolving-fund/postings/index
(2017 Public Water Supply Loan Program Intended Use Plan and Project Priority List)
City/State: Illinois
Issue: Drinking water lead testing in Illinois schools and day care centers.
Background: Legislation was passed in January 2017 by Governor Bruce Rauner requiring day care
centers constructed before 2000 that serve children under six and schools with students up to fifth
grade built before 2000 to test every tap for lead in drinking water as well as water used for cooking in
schools. Under the law, Illinois schools built before 1987 are required to test before the end of 2017.
Those constructed between 1987 and 2000 have until the end of 2018 to test. Taps that have been
tested after 2013 will not have to be tested again. To obtain a waiver from additional testing, the testing
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method and results must be submitted to the Illinois Department of Public Health for approval.
According to the Illinois Environmental Council and Illinois Attorney General Lisa Madigan's office,
approximately 2,500 schools and 11,000 licensed day care centers could be affected by the law. The
state's largest school district, Chicago Public Schools, has already conducted lead testing.
Financing/Funding Approach: The legislation requires day care centers and schools to pay for their own
lead testing, rather than water suppliers. The cost of testing for each school could range from $500 to
$5,000. This cost could increase if lead is present and mitigation is required. The legislation enables
schools to access monies available in tort immunity and life safety health funds for lead testing.
Concerns or Barriers: The legislation mandates lead testing in day care centers and schools that are at
the greatest risk of having lead in water supplies. The legislation does not address a source of funds for
any day care centers or schools that find excess lead levels and need to mitigate the exposure.
Program Links:
http://www.chicagotribune.com/news/ct-rauner-school-lead-testing-law-20170116-story.html
www.chicagotribune.com/news/.../ct-lead-testing-schools-met-20170110-story.html
www. politico.com/.../illinois/.../major-deal-reached-requiring-lead-testing-in-illinois-s
City/State: Chicago, Illinois
Issue: Lead Paint
Background: At one point in time, Illinois led the nation in the number of children identified as lead
poisoned. It was estimated that more than 81,000 children in Illinois were harmed by lead each year. In
Chicago, approximately 88,000 units of lead-contaminated housing were at risk for poisoning children.
55,000 of these units were in multi-family buildings.
Financing/Funding Approach: A program was designed to reduce childhood lead poisoning by making
more than $12 million available to replace windows and address other lead hazards in approximately
2,000 affordable rental units in apartment buildings in Chicago over two years from 2007 to 2009. The
program combined a $6 million grant from the City of Chicago Department of Public Health with $6
million private capital raised by Delta Redevelopment Institute through federal New Market Tax Credits
Program from five lenders and investors. City funds originated from grants made by the United States
Department of Housing and Urban Development. Qualifying landlords could borrow the required funds
for approved lead abatement work, but once half the loan plus interest has been paid back, the other
half would be forgiven.
Concerns or Barriers: There were many concerns and barriers to this program, including a complex
screening process, a time-consuming application, limited capacity to manage all aspects of the program,
weather conditions for installment, change in leadership, and the bankruptcy of a parent company to
the lead abatement service company. In the end, only 10% of the $12 million in public and private funds
allocated to the program were spent and only 10% of the projected units were abated.
This did not generate enough income to cover the cost of setting up and administering the program. The
program ended in the early days of the financial crisis and some borrowers defaulted on their loans. As
the real estate market has slowly recovered some delinquent borrowers have paid off their loans to
clear the lien and sell their property.
Case Study Takeaway: The New Market Tax Credits were used as a leveraging tool to help the City use
its $6 million grant to address the problem of lead abatement in multi-family buildings and double the
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number of units that would receive abatement services. The use of New Market Tax Credits was
significant because it provided a model for public/private partnership to raise private capital to address
this problem. New Markets Tax Credits are a source of private investment capital for lead abatement if
they are used to fund qualified businesses that provide lead abatement services. Public sector (HUD)
lead abatement grant requirements do not mesh well with private financing from either a marketing
(demand) or underwriting point of view. The energy efficiency benefits of window replacement were an
important inducement to building owners to participate in the lead abatement program. Charitable
organizations crafting public/private partnerships should seek payment for the effort from grants, and
not from the volume of a program over which they have no control.
Program Links: http://www.leadsafeillinois.org/prevention/
City/State: Lansing, Michigan
Issue: Replacing lead service lines in the city to prevent drinking water contamination.
Background: The Lansing Board of Water & Light (LBWL) is a municipally owned utility governed by a
Board of Commissioners. It has groundwater supplies and treats 22 MGD on average per day from 125
wells. There are approximately 59,000 accounts. LBWL took ownership of all water service lines from the
main line to the meter inside the building in 1927, and had installed lead service lines up until the early
1960s. Due to their ownership, they have very good records of the type of material for all the service
lines. Although there were lead service lines in the system, all the lead sampling showed lead levels
below the 90th percentile standard. LBWL has been using a corrosion inhibitor in the system since 1997
to help keep the lead levels low. In 2004, the LBWL board approved a Lead Service Line Replacement
(LSLR) Program. Approximately 14,000 service lines were replaced between 2004 and 2017. This
represents all the known lead service lines in the system.
Financing/Funding Approach: The total cost to replace the 14,000 lead service lines was $44.5 million.
Given the LBWL's ownership if the complete service line, the replacements were handled as a capital
investment of the utility. Over the 14 years of replacement, the average annual investment has been
approximately $3.4 Million/year. Rate payer revenues were used as part of the funding for the project.
To reduce the costs, the city developed its own unique method of trenchless service line replacement.
Initially, the replacements cost approximately $9,000 per home. With its trenchless method, the costs
were reduced to $3,600 per home. The time was reduced from all day to four hours. When possible,
projects were coordinated with other infrastructure replacements, such as road resurfacing or combined
sewer overflow projects, to save on pavement removal costs. The initial goal of removing all lead
services in ten years had to be extended to 14 years because of the slowdown in the combined sewer
overflow work that occurred because of the recession.
Effectiveness: The program was extremely effective. With Madison, Lansing represents only the second
city to remove all of its lead service lines. The work was done in a cost-efficient manner and was
coordinated with homeowners and largely supported by the community. Only complete service line
replacements were done. Testing has shown the city's water system to be in compliance with all lead
and copper standards.
Applicability to Other Utilities: The unique ownership style of the service lines made this project much
easier to complete. There was no issue with accessing property or getting homeowners to agree to
remove the lines because LBWL's regulations allow for its employees to enter the customer's property
to maintain the service line. There was coordination with the customers, but it was not necessary to
work with a private plumber to do the customer's side of the service as is often the case when the utility
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only owns to the curb stop. There also was no concern with partial lead line replacement since the utility
owned the entire line. LBWL has trained many other utilities in how to do the trenchless service line
replacement method.
Case Study Takeaway: Lansing reveals that a long-term, steady approach can work to remove lead
service lines. It was a major investment, but the utility accomplished the task by phasing the project
over 14 years. Looking at the lead service line replacement as an investment in the utility was a positive
approach. The city was able to use its own ingenuity to improve the speed and cost of repairs.
Program Links:
https://www.lbwl. com/Search. aspx?searchtext=lead%20water%20line%20replacement&LangType=103
3
https://www.lbwl.com/Community.../Lead-Service-Line-Replacement-Presentation/
http://www.detroitnews.com/story/news/local/michigan/2016/12/14/lansing-lead-service-
line/95435604/
City/State: Wisconsin
Issue: Helping disadvantaged customers pay for lead service line replacements when entire lead service
lines are being replaced.
Background: It has been shown that it is necessary to replace full lead service lines, not partial service
lines, in order to protect customers. In most water systems, the system owns the line from the main line
pipe to the curb stop and the customer owns the line from the curb stop to the house or building. While
the system can fund the replacement of their portion of the service line through user fees, they cannot
use user fees to replace the private portion of the service line. If customers are unable to pay for their
portion of the replacement, either only a partial replacement could be done or the entire line would
have to remain in place. Either of these scenarios is problematic, so Wisconsin DNR has allocated funds
to help disadvantaged communities with the full lead service line replacement.
Financing/Funding Approach: The funding for this program will come from Wisconsin's State Revolving
Fund Program. As such, it is federal funding and will require the recipient to abide by all federal
requirements. It is entirely principal forgiveness and does not include any loan portion. A municipality
can do a lead pipe replacement (LPR) project on its own (meaning no other work is being done) or it can
be part of a bigger pipe replacement project. The applicant also has the choice to use the funding to
seed a local revolving fund for lead pipe replacement or to set up a rebate program for homeowners.
The program is only eligible for two years - FY 17 and FY 18 - and the first year of the project, $11.8
million was set aside for the principal forgiveness.
A municipality is eligible for the funding if it qualifies for at least 15% principal forgiveness under the
regular guidelines for principal forgiveness. As long as the municipality qualifies at this level or higher
they are eligible for the maximum amount of award as shown below.
•	$1,000,000 for municipalities with populations over 500,000
•	$500,000 for municipalities with populations between 50,000 and 500,000
•	$300,000 for municipalities with populations below 50,000
Effectiveness: Thirty-eight municipalities submitted applications for the first round of funding. They
have three years to use this funding. It is too soon to know exactly how effective the program will
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ultimately be, but it will allow municipalities to pay for the entire replacement cost of lead service lines
at no cost to the municipality, so it is expected to be very effective.
Concerns or Barriers: There is no ability to use this funding for low income areas within communities
that are otherwise not considered disadvantaged. These customers are at a disadvantage because they
will not be eligible for no-cost replacement but will have a hard time paying for the replacement cost
any other way.
Case Study Takeaway: For states in which there are large numbers of communities with lead service
lines and large numbers of disadvantaged communities, this approach may be an option to increase the
pace and affordability of lead service line replacement.
Program Links:
http://dnr.wi.gov/Aid/projectListslUPs.html
http://dnr.wi.gov/Aid/documents/EIF/leadServiceLineFunding.html
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Appendix D: Lead Abatement Industry Employment Data
The intent of this section is to provide insight into the number of employers who work and retain
numerous employees across the country in the field of "lead abatement, lead risk assessment, lead
inspection, lead project monitoring, lead project supervising, lead handling workers, and all lead
practitioners."
The information contained here was compiled from various state, and federal websites from all 50 U.S.
states, and includes Washington D.C. Within the information captured for each state a list of website
links are provided to showcase where the information was derived from. The 13,914 lead firms
associated with the data in the addendum are corporate entities large and medium sized as well as the
small business. Additionally, the information also reflects companies that provide "EPA certified lead
abatement training and lead certifying" to assist with a more well-rounded view of the jobs associated
with lead abatement.
Lastly, this section does include very limited information on the amount of staff contained within each of
the 13,914 lead abatement firms. Unfortunately, information from each employer was not readily
accessible allowing for the quantification of employees associated within each field of "lead abatement"
services needed to perform in removal of toxic hazardous contaminated materials that currently plague
various U.S. communities, and the environment.
The total number tally contained in this section is for the number of companies/firms only. A loss of
13,913 firms and companies would take place if lead abatement programs are discontinued nationwide.
This information does not list the number of employees within each firm although within this document
some information on individuals was located and provided were data was readily available. All firms and
companies complied in the total count shown above are shown in bold lettering throughout the
document and used for the final tally.
Alabama
•	Contractors within the state certified for lead abatement services/ removal- 267 firms (12
counties)
•	Organizations that provide lead removal support programs/ advocate/ awareness/ referral
services/ train the trainer/ certifications-11 companies
•	Links
http://www.alabamapublichealth.gov/lead/index.html
http://www.alabamapublichealth.gov/lead/assets/rrpweblist03012017.pdf
http://www.leadsafelist.com/renovators/alabama/
Alaska
In Alaska, the US EPA administers the lead-based abatement program. The construction industry is
affected by two separate regulations that impact activities associated with lead paint.
•	Contractors within the state providing lead abatement services- Organizations that provide lead
removal support programs/ advocate/ awareness/ referral services / train the trainer/
certifications - 506 firms and or organizations (combined list of contractors, and organizations)
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•	Links
http://www.envcap.org/statetools/lead/pb2001.cfm?st=AK
https://www.environmental-expert.com/companies/kevword-lead-abatement-1017/serving-
usa-alaska?redirectedToServing=l
http://www.leadsafelist.com/renovators/alaska/
Arizona
•	Contractors within the state providing lead abatement services- 27 firms (7 counties)
•	Organizations that provide lead removal support programs/ advocate/ awareness/ referral
services / train the trainer/ certifications - EPA provides certification training for lead abatement
trainers. No list could be located to provide any company names
•	Links
http://legacy.azdeq.gov/environ/waste/ust/statelead.html
http://www.azdeq.gov/
http://www.azroc.gov/roc/contractorsearch.html
http://www.leadsafelist.com/renovators/arizona/
Arkansas
•	Contractors within the state providing lead abatement services-10 firms (9 counties)
•	Arkansas Department of Health website as well as the state's official website have removed all
information regarding lead abatement contractors, services, programs, and or training classes.
All links associated with this topic that correlate to the state's official websites have the Error
Message 404. No additional information could be located without directly calling upon each
entity one at a time to obtain information needed.
•	Organizations that provide lead removal support programs/ advocate/ awareness/ referral
services / train the trainer/ certifications - No information located
•	Links
http://www.healthy.arkansas.gov/programsServices/epidemiology/Environmental/Pages/LeadB
asedPaint.aspx
http://www.leadsafelist.com/renovators/arkansas/
California
•	Contractors within the state providing lead abatement services- 347 firms (from 46 counties)
•	Organizations that provide lead removal support programs/ advocate/ awareness/ referral
services / train the trainer/ certifications - 40 companies approximated due to repeat of
supplier information
•	Links
Type of Certificate Required Training Inspector/Assessor Inspection/Assessment (40 hours); or
Certified Industrial Hygienist Course (24 hours - CIHs only) Project Monitor Supervision & Project
Monitoring (40 hours); or Work (24 hours) + Supplemental Supervision & Project Monitoring (16
hours); or Certified Industrial Hygienist Course (24 hours - CIHs only) Sampling Technician
Sampling Technician (8 hours) Supervisor Supervision & Project Monitoring (40 hours); or Work
(24 hours) + Supplemental Supervision & Project Monitoring (16 hours) Worker Work (24 hours)
(the above information is a link)
http://www.leadsafelist.com/renovators/California/
https://archive.cdph.ca.gov/programs/CLPPB/Pages/LRCWhichCert.aspx
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Required Training
Inspection/Assessment (40 hours); or
Certified Industrial Hygienist Course (24 hours - CIHs only)
Supervision & Project Monitoring (40 hours); or
Work (24 hours) +
Supplemental Supervision & Project Monitoring (16 hours); or
Certified Industrial Hygienist Course (24 hours - CIHs only)
Sampling Technician (8 hours)
Supervision & Project Monitoring (40 hours); or
Work (24 hours) +
Supplemental Supervision & Project Monitoring (16 hours)
Work (24 hours)
Colorado
•	Contractors within the state providing lead abatement services- 93 firms (23 counties)
•	Organizations that provide lead removal support programs/ advocate/ awareness/ referral
services / train the trainer/ certifications, evaluator, laboratories- 37 companies
•	County Staff focused on Lead Abatement- 64 individuals
•	Additional entities providing regulatory services- 9
•	Links
http://www.leadsafelist.com/renovators/Colorado/
https://www.colorado.gov/pacific/sites/default/files/AP_IN_Lead-Services-Directory.pdf
Connecticut
•	Contractors within the state providing lead abatement services- 98 firms (8 counties)
•	Organizations that provide lead removal support programs/ advocate/ awareness/ referral
services / train the trainer/ certifications - 7 companies
•	3 state official office staff members, LEAD POISONING PREVENTION, Program Contacts
•	Links
http://www.leadsafelist.com/renovators/Connecticut/
http://www.ct.gov/dph/lib/dph/environmental health/lead/pdf/resources.pdf
http://www.ct.gov/dph/lib/dph/environmental health/lead/pdf/how to find dph licensed co
ntractor-4-12-12.pdf
https://www.elicense.ct.gov/ (site cannot be accessed without user name and ID)
Contractors and Consultants	Education and Training
• Licensed Lead Practitioners	• Lead Training Providers
• Training Course Approval
Type of Certificate
Inspector/Assessor
Project Monitor
Sampling Technician
Supervisor
Worker
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EPA's Renovation, Repair and Painting (RRP)
Certification Program
Lead Inspections
Lead Abatement Guidance Documents
Licensing and Certification
Requirements
Lead Semi-Annual Meeting
information
Delaware
•	Contractors within the state providing lead abatement services- 42 firms
•	Organizations that provide lead removal support programs/ advocate/ awareness/ referral
services / train the trainer/ certifications - 260 companies (Delaware certified Renovation
Firms), 18 companies (Lead Certified Risk Assessment Firms)
•	Links
http://dhss.delaware.gov/dph/hsp/leadregcomm.html
http://dhss.delaware.gov/dph/hsp/files/leadcert.pdf
http://dhss.delaware.gov/dph/hsp/files/leadcertrrp.pdf
Florida
•	Contractors within the state providing lead abatement services-171 firms (46 counties)
Organizations that provide lead removal support programs/ advocate/ awareness/ referral
services / train the trainer/ certifications, Dust Sampling Technician, Lead Abatement
Supervisor, Lead Abatement Worker, Lead Inspector, Lead Renovator (Renovation, Repair, and
Painting), Lead Risk Assessor, Project Designer- all jobs associated with list
•	Links
http://www.leadsafelist.com/renovators/florida/
http://www.floridahealth.gov/environmental-health/lead-poisoning/renovation.html
http://www. leadcertification.org/states. php?s=fl
Georgia
•	Contractors within the state providing lead abatement services (Georgia Certified Lead-Based
Paint Renovation Firms (as of August 8, 2017,) - 873 firms
•	Organizations that provide lead removal support programs/ advocate/ awareness/ referral
services / train the trainer/ certifications - 125 companies, Lead Paint Inspectors 152 individuals
•	Links
https://epd.georgia.gov/lead-based-paint
https://epd.georgia.gov/sites/epd.georgia.gov/files/Lead Abatement Training Providers 0112
15
pdf
https://epd.georgia.gov/sites/epd.georgia.gov/files/Lead_Firms_Aug2017.pdf
https://epd.georgia.gov/sites/epd.georgia.gov/files/GeorgiaCertifiedRenovators 080817.pdf
https://epd.georgia.gov/sites/epd.georgia.gov/files/Lead_lndividuals_Aug2017.pdf
Hawaii
•	Contractors within the state providing lead abatement services- 87 firms
•	Organizations that provide lead removal support programs/ advocate/ awareness/ referral
services / train the trainer/ certifications - 5 companies
•	Links
http://www.leadsafelist.com/renovators/hawaii/
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http://health.hawaii.gov/irhb/lead/
http://health.hawaii.gov/irhb/files/2013/07/leadtp.pdf
http://health.hawaii.gov/irhb/files/2013/07/Hawaii-Certified-Firms-January-l-2017.pdf
Idaho
•	Contractors within the state providing lead abatement services- 25 firms + 11 EPA certified lead
abatement firms (17 counties)
•	Organizations that provide lead removal support programs/ advocate/ awareness/ referral
services / train the trainer/ certifications - lead abatement trainings appear to be only provided
through the EPA in the State of Idaho
•	Links
http://www.leadsafelist.com/renovators/idaho/
https://cfpub.epa.gov/flpp/pub/index.cfm?do=main.firmResults&Applicant Type=FIRM&static=
true&doSearch=Yes&qlat=&qlong=&programType=Abatement%2CCombination&discipline=Eval
uation&TxtLocation=&distance l=50&state 2=ID&Applicant Name=&Certificate number=
https://labor.idaho.gov/dnn/wia/CustomerServices/EligibleProviderLists.aspx
Illinois
•	Contractors within the state providing lead abatement services-121 firms (39 counties)
•	Organizations that provide lead removal support programs/ advocate/ awareness/ referral
services / train the trainer/ certifications, supervisors, employees, lead risk assessor, lead risk
inspector - 325 individuals
•	Links
http://www.leadsafelist.com/renovators/illinois/
https://data.illinois.gov/dataset/566lead_contractor_registration
https://data.illinois.gov/dataset/566lead contractor registration/resource/a225b294-22bf-
4ff6-8854-27d5edb4d705
https://data.illinois.gov/dataset/568lead_supervisor_licensees
https://data.illinois.gov/dataset/568lead supervisor Iicensees/resource/70d68a68-50fe-48e9-
86ea-b609934fabl7
https://data.illinois.gov/dataset/570lead_worker_licensees
https://data.illinois.gov/dataset/570lead worker licensees/resource/6934e526-c43a-415b-
a999-6b2ae29f0b2a
https://data.illinois.gov/dataset/567lead risk assessor and inspector licensees
https://data.illinois.gov/dataset/567lead risk assessor and inspector licensees/resource/e56
6cl81-c345-4e49-9ff5-d233ec210adc
https://data.illinois.gov/dataset/569lead training course provider list
https://data.illinois.gov/dataset/569lead_training_course_provider_list/resource/4d45e54b-
fcc9-45al-a605-e5c7520fcda4
Indiana
•	Contractors within the state providing lead abatement services- 80 Firms (39 counties)
•	Organizations that provide lead removal support programs/ advocate/ awareness/ referral
services / train the trainer/ certifications - 13 Companies
•	Links
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http://www.leadsafelist.com/renovators/lndiana/
http://www.ai.org/isdh/files/l_LIST_OF_LEAD_TRAINING_COURSE_PROVIDERS.pdf
Iowa
•	Contractors within the state providing lead abatement services- 5 Firms
•	Organizations that provide lead removal support programs/ advocate/ awareness/ referral
services / train the trainer/ certifications - 10, Lead Testing Companies
•	Links
http://idph.iowa.gov/lpp
https://idph.i0wa.g0v/P0rtals/l/userfiles/8l/AugustLTP ByNameofFirm%26Courses.pdf
https://idph.iowa.gOv/Portals/l/userfiles/81/April2017 ThirdPartvTestProviders%20%281%29.p
df
http://www.leadsafelist.com/renovators/lowa/
Kansas
•	Contractors within the state providing lead abatement services/ Lead Activity- 51 firms
•	Organizations that provide lead removal support programs/ advocate/ awareness/ referral
services / train the trainer/ certifications - 7 companies, Certified Renovators excel worksheet
340 individuals
•	Links
http://www.kshealthvhomes.org/
http://www.kshealthvhomes.org/lead training.htm
http://www.kshealthvhomes.org/download/LicensedLeadActivitvFirmsfinal-28-2017.pdf
Kentucky
•	Contractors within the state providing lead abatement services- 53 Firms
•	Organizations that provide lead removal support programs/ advocate/ awareness/ referral
services / train the trainer/ certifications - 6 Companies
•	Links
http://chfs.ky.gov/dph/lead.htm
http://chfs.kv.gov/NR/rdonlvres/1509229C-F492-45D9-865C-
B54CFF24B8A4/0/WebListingDecember2016.pdf
http://chfs.kv.gov/NR/rdonlvres/54B11067-5949-492D-AAEE-
8042DBFC764B/0/TrainingProviderWebpageDecember2016.pdf
http://www.leadsafelist.com/renovators/kentucky/
Louisiana
•	Contractors within the state providing lead abatement services- 23 Firms (14 Parishes)
•	Organizations that provide lead removal support programs/ advocate/ awareness/ referral
services / train the trainer/ certifications - 6 Companies
•	Links
http://www.leadsafelist.com/renovators/louisiana/
http://deq.louisiana.gov/page/leadbased-paint/
http://deq.louisiana.gov/assets/docs/Air/Lead_Paint/LA-RRP-program-Trainers-EPA-as-of-
090911.pdf
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Maine
•	Contractors within the state providing lead abatement services- 31 Firms (12 counties)
•	Organizations that provide lead removal support programs/ advocate/ awareness/ referral
services / train the trainer/ certifications - 20 Companies, 17 Inspectors, 10 Accessors
•	Links
http://www.leadsafelist.com/renovators/maine/
http://www.maine.gov/dep/waste/asbestos/trproviders.html
http://www.maine.gov/dep/waste/lead/findalp.html
http://www.maine.gov/dep/waste/lead/leadcontractors.html
http://www.maine.gov/dep/waste/lead/leadinspectors.html
http://www.maine.gov/dep/waste/lead/leadassessors.html
Maryland
•	Contractors within the state providing lead abatement services-146 Firms (24 counties)
•	Organizations that provide lead removal support programs/ advocate/ awareness/ referral
services / train the trainer/ certifications - 8 Companies, 255 Inspectors
•	Links
http://www.leadsafelist.com/renovators/marvland/
http://mde.marvland.gov/programs/LAND/Documents/LeadFactSheets/LeadfsTrainingProviderL
ist.pdf
http://mde.marvland.gov/programs/LAND/LeadPoisoningPrevention/Pages/leadcontractors.asp
x?state wide=l
http://mde.maryland.gov/programs/LAND/LeadPoisoningPrevention/Pages/leadinspectors.aspx
?a=go&state_wide=l
Massachusetts
•	Contractors within the state providing lead abatement services Currently Licensed Renovation,
Repair and Painting Contractors - 896 Firms (14 counties)
•	Organizations that provide lead removal support programs/ advocate/ awareness/ referral
services / train the trainer/ certifications - 12 Companies
•	Links
http://www.mass.gov/lwd/labor-standards/deleading-and-lead-safety/
http://www.mass.gov/lwd/docs/dos/lead-asbestos/lead/la-rpt-list-lr.pdf
http://www.mass.gov/lwd/docs/dos/lead-asbestos/lead/la-rpt-list-dc.pdf
http://www.leadsafelist.com/renovators/Massachusetts/
http://www.mass.gov/lwd/docs/dos/lead-asbestos/lead/la-rpt-list-dt.pdf
Michigan
•	Contractors within the state providing lead abatement services- 214 Firms (34 counties)
•	Organizations that provide lead removal support programs/ advocate/ awareness/ referral
services / train the trainer/ certifications - 6 companies, 92 certified lead workers, 716
supervisors
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•	Links
http://www.michigan.gOv/mdhhs/0.5885.7-339-71550 2955 2983-42276-.00.html
http://www.michigan.gOv/mdhhs/0.5885.7-339-71550 2955 2983-95171--.00.html
http://www.michigan.gov/documents/mdhhs/List of Contractors 543750 7.pdf
http://www.michigan.gov/documents/mdhhs/Worker 543746 7.pdf
http://www.michigan.gov/documents/mdhhs/Supervisors 543748 7.pdf
http://www.leadsafelist.com/renovators/michigan/
Minnesota
•	Contractors within the state providing lead abatement services- 230 Firms contractors and
consultants (36 counties)
•	Organizations that provide lead removal support programs/ advocate/ awareness/ referral
services / train the trainer/ certifications - EPA provides training for instructors teaching lead
abatement courses in Minnesota, a list cannot be obtained of the providers unless taking a
course
•	Links
http://www.leadsafelist.com/renovators/minnesota/
http://www.health.state.mn.us/divs/eh/lead/prof/license.html
http://www.health.state.mn.us/divs/eh/lead/find_firm/index.cfm
http://www.health.state.mn.us/divs/eh/lead/find firm/pb firms by state.cfr?state code=MN
http://www.leadcertificationmn.com/
Mississippi
•	Contractors within the state providing lead abatement services, Mississippi Lead Based Paint
Certified entities-148 firms
•	Organizations that provide lead removal support programs/ advocate/ awareness/ referral
services / train the trainer/ certifications, inspectors - 30 lead inspectors, 19 risk assessors
•	Links
http://www.deq.state.ms.us/MDEQ.nsf/page/Air Lead-BasedPaint
http://opc.deq.state.ms.us/report lead el.aspx
http://www.deq.state.ms.us/MDEQ.nsf/page/Air Lead-BasedPaint
http://www.deq.state.ms.us/MDEQ.nsf/pdf/Air LBPMSAccreditedTrainingProvidersl2 02 2015
/$File/Mississippi%20Accredited%20Training%20Providers%20offering%20Lead%20Renovator%
20Training.pdf?QpenElement
http://opc.deq.state.ms.us/report lead el.aspx
http://www.leadsafelist.com/renovators/mississippi/
Missouri
•	Contractors within the state providing lead abatement services-180 firms (29 counties)
•	Organizations that provide lead removal support programs/ advocate/ awareness/ referral
services / train the trainer/ certifications - 302 abatement supervisors, 628 lead abatement
workers, 66 inspectors, 115 risk assessors, 9 project designers, 11 companies that train and
certify lead abatement firms/ companies/entities and individuals
•	Links
http://health.mo.gov/safety/leadlicensing/
http://health.mo.gov/safety/leadlicensing/pdf/AbatementContractors.pdf
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http://health.mo.gov/safetv/leadlicensing/pdf/MissouriLicensedLeadAbatementWorkers.pdf
http://health.mo.gov/safety/leadlicensing/pdf/MissouriLicensedLeadlnspectors.pdf
http://health.mo.gov/safety/leadlicensing/pdf/MissouriLicensedRiskAssessors.pdf
http://health.mo.gov/safety/leadlicensing/pdf/MissouriLicensedLeadProiectDesigners.pdf
http://www.leadsafelist.com/renovators/missouri/
http://health.mo.gov/safety/leadlicensing/training.php
http://health.mo.gov/safety/leadlicensing/pdf/AccreditedProvidersReport.pdf
Montana
•	Contractors within the state providing lead abatement services- 7 firms (10 counties)
•	Organizations that provide lead removal support programs/ advocate/ awareness/ referral
services / train the trainer/ certifications - EPA provides certification training for lead abatement
trainers. No list could be located to provide any company names
•	Links
http://www.leadsafelist.com/renovators/montana/
http://deq.mt.gov/Business/leadbasedpaint
Nebraska
•	Contractors within the state providing lead abatement services-11 firms (9 counties)
•	Organizations that provide lead removal support programs/ advocate/ awareness/ referral
services / train the trainer/ certifications, consultants - 8 companies
•	Links
http://www.leadsafelist.com/renovators/nebraska/
http://dhhs.ne.gov/publichealth/Pages/LeadContractors.aspx
http://dhhs.ne.gov/publichealth/Documents/LeadBusinessEntitiesAndConsultants.pdf
http://dhhs.ne.gov/publichealth/Documents/leadthirdpartyexams.pdf
Nevada
•	Contractors within the state providing lead abatement services-18 firms (5 counties)
•	Organizations that provide lead removal support programs/ advocate/ awareness/ referral
services / train the trainer/ certifications - EPA provides trainer training a compiled list of
trainers could not be located
•	Links
http://www.leadsafelist.com/renovators/nevada/
https://www.epa.gov/lead/lead-based-paint-activities-professionals
New Hampshire
•	Contractors within the state providing lead abatement services- 47 firms (10 counties)
•	Organizations that provide lead removal support programs/ advocate/ awareness/ referral
services / train the trainer/ certifications - EPA provides trainer training for lead abatement
programs
•	Links
https://www.dhhs.nh.gov/dphs/bchs/clpp/documents/contractor.pdf
http://www.leadsafelist.com/renovators/new-hampshire/
New Jersey
•	Contractors within the state providing lead abatement services-154 firms (21 counties)
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•	Organizations that provide lead removal support programs/ advocate/ awareness/ referral
services / train the trainer/ certifications - 13 companies
•	Links
http://www.state.ni.us/health/ceohs/lead/lead-training-cert/
http://www.state.ni.us/health/ceohs/documents/lead/pb trng providers.pdf
http://www.leadsafelist.com/renovators/New-Jersev/
New Mexico
•	Contractors within the state providing lead abatement services-16 firms (7 counties)
•	Organizations that provide lead removal support programs/ advocate/ awareness/ referral
services / train the trainer/ certifications - EPA provides trainer training for lead abatement
programs
•	Links
http://www.leadsafelist.com/renovators/new-mexico/
New York
•	Contractors within the state providing lead abatement services- 336 firms (55 counties)
•	Organizations that provide lead removal support programs/ advocate/ awareness/ referral
services / train the trainer/ certifications - the State of New York provides a mix of training
providers and sources including some training through the EPA. Unfortunately, due to the lack
of a unified database a list of certified trainers could not be located
•	Links
http://www.leadsafelist.com/renovators/new-vork/
http://www.nvshcr.Org/AboutUs/Training/index.htm#lead
North Carolina
•	Contractors within the state providing lead abatement services-13 firms (additional database
provided but no ability to search statewide, only a city by city search available/ not user friendly)
•	Organizations that provide lead removal support programs/ advocate/ awareness/ referral
services / train the trainer/ certifications - 27 companies
•	Links
http://epi.publichealth.nc.gov/lead/lhmp.html
http://epi.publichealth.nc.gov/lead/pdf/LeadTrainingProviders0817.pdf
http://epi.publichealth.nc.gov/lead/pdf/NCRRPTrngPvdrlnfo Aug2017.pdf
http://www.schs.state.nc.us/lead/accredited.cfm
http://www.leadsafelist.com/renovators/North-Carolina/
North Dakota
•	Contractors within the state providing lead abatement services- 32 firms
•	Organizations that provide lead removal support programs/ advocate/ awareness/ referral
services / train the trainer/ certifications - EPA provides training for the certified lead
abatement contractors
•	Links
http://www.leadsafelist.com/renovators/north-dakota/
https://www.ndhealth.gov/aq/iaq/lbp/
http://www.ndhealth.gov/AQ/IAQ/LBP/NDLIBLBP.pdf
http://www.ndhealth.gov/ehs/aq/Lead/
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Ohio
•	Contractors within the state providing lead abatement services-108 firms (51 counties). The
state database requires an individual name search by city and county to locate a certified
licensed lead abatement contractor
•	Organizations that provide lead removal support programs/ advocate/ awareness/ referral
services / train the trainer/ certifications - Any trainer wishing to offer the U.S. EPA's
Renovation, Repair, and Painting (RRP) Renovator training in Ohio needs to not only be
approved by the USEPA, but also by ODH (Ohio Department of Health). A list of training
companies was not located
•	Links
http://www.leadsafelist.com/renovators/ohio/
https://www.odh.ohio.gov/-/media/ODH/ASSETS/Files/eh/lead-poisoning-prevention/ODH-
Approved-Encapsulant-List-7-l-15.pdf?la=en
https://www.odh.ohio.gov/odhprograms/eh/lp prev/lp listl.aspx
http://publicapps.odh.ohio.gov/Envlicense_Reports/External_License_Search.aspx?Program=Le
ad
Oklahoma
•	Contractors within the state providing lead abatement services- 256
•	Organizations that provide lead removal support programs/ advocate/ awareness/ referral
services / train the trainer/ certifications -
•	Links
http://www.deq.state.ok.us/aqdnew/lbp/index.htm
http://www.deq.state.ok.us/aqdnew/lbp/lbplistings.htm
http://www.deq.state.ok.us/aqdnew/lbp/Certified%20Lists/CertifiedLBPAbatementWorkers.ht
ml
http://www.deq.state.ok.us/aqdnew/lbp/Certified%20Lists/CertifiedLBPFirms.html
http://www.deq.state.ok.us/aqdnew/lbp/Certified%20Lists/CertifiedLBPInspectors.html
http://www.deq.state.ok.us/aqdnew/lbp/Certified%20Lists/CertifiedLBPRiskAssessors.html
http://www.deq.state.ok.us/aqdnew/lbp/Certified%20Lists/CertifiedLBPProiectDesigners.html
http://www.deq.state.ok.us/aqdnew/lbp/Certified%20Lists/CertifiedLBPSupervisors.html
http://www.deq.state.ok.us/aqdnew/lbp/Certified%20Lists/RRP_Firms.html
•	Abatement Workers
•	Firms
•	Inspectors
•	Inspector/Risk Assessors
•	Project Designers
•	Supervisors
•	Renovation, Repair and Painting Firms
Oregon
•	Contractors within the state providing lead abatement services- 41 firms (5 counties)
•	Organizations that provide lead removal support programs/ advocate/ awareness/ referral
services / train the trainer/ certifications - 14 companies
•	Links
http://www.oregon.gov/OHA/PH/Pages/index.aspx
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http://www.oregon.gov/oha/PH/HEALTHYENVIRONMENTS/HEALTHYNEIGHBORHOODS/LEADPQ
ISONING/TRAININGPROVIDERS/Documents/OR-Accredited-RRP-LBPA-Training-Providers.pdf
http://www.oregon.gov/oha/PH/HEALTHYENVIRONMENTS/HEALTHYNEIGHBORHOODS/LEADPQ
ISONING/INSPECTIONABATEMENTPROFESSIONALS/Documents/firmlist.pdf
http://www.leadsafelist.com/renovators/Oregon/
Pennsylvania
•	Contractors within the state providing lead abatement services-106 firms (48 counties)
•	Organizations that provide lead removal support programs/ advocate/ awareness/ referral
services / train the trainer/ certifications - 12 companies
•	Links
http://www.leadsafelist.com/renovators/pennsvlvania/
www.dli.pa.gov/lndividuals/Labor-Management-Relations/bois/.../LEDCONTR.HTML
http://www.phila.gov/health/pdfs/CertifiedLeadAbatementContractors.pdf
www.dli.pa.gov/lndividuals/Labor-Management-Relations/bois/.../LEDSCH.HTML
Rhode Island
•	Contractors within the state providing lead abatement services- 2031 firms/ licensed individuals
•	Organizations that provide lead removal support programs/ advocate/ awareness/ referral
services / train the trainer/ certifications - categories combined within contractor grouping
shown above information provided from state website
•	Links
http://www.health.ri.gov/healthrisks/poisoning/lead/index.php
http://www.health.ri.gov/find/environmentallead/trainingcourses/
http://www.leadsafelist.com/renovators/rhode-island/
http://www. health, ri.gov/find/licensees/index. php?prof=Lead%20Program#foo
South Carolina
•	Contractors within the state providing lead abatement services- 23 firms (18 counties)
•	Organizations that provide lead removal support programs/ advocate/ awareness/ referral
services / train the trainer/ certifications - the EPA administers the states lead abatement
training programs, individual training company information not available
•	Links
https://www.epa.gov/lead/lead-based-paint-activities-professionals
http://www.leadsafelist.com/renovators/south-carolina/
South Dakota
•	Contractors within the state providing lead abatement services- 6 firms (4 counties)
•	Organizations that provide lead removal support programs/ advocate/ awareness/ referral
services / train the trainer/ certifications - the EPA provides the lead safe training and
certification in the State of South Dakota
•	Links
http://www.leadsafelist.com/renovators/South-dakota/
https://denr.sd.gov/des/wm/wmp/leadpaint2.aspx
Tennessee
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•	Contractors within the state providing lead abatement services- 38 firms (32 counties)
•	Organizations that provide lead removal support programs/ advocate/ awareness/ referral
services / train the trainer/ certifications - the EPA provides the lead safe training and
certification in the State of Tennessee
•	Links
http://www.leadsafelist.com/renovators/tennessee/
Texas
•	Contractors within the state providing lead abatement services- 78 firms (38 counties) The State
of Texas requires a database search online by city and county to locate a licensed and lead
abatement certified contractor
•	Organizations that provide lead removal support programs/ advocate/ awareness/ referral
services / train the trainer/ certifications - 12 companies
•	Links
https://www.dshs.texas.gov/elp/training-providers.aspx
Utah
•	Contractors within the state providing lead abatement services- 208 firms
•	Organizations that provide lead removal support programs/ advocate/ awareness/ referral
services / train the trainer/ certifications - 10 companies
•	Links
https://deq.utah.gov/ProgramsServices/programs/air/lead/index.htm
https://documents.deq.utah.gov/air-quality/compliance/atlas/DAQ-2017-002431.pdf
https://documents.deq.utah.gov/air-qualitv/compliance/atlas/DAQ-2017-0024Q3.pdf
http://www.leadsafelist.com/renovators/utah/
Vermont
•	Contractors within the state providing lead abatement services- 5 firms (7 counties)
•	Organizations that provide lead removal support programs/ advocate/ awareness/ referral
services / train the trainer/ certifications - EPA Renovator Training Courses are provided by
various organization certified by the EPA. A compiled list of the trainer providers was not
located
•	Links
http://www.leadsafelist.com/renovators/vermont/
http://www.healthvermont.gov/health-environment/asbestos-lead-buildings/lead
Virginia
•	Contractors within the state providing lead abatement services- 96 firms (49 counties)
•	Organizations that provide lead removal support programs/ advocate/ awareness/ referral
services / train the trainer/ certifications - the EPA provides lead certification training for the
State of Virginia outside organizations providing any additional EPA certified training was not
located
•	Links
http://www.leadsafelist.com/renovators/virginia/
http://www.leadcertificationva.com/
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Washington
•	Contractors within the state providing lead abatement services- 2370 firms (19 counties) (52-
page documented list of certified lead abatement firms)
•	Organizations that provide lead removal support programs/ advocate/ awareness/ referral
services / train the trainer/ certifications - 18 companies
•	Links
http://www.commerce.wa.gov/building-infrastructure/housing/lead-based-paint/renovation-
repair-painting/
http://www.commerce.wa.gov/wp-content/uploads/2015/12/ceo-rrp-training-providers.pdf
https://app.box.eom/s/ry966km9dvrwwjml7hwom3g43flkjtij
West Virginia
•	Contractors within the state providing lead abatement services-11 firms (14 counties)
•	Organizations that provide lead removal support programs/ advocate/ awareness/ referral
services / train the trainer/ certifications - A compiled list of certified lead abatement training
companies was not located
•	Links
http://www.leadsafelist.com/renovators/west-virginia/
Wisconsin
•	Contractors within the state providing lead abatement services- 2080 firms
•	Organizations that provide lead removal support programs/ advocate/ awareness/ referral
services / train the trainer/ certifications/ consultants - 259 companies
•	Links
https://www.dhs.wisconsin.gov/lead/index.htm
https://www.dhs.wisconsin.gov/lead/training.htm
https://www.dhs.wisconsin.gov/lead/contractor/leadsafecompanv.pdf
https://www.dhs.wisconsin.gov/lead/contractor/leadcompany.pdf
Wyoming
•	Contractors within the state providing lead abatement services- 5 firms (4 counties)
•	Organizations that provide lead removal support programs/ advocate/ awareness/ referral
services / train the trainer/ certifications - online applications must be submitted to the EPA for
certified lead abatement training courses, information on additional trainings outside the EPA
was not located and could not be provided
•	Links
http://www.leadsafelist.com/renovators/wyoming/
Washington D.C.
•	Contractors within the state providing lead abatement services- 99 firms
•	Organizations that provide lead removal support programs/ advocate/ awareness/ referral
services / train the trainer/ certifications - information was not located on the training providers
for certified lead abatement training in Washington D.C.
•	Links
http://www.leadsafelist.com/renovators/D-C/
https://doee.dc.gov/publication/certified-lead-based-paint-abatement-renovation-companies
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https://doee.dc.gov/sites/default/files/dc/sites/ddoe/publication/attachments/DC%20Lead%20
Abatement%20-%20Renovation%20Companies%20Updated%208-21-2017.pdf
https://doee.dc.gov/lead
Publication #850R17002
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