oEPA
United States
Environmental Protection
Agency
Strategies to Achieve Full Lead Service Line Replacement
October 2019
EPA 810-R-19-003

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Contents
1	Introduction	4
2	Assessment of Projected Household Initiated Voluntary Lead Service Line Replacement as a Result
of Revisions to Public Education	6
2.3 Uncertainty	11
3	Challenges of Establishing LSLR Programs: Ownership, Control, and Access	14
3.1	Consent of the Customer	14
3.2	Mandatory LSLR	15
3.3	State and Local Authority to Enter Granted Through Regulation	16
4	Assessment of Projected Community Lead Service Line Replacement Programs as a Result of
Availability of Low Cost Federal Funds	18
5	Financing Full LSLR	22
5.1	Using Ratepayer Revenue	23
5.2	Using Non-Ratepayer Revenue	26
5.2.1	Federal Funds for Water System-Owned and Customer-Owned LSLR	26
5.2.2	State and Local Loan and Grant Programs	27
5.2.3	Special Assessments, Tax Levies, and Surcharges	29
5.2.4	Creative Funding Mechanisms	30
5.3	Targeting LSLR to Communities Most in Need	31
6	The Cost of LSLR	33
6.1	Coupling LSLR with Other Infrastructure Projects	33
6.2	Incorporating LSLR Best Practices to Improve Efficiency	34
7	References	36
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1 Introduction
The purpose of this document is to demonstrate how individual household lead service line replacement
(LSLR) is motivated by increased public education proposed in the revised Lead and Copper Rule (LCR).
Proactive community LSLR programs are similarly motivated and facilitated by the designation of lead as
a priority for low cost federal funding and financing programs. These programs could expand LSLR across
the country beyond that required by the proposed revisions to the LCR.
In addition, this document identifies challenges to LSLR that many communities face and the strategies
of states and communities across the country that have overcome these challenges. This document
supports the proposed Lead and Copper Rule Revisions (LCRR), which would require certain water
systems to conduct full LSLR. This document shows several examples of states and local communities
that are achieving full LSLR. In addition, it provides estimates of the numbers of LSLRs that will occur as a
result of actions under the proposed LCRR.
Numerous studies have evaluated the contribution of lead in drinking water from different sources
(e.g., service lines, faucets, meters). A study published by American Water Works Association (AWWA)
Water Research Foundation (2008) "Contributions of Service Line and Plumbing Fixtures to Lead and
Copper Rule Compliance Issues" (Sandvig et al, 2008) estimates that 50 percent - 75 percent of lead in
drinking water comes from lead service lines (LSLs). Given that LSLs are the greatest contributer of lead
in drinking water, identifying the locations and removing this source of lead is a critical component of
the proposed rule.
While LSLR is a component of the current Federal LCR, it is required only after all other actions to control
lead levels at the tap have been attempted. Public water systems (PWSs) triggered into LSLR due to a
failure to meet the lead action level1 in tap samples2 taken after installing corrosion control and/or
source water treatment must replace the portion of the lead service line (LSL) that it owns at an annual
rate of 7%. In cases where the water system does not own the entire LSL, the system must offer to
replace the customer-owned portion at his or her expense. If the customer elects not to have his or her
portion replaced, the water system is not required to replace the customer-owned portion. In addition,
water systems are not required to replace the customer-owned portion of the line where doing so
would be precluded by State, local, or common law (40 CFR 141.84(d)).
In most communities, LSLs are partially owned by the water system and partially owned by the
customer. The PWS typically owns the portion of the line from the water main to the curb stop or meter.
In many cases, the water system retains the authority to access and maintain the customer-owned
portion of the service line although the expense of performing the work is placed on the customer. In
those instances where a PWS subject to LSLR does not replace the customer-owned portion of the
1	The lead action level is exceeded if the concentration of lead in more than 10 percent of tap water samples
collected during any monitoring period conducted in accordance with §141.86 is greater than 0.015 mg/L (i.e., if
the "90th percentile" lead level is greater than 0.015 mg/L) (40 CFR §141.80(c)).
2	These regulations establish a treatment technique that includes requirements for corrosion control treatment,
source water treatment, LSLR, and public education. These requirements are triggered, in some cases, by lead and
copper action levels measured in samples collected at consumers' taps.
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service line, the PWS can meet the LSLR requirements of current Federal LCR by completing a partial
LSLR.
The U.S. Environmental Protection Agency (EPA) is proposing revisions to the LCR to include
requirements for full LSLR and to limit partial LSLR3 and prohibit the "test-out" provision4. Although
there are significant health benefits from full LSLR, full LSLR can be expensive at an average cost of
$4,700, ranging from $1,200 to $12,300 per line replaced (see Chapter 5 of the LCRR Economic Analysis,
docket number EPA-HQ-OW-2017-0300 at https://www.regulations.gov). In addition to cost, the EPA is
aware of implementation challenges that can be encountered when conducting full LSLR such as: issues
of who owns or is responsible for maintaining or repairing the LSL; how to gain access to private
property; and statutory and regulatory requirements that may impact cost recovery, especially for
replacement of the customer-owned portion of the LSL.
Despite these challenges, individual households and communities around the country have prioritized
LSLR and are proactively addressing the risk of lead in their water distribution system by developing and
executing full LSLR programs. The EPA is aware of many water systems with proactive LSLR programs
(EDF, 2019) and has been studying them to understand how water systems are overcoming challenges
to achieve full LSLR. While every community is different, the EPA finds that LSLR programs can be
structured in ways to overcome potential legal, financial, and practical challenges related to full LSLR.
Further the EPA estimated the number of full LSLRs, including customer-owned portions, that may occur
as a result of proposed LCRR enhanced public education and increased customer awareness regarding
LSLs.
Additionally, the EPA anticipates the proposed changes to the LCRR public education requirements will
build upon customer's willingness to allow the water system to access their property and perform a full
LSLR and increase customer interest in having their portion of an LSL replaced. These proposed
requirements will enhance transparency, risk communication, and public outreach and are anticipated
to increase public awareness of the risks associated with lead in drinking water and the benefits of full
LSLR.
3	The Current Rule only requires systems to replace the portion of the LSL that they own. Often, the system's
ownership stops at the homeowner's property line, and the homeowner's portion is not required to be replaced.
4	An LSL can "test out" if all samples from the LSL are at or below the lead AL. "Tested-out" LSLs are considered to
be replaced.
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2 Assessment of Projected Household Initiated Voluntary Lead
Service Line Replacement as a Result of Revisions to Public Education
The proposed LCR revisions include improvements to public education provisions, such as: (1) an
updated mandatory statement on health effects and added mandatory statement on LSLs in the
Consumer Confidence Report; (2) notification and provision of public education for households within
24 hours of exceeding the lead action level; (3) public access to an inventory of water system-owned and
customer-owned LSLs; (4) notification and provision of public education for households with an LSL,
including information on programs available to replace LSLs; (5) public outreach activities required for
systems that do not meet their annual LSLR goal; and (6) annual outreach by systems to state and local
health agencies that serve sensitive populations. By improving transparency, risk communication, and
public education and outreach, proposed revisions to the LCR are anticipated to increase public
awareness, increase rates of consumer-initiated LSLR, and further reduce sources of lead.
The impact of the proposed public education provisions on consumer-initiated LSLR, hereafter referred
to as voluntary LSLR, can be projected by examining the impact of past public education efforts.
However, there is a lack of literature evaluating LSLR in the context of public education. Given these
limitations, projections can also be estimated from studies of other, comparable risk reduction
behaviors. Risk reduction behaviors that share many similarities with voluntary LSLR include high-cost,
effective forms of radon and lead paint remediation. The behaviors are similar in that costs are
comparable5 (Riesenfeld et al., 2007; Zhang et al., 2011; HUD, 1990; USEPA, 2016a), the action that
reduces the health risk is generally a one-time behavior, actions are considered "home improvement"
measures, mitigation actions can occur at the point of home sale, and the health hazards are generally
"invisible" (USEPA, 2018; USEPA, 2016b; USEPA, 2016c).
The EPA conducted a literature review on risk reduction behaviors that are similar to voluntary LSLR and
have been evaluated in the context of health education interventions. Based on these findings, the EPA
provides 35-year projections of national voluntary LSLR with proposed revisions to the LCR public
education requirements. Lastly, the EPA presents a recommendation for projecting national voluntary
LSLR rates.
2.1 Methods
The EPA conducted a literature search to identify studies that evaluate the impact of health education
interventions on risk reduction behaviors similar to voluntary LSLR. These behaviors included high-cost
radon and lead paint remediation methods that are effective at reducing radon and lead levels in the
home. While remediation was the primary outcome of interest, the review also included studies on
related outcomes such as knowledge and testing to provide context, although these were not
considered in further analyses presented in this report. Studies were identified through PubMed, Google
Scholar, and the EPA Desktop Library. Key search terms included "public education," "campaign," "real
5 Cost ranges for effective forms of remediation include $800-$2,500 for radon remediation of a home (USEPA,
2010), $2,000-$ 12,000 for lead paint abatement of a home (HUD, 1990), and $2,500-$5,500 for full LSLR (USEPA,
2016a).
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estate disclosure," "radon," "lead paint," "remediation," and "mitigation." Relevant studies cited in the
identified literature were also reviewed.
After conducting the literature review, data was extracted on remediation rates measured in the
presence of health education interventions. These remediation rates were then used to project different
estimates of voluntary LSLR with the enhanced public education put forth in the proposed revisions to
the LCR over the next 35 years. These projections were extrapolated to the national level using
estimates of the number of lead service lines in the United States.
2.1.1 Literature Search and Study Evaluation
Twelve peer-reviewed studies evaluating risk reduction behaviors and related outcomes were identified
(see Exhibit 1. Summary of Studies Identified in Literature Search). All of the studies measured radon-
related outcomes. Ten of the studies assessed the impact of health education interventions on radon
knowledge, testing, and remediation. Interventions included several different sources of radon
information: traditional public education campaigns (Doyle et al., 1990; Desvousges et al., 1992; Wang
et al., 1999; Wang et al., 2000; Riesenfeld et al., 2007; Poortinga et al., 2011; Zhang et al., 2011; Bain et
al., 2016), primary care providers (Nissen et al., 2012), realtors (Doyle et al., 1990), and radon
notification policies (Neri et al., 2018). The remaining two studies assessed radon-related outcomes in
the absence of intervention (Ford & Eheman, 1997; Ryan & Kelleher, 1999). No studies measuring lead
paint remediation associated with health education were identified. General findings from the literature
included the following:
•	The general population frequently reports an awareness of radon as a problem; however,
understanding of radon risk is lacking (Doyle et al., 1990; Nissen et al., 2012).
•	Of those aware of radon, rates of home radon testing are generally low (Doyle et al., 1990; Ford
& Eheman, 2007); however, testing rates are higher when performed at the point of home sale
(Doyle et al., 1990; Riesenfeld et al., 2007).
•	When residents are informed of high home radon levels, remediation rates are generally low
(Doyle et al., 1990; Riesenfeld et al., 2007; Nissen et al., 2012).
•	Primary barriers to remediation are cost (Wang et al., 1999; Ryan & Kelleher, 1999; Riesenfeld et
al., 2007), low perceived radon risk or a lack of concern over high radon test results (Doyle et al.,
1990; Wang et al., 1999; Riesenfeld et al., 2007; Nissen et al., 2012), indecision (Ryan & Kelleher,
1999), and perceived complexity of radon remediation (Doyle et al., 1990).
Of the ten studies evaluating the impact of health interventions, four studies specifically measured
radon mitigation, the primary outcome of interest, and were considered in projecting voluntary LSLR.
These included studies evaluating radon remediation levels among households exposed to the following
interventions: a public education campaign in Washington DC (Doyle et al., 1990), a public education
campaign in New York (Wang et al., 1999), a testing and outreach program in Vermont (Riesenfeld et al.,
2007), and real estate disclosure in Boulder, Colorado (Doyle et al., 1990). Studies with the largest
sample sizes were preferred for projecting voluntary LSLR. Therefore, subsequent analyses used the two
studies that evaluated public education campaigns in Washington DC (Doyle et al., 1990) and New York
(Wang et al., 1999). The selected studies and projections are described below.
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Study Summary: Public education campaign in Washington DC: "An Evaluation of Strategies for
Promoting Effective Radon Mitigation" (Doyle et a!., 1990)
Doyle et al. (1990) studied the success and effectiveness of an intensive mass-media radon information
and awareness program in Washington DC, a high radon area. The health intervention included a mass-
media campaign which consisted of printed advertisements in newspapers, public service
announcements on television, and discounted radon test kits. The campaign was conducted in January
and February of 1988 and was evaluated at the end of the same year. The campaign resulted in 100,000
test kits purchased and 55,830 test kits completed and returned to obtain test results (55% of total tests
purchased). These results represent 6.5% of the Washington DC population estimated to have home
radon levels above the EPA action level of 4 pCi/L. A sample of households who participated in the
program who returned radon test kits were mailed paper surveys to assess radon knowledge, testing
results, and mitigation behaviors. A stratified random sampling design was used to survey 1,000
households equally distributed across 4 radon levels (<4, 4-20, 20-50, and >50 pCi/L); due to loss of
useable addresses, a total of 920 households were surveyed (<1% of total test kits purchased). The
response rate was approximately 77%.
Doyle et al. (1990) evaluated the results of the program as a multi-stage process characterized by
transition rates from initial awareness of radon risk, buying a test kit (testing uptake), performing and
returning the test, and mitigation. Those who claimed mitigation reported a variety of mitigation
methods ranging from opening a basement window (low-cost) to hiring a certified professional to
perform mitigation such as sub-slab depressurization (high-cost). While low-cost mitigation methods are
not reliable for effectively eliminating the threat of radon, high-cost methods conducted by a certified
professional are more effective. Doyle et al. (1990) addressed this issue with self-reporting by
differentiating between "claimed" and "confirmed" mitigation, where confirmed mitigation referred to a
remediation method that effectively reduced home radon levels. This was determined based on
whether remediation was conducted by a certified professional and/or through radon retesting
following remediation to confirm radon levels had been reduced.
Of the 920 households, 73% tested above the EPA action level and 1.2% claimed mitigation. Of the 1.2%
of households that claimed mitigation, one-third (0.4%) retested to confirm mitigation was effective.
Survey results were extrapolated to absolute population estimates of the entire pool of single-family
homes in the Washington DC area predicted to have radon levels over the EPA action level. Of the
933,630 single-family homes, Doyle et al. (1990) predicted 381,714 single-family homes would require
mitigation and 376 homeowners would complete effective radon remediation. Based on this
extrapolation, less than 0.1% of all households needing radon mitigation would successfully mitigate and
reduce home radon levels.
Analysis
The 0.1% annual rate of confirmed mitigations for homes which require radon remediation in the
Washington DC area can be used to project estimates of voluntary LSLRs in the Washington DC area and
nationally due to increased public awareness from proposed updated public education provisions of the
LCR. The 0.1% confirmed mitigation rate can be considered a multiplier (0.001) which can be applied to
the total pool of LSLs in the Washington DC area and nationally. The estimated number of LSLs present
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in the Washington DC area is approximately 48,000 (Government of the District of Columbia, 2018), and
the national estimate of LSLs ranges from 6.1 million (Cornwell et al., 2016) to 10 million (USEPA, 1991).
For the Washington DC area, this results in 48 voluntary LSLRs estimated to occur per year, or
approximately 1,680 voluntary LSLRs in the next 35 years. Nationally, this results in approximately 6,100
to 10,000 voluntary LSLRs estimated to occur annually, or approximately 213,500 to 350,000 voluntary
LSLRs in the next 35 years. An example of this calculation is 0.001 x 6.1 million LSLs x 35 years = 213,500
LSLs.
Study Summary: Public Education Campaign in New York: "Radon Mitigation Survey among New
York Residents Living in High Radon Homes" (Wang et al., 1999)
Beginning in 1987, the New York State Department of Health (NYSDOH) launched a campaign to
increase radon awareness, testing, and remediation in accordance with the EPA's 1986 radon guidelines
(Wang et al., 1999; USEPA, 1992). To evaluate the effectiveness of the program, Wang et al. (1999)
conducted a cross-sectional telephone survey to measure rates of radon remediation among high radon
homes6 in New York that had been exposed to NYSDOH's campaign efforts. Drawing their sample from
the NYSDOH database of radon testing results, Wang et al. (1999) selected all homes with radon levels
greater or equal to 370 Bq/m3 and used stratified sampling by county to select homes with radon levels
greater than 148 Bq/m3 but less than 370 Bq/m3 (n=l,522). Of the 1,522 households contacted, 1,113
completed the survey (73% response rate). Wang et al. (1999) found that 60% (665 of 1,113) of
households participating in the study reported taking remedial action. Specifically, 32% (356 of 1,113)
reported installing a powered ventilation system while 26% (294 of 1,113) reported either opening
windows and doors (5.2%; 58 of 1,113) or sealing cracks and openings (21%; 236 of 1,113) (Wang et al.,
1999). This meant that 32% of participants were willing to engage in a higher cost, more complex and
effective form of radon remediation while 26% reported using a lower cost, simpler but less effective
method.
Analysis
Based on the 32% of surveyed homes that reported performing high-cost radon mitigation in Wang et
al.'s (1999) study, and the eight-year period over which NYSDOH's radon education efforts had been
active, the EPA calculated a rate of 4% of high radon homes in the study mitigating per year of the
program. Given there were approximately 2,932 high radon homes in New York according to NYSDOH's
testing database at the time of the study, this corresponds to approximately 1.5% of high radon homes
in New York remediating per year with exposure to NYSDOH's radon campaign (Wang et al., 1999).
Using this 0.015 annual radon remediation rate to project voluntary LSLR with enhanced public
education and given that there are approximately 360,000 LSLs in New York (Cornwell et al., 2016), it is
estimated that 5,400 LSLs would be replaced per year. At this rate, 189,000 LSLs in New York would be
replaced over 35 years. Extrapolating these values to the national level, approximately 3.2 to 5.25
million LSLs of the total 6.1 to 10 million estimated LSLs in the United States (Cornwell et al., 2016;
USEPA, 1991) would be replaced in that 35-year period.
2.2 Results
6 Radon levels greater than or equal to 148 Bq/m3, or 4 pCi/L, on the first floor or above (Wang et al., 1999).
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The EPA conducted a review of the literature to estimate projections of voluntary LSLR with proposed
revisions to the LCR public education requirements. High-cost radon remediation was identified as a
relevant risk reduction behavior that has been evaluated in the literature on health education. These
risk reduction behaviors are similar in that a homeowner may choose between a low-cost and high-cost
method to mitigate an environmental health risk in the home. If a homeowner becomes aware that
their residence is serviced by an LSL as a result of proposed revisions to the LCR public education
requirements, the homeowner may choose a low-cost option to reduce lead levels at the tap such as a
point-of-use device or pitcher filter, or a higher cost option of replacing the LSL. These low-cost options
are effective at removing lead at the tap; however, they do not remove the source of lead
contamination (the LSL). Similarly, low-cost options for radon reduction include opening windows and
installing a fan in a basement window; however, these methods do not effectively eliminate or reduce
radon from entering a home. In contrast, higher cost forms of radon remediation such as sub-slab
depressurization are more effective at reducing radon levels and therefore were found to be more
suitable for estimating voluntary LSLR projections.
Projections of voluntary LSLR were estimated from two studies evaluating the impact of public
education campaigns on radon remediation in the United States: Doyle et al (1990) and Wang et al.
(1999). When making estimates from the Doyle et al. (1990) study, confirmed (effective) mitigation rates
for homeowners were used for projecting rates of voluntary LSLR. This provided a method to measure
effective radon mitigation which is most relevant to LSLR, whereas self-reported (claimed) mitigation
rates, which may include low-cost, less effective actions, may inflate the number of remediations which
effectively reduce radon in the home. This highlights the importance of using confirmed mitigation rates
for projecting voluntary LSLR, which Doyle et al. (1990) provide. The target audience of the radon health
education campaign in the Washington DC area and subsequent surveys were single-family
homeowners; similarly, the intended audience for LSLR are consumers, usually homeowners, who are
willing and able to pay the cost of a full LSLR. However, in most communities, LSLs are partially utility-
owned and partially owned by the homeowner. Doyle et al. (1990) did not specify if the full cost of
radon remediation was the burden of the homeowner; therefore, remediation cost may have been
subsidized. To estimate the voluntary LSLR projection, the EPA assumed the full cost of radon
remediation was paid for by the homeowner; however, this may result in an underestimation of the
total number of full LSLRs initiated by a homeowner as funding sources may be available to offset the
full cost of replacement, such as: water systems using rate payer revenue; using federal, state, and local
grant and loan programs; and using special assessments, tax levies, and surcharges.
Projecting voluntary LSLR from the Wang et al. (1999) study resulted in a higher estimated remediation
rate as compared to the rate predicted from the Doyle et al. (1990) study. Although Wang et al. (1999)
did not directly measure the impact of NYSDOH's extensive radon campaign, the large proportion of
surveyed homes exposed to the campaign that reported engaging in radon remediation (60%), and
specifically high-cost remediation (32%), suggests that it is a contributing factor (Wang et al., 1999). The
projected LSLR rate was calculated using the percentage of households specifically undergoing high-cost
remediation (defined in the study as installation of a powered ventilation system), rather than the rate
of overall remediation which includes low-cost, less effective methods in order to more closely
approximate the cost burden of voluntary LSLR. A unique feature of the Wang et al. (1999) study that
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distinguishes it from the study by Doyle et al. (1990) was that over a quarter of the respondents were
enrolled in a radon diagnostic assistance program which provides eligible homeowners with up to $300
of financial assistance towards radon mitigation (n=297 of 1,113). Because this reduces the number of
households who experience cost as a barrier, this may have inflated the rate of high-cost radon
remediation, thereby overestimating the rate of voluntary LSLR. However, the proposed LCR revisions
include provisions for focusing resources on LSLR, thereby lowering the cost on the homeowner.
Therefore, this factor alone does not necessarily limit the study's suitability for projecting LSLR.
Additionally, the sample was comprised predominantly of homeowners (n=l,091 of 1,113), while only
22 participants were renters and were significantly less likely to report high-cost mitigation. This may
have contributed to a larger remediation rate. However, homeowners also represent the target
audience of public education around voluntary LSLR. The high remediation rates reported by Wang et al.
(1990) may also reflect a potentially more proactive sample relative to the general population, in that all
study respondents had requested a radon detector from NYSDOH for a small fee in the past. While
NYSDOH's campaign likely also encouraged homeowners with high radon levels to obtain a radon
detector, the fact that the study sample was selected from this pool may reduce its applicability for
projecting voluntary LSLR.
The EPA used the confirmed and effective radon mitigation rates from the Doyle et al. (1990) study to
estimate a national 35-year voluntary LSLR projection (213,500-350,000 projected LSLRs). The evaluation
of the radon public education campaign presented in Doyle et al. (1990) provides confirmed radon
remediation rates which represent the most analogous health risk reduction behavior to LSLR identified
in this research. As compared to the self-reported rates of high-cost radon mitigation measured in Wang
et al. (1990), confirmed mitigation rates are more accurate at estimating frequencies of radon mitigation
that successfully reduce radon in the home. The mitigation rates reported by Doyle et al. (1990) are
either confirmed through retesting to verify the mitigation was successful or consist of mitigations
performed by a professional contractor. The EPA prefers to estimate national voluntary LSLR projections
based on remediation rates from Doyle et al. (1990) as these estimates represent confirmed mitigation
rates and the study is cited in nearly all published and peer-reviewed research assessing the efficacy of
health education campaigns focusing on radon risk reduction and remediation.
The EPA is proposing changes to the public education requirements in the proposed LCRR which
enhance transparency, risk communication, and public outreach. These proposed revisions are
anticipated to increase public awareness and support informed decision making, and thereby increase
customer willingness to pay for LSLR and result in customer-initiated LSLR efforts. To estimate the
number of consumer-initiated LSLRs associated with improvements to LCRR public education, the EPA
investigated the efficacy of health education campaigns on comparable risk reduction behaviors. Based
on this analysis, the EPA projected approximately 213,500 to 350,000 voluntary, customer-initiated
LSLRs to occur in the United States in the next 35 years. It is also expected that customer willingness to
pay for water system-initiated LSLR would increase.
2.3 Uncertainty
Projecting voluntary LSLR based on studies of other risk reduction behaviors involved several limitations
and assumptions. The EPA's voluntary LSLR projection estimates will vary from the actual number of
consumer-initiated LSLs replacements rates as the assumptions and limitations detailed below introduce
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a variety of unquantified uncertainties that will result in over- and under- estimation of the projections.
First, it is important to note that all the projections were based on studies of radon remediation. While
some relatively more expensive forms of radon remediation are comparable to LSLR in terms of cost,
there are differences between these two behaviors that may differentially affect people's willingness to
remediate. For example, there may be greater awareness and perceived risk around lead than radon
(Doyle et al., 1999). This may particularly be the case given ongoing events and media attention relating
to lead-contaminated drinking water across the United States, most notably in Flint, Michigan.
Conversely, LSLR may be perceived as more complex than comparatively high-cost radon remediation.
Given these differences, it would have been helpful to develop estimates based on a more diverse array
of risk reduction behaviors comparable to voluntary LSLR, particularly those involving lead, such as lead
paint removal. However, no other studies were identified in this review. Despite this limitation, cost is a
significant structural barrier to risk reduction that lends support to using radon remediation to estimate
voluntary LSLR.
The projections are also limited by the age of the studies applied in the analyses, which were twenty to
thirty years old. Given improvements in risk communication and development of health promotion
programs, as well as the growth of the internet and social media to increase information access and
exchange in the past thirty years, these estimates may underestimate the impact of health education on
voluntary LSLR. While more recent studies were identified in the review, they measured levels of
awareness and testing, but not remediation. There was one study conducted in the past fifteen years
that measured remediation with health education (Riesenfeld et al., 2007); however, the sample size
was much smaller than those in the selected studies. More research is needed in this area. Despite the
lack of recent data identified in this review, the Doyle et al. (1990) study remains one of the most cited
works in the literature on interventions promoting radon remediation.
In order to project voluntary LSLR from the Doyle et al. (1990) and Wang et al. (1999) studies, many
assumptions were made. Making these projections involved assuming that the success of the
Washington DC and New York radon health education campaigns would be comparable to the success of
the public education requirements of the proposed LCR revisions, in spite of programmatic differences
existing between the three. Moreover, there are external validity concerns with generalizing results
from Washington DC or New York to the entire United States which is substantially larger and more
diverse in terms of the geographic distribution of LSLs and lead risk exposure, access to resources and
economic power, as well as the relationship and dynamics of engagement between communities, water
systems, and states.
Additionally, it was assumed that living in a high radon area and the associated radon exposure risk were
analogous to the presence of an LSL and associated lead exposure risk. However, properties with LSLs
are systematically different from properties with high radon levels. The 1986 Amendments to the Safe
Drinking Water Act banned the use of LSLs and states were required to implement the ban in 1988;
therefore, LSLs are most commonly connected to older single-family homes and properties. In contrast,
radon arises naturally from the soil beneath a property's foundation, and the age of the property does
not affect radon levels. Not accounting for differences in property characteristics introduces uncertainty
into the voluntary LSLR projections given that high-cost home improvement renovations often occur at
the point of home-sale. The voluntary LSLR projections using the Doyle et al. (1990) and Wang et al.
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(1999) studies do not account for such variation in property characteristics and whether mitigation
occurred during a real estate transaction.
To estimate voluntary LSLR from the Doyle et al. (1990) study, the EPA made several assumptions.
Because the duration of the intensive mass-media campaign was less than a year, the 0.1% confirmed
remediation rate is valid for a short, one-time public health campaign. To calculate a 35-year projection
of voluntary LSLR, the rate is assumed to have an impact beyond one year and a constant annual impact
for 35 years. Making projections from the Wang et al. (1999) study involved several assumptions of its
own. An eight-year exposure period to the radon public education campaign was assumed based on the
campaign beginning in 1987 and the survey being administered in 1995; however, survey respondents
may not have been exposed for the full campaign period. As a result, this approach may underestimate
the radon remediation rate and, therefore, projected voluntary LSLR.
When making projections from both studies, the effect of the campaign and radon remediation rate
were assumed to remain constant over the campaign period. However, the effectiveness of the
campaign may have varied over time, along with other factors which could in turn affect the radon
remediation rate, resulting in an over- or under-estimate of projected voluntary LSLR. Similarly,
sustained public interest in removal of LSLs was assumed, which could either over- or under-estimate
the LSLR rate. It was also assumed in both analyses that the national or state estimate of LSLs does not
incrementally decrease annually, resulting an in an overestimate of the projected LSLR rate.
Furthermore, there is significant uncertainty in developing a national LSL estimate as few community
water systems have an accurate count of the total number of LSLs in their distribution system.
In addition to the limitations of the projections and studies selected, there were also limitations to the
literature review. Because this was not a systematic review, studies may have been missed that would
have been useful for projecting voluntary LSLR. There may have also been other risk reduction behaviors
comparable to voluntary LSLR that were not identified in this literature search.
In spite of these limitations, these estimates project increases in voluntary LSLR over the next 35 years
with the proposed LCR revisions. Given the limited literature that are available on voluntary LSLR, basing
projections on similar risk reduction behaviors that have been evaluated with health education helps the
EPA to estimate the impact of the proposed LCR revisions.
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3 Challenges of Establishing LSLR Programs: Ownership, Control,
and Access
In many communities, LSLs are partially owned by the water system and partially owned by the
customer. The portion of the service line that the PWS owns is typically the portion of the line from the
water main to the property line, although some systems use the water meter or the curb stop (which
are not necessarily at the property line) as the point of reference for ownership. In addition: (1)
ownership of the real property on which the service line is located does not always determine
ownership of the service line, and (2) ownership of the service line or of the real property on which the
service line is located may not be the only indicator of who is responsible for the repair and replacement
of the service line. This is because in many cases, the utility retains the authority to access and maintain
the customer-owned portion of the service line although the expense of performing the work is placed
on the property owners. The details (e.g., who owns the line, who is responsible to maintain or repair it,
who is responsible for the costs of the maintenance, repair and replacement) are usually spelled out in
the local water utility tariff (i.e., water rate) and will vary among PWSs and communities.
To complete full LSLR the water system may, in many cases, need to identify the current owner of the
service line, secure permission for the work, schedule services, and gain access to the interior of a
building. Many PWSs and States have mechanisms to overcome the issues of ownership, control and
access including securing express consent of the owner, instituting mandatory LSLR or through
regulatory authorities that provide PWSs with access to customer-owned LSLs.
3.1 Consent of the Customer
In many instances, the PWS may have the right to access private property for certain activities, such as
inspection or monitoring, which are typically granted in state or municipal codes. LSLR and its associated
activities (digging, construction, impacting surrounding property) could be covered by the general
maintenance activities included in the tariff. However, it is possible that access rights for LSLR are not
specifically authorized by the tariff, or that the tariff does not clearly establish these access rights for
LSLR. In those cases, the water system may seek to obtain voluntary consent from the customer to
conduct full LSLR. The following examples show how some water systems sought consent to undertake
their LSLR programs.
• In Flint, Ml, where ownership of the LSL is split between the city and the customer, the city had
to obtain homeowner consent to conduct full LSLR. The city utilized volunteers from the AARP to
mail consent cards and go door-to-door to obtain a signature from the owner (and the tenant in
a rented unit) to gain permission to replace the LSL. Identifying and tracking down customers,
however, sometimes presented logistical challenges. Securing permission and locating absent
owners increased the time needed to complete the LSLR project (Derringer, 2016). There is also
an online opt-in form granting the City permission to conduct full LSLR on the City of Flint's Fast
Start website. The website shows that as of September 6, 2019, Flint has successfully replaced
approximately 9,200 LSLs with less than 900 left to replace, so the city has shown overall success
in obtaining consent from homeowners to conduct LSLR (City of Flint, Ml, 2019).
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•	The Lansing, Ml Board of Water and Light (BWL) bought the customer-owned service lines from
homeowners and building owners in 1927 to address extensive leakage issues (Gell and
McEntire, 2016). Despite owning the whole service line, BWL still had to seek permission from
the homeowner to complete its full LSLR program. The BWL's "Rules and Regulations for Water
Service" state that the "Customer Water Service shall be furnished, installed, owned and
maintained by the Board" (Water Rule and Regulation 11, Lansing BWL, 2015)7. The rules also
require that customers "provide and maintain appropriate access and working space" around
service lines and other BWL-owned water facilities, and they authorize BWL personnel to access
infrastructure on customers' property as necessary (Water Rule and Regulation 4, Lansing BWL,
2015). Even with this authority, however, water system personnel required permission to enter
residents' basements to disconnect the LSL from the meter and connect the new copper line
(Clark, 2016). To ensure consent would be obtained by all customers, BWL conducted a multi-
component outreach program to educate city residents about LSLs and promote coordination
with customers (Hamelink et al., 2016; Lansing BWL, 2016). While there were some instances of
coordination and scheduling problems, for the most part, the LSLR was welcome and BWL did
not have to enforce access rights. The last LSL in Lansing was removed in December 2016
(Lansing BWL, 2016).
The EPA is aware of several other successful LSLR programs where customer consent was required to
conduct the full LSLR (EDF, 2019; and "LSLR Rate Analysis" in the LCRR docket under EPA-HQ-OW-2017-
0300 at https://www.regulations.gov). While the approach of obtaining customer consent can
sometimes present challenges from individual homes, the EPA is not aware of any LSLR program where
it has proved to be a major or widespread impediment to the overall success of the program. Customer
consent could be obtained more efficiently by combining it with water utility bills or other mailers,
obtaining consent by phone, during an in-person lead service line inventory inspection, or by coupling it
with other infrastructure work.
3.2 Mandatory LSLR
In contrast to LSLR programs structured around a customer voluntarily agreeing to full LSLR, some
communities have instituted LSLR programs which require the customer to replace their portion of the
LSL. Under this scenario, consent by the individual customer is not sought since the community
determined this action was needed by municipal ordinance. While the ordinance itself could specifically
grant private property access to the water system, it could also require the customer to hire a licensed
contractor to perform the work, eliminating the need for the water system to access private property.
•	The Madison Water Utility in Wisconsin, for example, required customers to replace their
portion of the LSL with a private contractor while the water system simultaneously replaced the
water system-owned portion (MGO, 2000). Non-compliance with the ordinance resulted in a
fine of $50-$l,000 per day. The water system referred non-compliant customers to the city
7 The Lansing BWL's Rules and Regulations for Water Service define "customer water service" as "those pipes,
valves and appurtenances owned and maintained by the Board installed between a Water Main and Customer
Piping."(Water Rule and Regulation 11, Lansing BWL, 2015).
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attorney's office. The water system was able to replace all LSLs in the distribution system
(Madison Water Utility, 2019).
•	The Cincinnati City Council passed ordinances in 2016 and 2017 requiring the Greater Cincinnati
Water Works (GCWW) to develop and implement an LSLR program to replace the remaining
LSLs (both water system-owned and customer-owned) in the city within 15 years, or
approximately 7% per year. Customers must either participate in the water system's LSLR
program in which the water system would cover 40 percent of the cost, or customers must hire
a plumber who is certified with GCWW to replace the LSL. Customers must decide how they will
replace their portion of the LSL within 30 days after receiving notice from GCWW that they are
required to replace the LSL (GCWW, 2018; EDF, 2019).
•	Milwaukee, Wl's mandatory LSLR program requires customers to replace customer-owned LSLs
if a leak is detected in the LSL or if the water system-owned portion is removed on a planned or
emergency basis and prohibits the repair of any LSLs and any reconnection of a customer-owned
LSL to the city's system. The city is required to notify the customer in the event of a leak or
failure and must provide notice at least 45 days before the commencement of a planned
replacement of the water system-owned LSL. Upon receipt of notice, the customer has 10 days
to either replace the LSL by contracting with a licensed contractor or authorize the city
contractor to replace their portion of the LSL. Access to private property is not an issue as the
homeowner can either use a licensed contractor or provide consent to the city contractor to
replace the customer-owned LSL. Those that use the city contractor must sign a hold-harmless
agreement freeing the city from liability for damage done in performance of the LSLR and sign a
temporary right of entry and construction entry (Milwaukee, 2016). Fond du Lac, Wl and several
other Wl municipalities have an ordinance like Milwaukee's, where the homeowner must
replace the customer-owned LSL with a hired contractor or give consent to city contractors to
replace it (LSLR Collaborative).
There are also mandatory LSLR programs in which the system is required to replace both water system-
owned and customer-owned LSLs. However, full replacement may still be contingent upon the
customer's consent.
•	The State of Michigan recently updated their State LCR with a mandate that water systems
proactively replace five percent of their LSLs each year. While the regulation requires the water
system to fully finance and conduct both the water system-owned and customer-owned LSLR,
customers are allowed to refuse the LSLR. In that case, the water system must not conduct a
partial LSLR, leaving the full LSL intact (Ml DEQ, 2017b). Since Michigan's mandatory LSLR
requirement applies to the water system, not to the customer, the water system can offer the
LSLR to another customer in its distribution system who is served by an LSL to meet its
replacement target.
3.3 State and Local Authority to Enter Granted Through Regulation
Some states and municipalities provide the water system with the authority described in the tariff to
enter private property for the purposes of inspection, monitoring, or to determine compliance with
State drinking water standards. Potential limitations to this authority could include: (1) LSLR activities
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may not necessarily be covered by this right to enter authority; (2) in some states, the right to enter for
the specifically stated purposes is limited to the property owned or controlled by the PWS; and (3) the
state may need to secure a court issued warrant if access is denied. While it is possible that a state or
municipality may grant the water system access rights to conduct the LSLR, there are several examples,
as mentioned in the previous section, where the customer hires a contractor to perform the work on
private property, avoiding the need for the water system to gain access to the private property.
One approach to the issue of access is a short-term approach taken by Milford, MA. The Milford Water
Company amended the Company's Rules and Regulations so that customer-owned LSLs, while otherwise
the responsibility of the customer, will be replaced by the Company (at the Company's expense), but
only for a finite period. After this period, the responsibility and the cost of maintaining the service line
would presumably return to the customer. The revised Department of Public Utilities (DPU) Rules and
Regulations, M.D.P.U. No. 22-4(c) state that:
Service pipe from the curb valve to the customer's premises will be maintained by the customer
at his expense and in a manner satisfactory to the Company;... and provided further, that for
the period of January 1, 2017 through and including December 31, 2018, the replacement by the
Company of any portion of the service pipe which contains materials other than copper, steel or
plastic shall be at Company expense for the first one hundred (100) feet from the curb valve.
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4 Assessment of Projected Community Lead Service Line
Replacement Programs as a Result of Availability of Low Cost Federal
Funds
The EPA supports states and cities in fully utilizing the suite of funding and financing options provided by
the federal government to address lead in drinking water. The Drinking Water State Revolving Fund
allows states to finance high priority infrastructure investments, including the replacement of lead
service lines to protect human health. In FY 2018, the Water Infrastructure Finance and Innovation Act
(WIFIA) loan program invited 39 projects in 16 states and Washington, D.C. to apply for loans totaling up
to $5 billion to help finance over $10 billion in water infrastructure investments. 12 of these projects are
to reduce lead or other contaminants in drinking water. In FY 2019, the EPA once again prioritized
projects that reduce exposure to lead when announcing the availability of $6 billion for new WIFIA
loans. Additional opportunities to fund full LSLR include the EPA's Water Infrastructure Improvements
for the Nation Act grant programs and HUD's Community Development Block Grants.
The Drinking Water State Revolving Fund (DWSRF) has funded numerous water system infrastructure
projects, including lead service line replacement (LSLR). To better understand the effect of the DWSRF
on LSLR, the EPA estimated the number of proactive and compliance-based LSLR that may be funded by
DWSRF over a 35-year period. The EPA found that over this timeframe, approximately 149,200 full LSLR
are expected to occur using DWSRF funding in part or in whole with approximately 9 percent of funds
being used for proactive LSLR.
Although additional EPA funding mechanisms exist to fund full LSLR, the Water Infrastructure Finance
and Innovation Act (WIFIA) and America's Water Infrastructure Act (AWIA) grant programs are newer
programs, and there is not data available to estimate future LSLR demand. Thus, the estimate presented
by this analysis will undercount the number of LSLRs that will occur in practice as a result of
longstanding EPA funding and financing mechanisms. Furthermore, other federal funding programs,
such as the Department of Housing and Urban Development's (HUD) Community Development Block
Grants (CDBG) have been used for full LSLR, however the EPA lacks the data required to project future
LSLR from other federal sources.
4.1 Background
The DWSRF program was created as part of the 1996 Amendments to the Safe Drinking Water Act
(SDWA). The DWSRF is structured as a federal-state partnership through which a permanent drinking
water infrastructure revolving loan fund has been created in every state. The federal government
provides capitalization grants to states. States provide a 20% match for those grants. The principal
objective of the DWSRF is to facilitate compliance with national primary drinking water regulations or
otherwise significantly advance the public health protection objectives of the SDWA. States are required
to give priority for the use of DWSRF project funds to:
*	address the most serious risks to human health;
*	ensure compliance with the requirements of the SDWA; and
*	assist systems most in need on a per household basis according to state affordability criteria.
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In 2011, the EPA asked the Science Advisory Board (SAB) to evaluate the current scientific data on partial
LSLR. The SAB concluded that partial LSLRs have not been shown to reliably reduce drinking water lead
levels in the short-term of days to months, and potentially even longer (USEPA, 2011). The Lead and
Copper Rule Revisions (LCRR) emphasize full LSLR over partial LSLR. In 2016, the EPA issued a memo
clarifying the DWSRF funds can be used to fund full LSLR including replacement of the customer-owned
portion of the LSL (USEPA, 2016). The EPA is aware of several public water systems that are utilizing
DWSRF to fund full LSLR in full or in part (USEPA, 2019). For example, Green Bay, Wl is using DWSRF
principal forgiveness funds, in addition to local funding raised from their stadium tax, to subsidize
customer replacement of their LSL. The EPA estimated the demand for DWSRF funds and the associated
number of LSLR in the next 35 years.
4.2 Methods
The EPA queried DWSRF project descriptions for relevant keywords, such as "service line," and compiled
the resulting 217 DWSRF applications (see attached "Future LSLR from SRF.xIsx"). The EPA categorized
the project descriptions for lead service line replacement activities as follows:
•	Project descriptions that explicitly mention LSLR.
•	Project descriptions that may involve LSLR.
•	Project descriptions that likely do not involve LSLR.
In developing the projection, the EPA only included DWSRF projects with an initial loan date of 2016 or
later. The EPA's Office of Groundwater and Drinking Water issued a memo in 2016 that clarifies DWSRF
funds can be used for replacement of the customer-owned portion of LSLR. This clarification creates a
new baseline from previous DWSRF utilization as it expands the universe of LSLs that can be replaced
with DWSRF funding and facilitates full LSLR.
The EPA assumed that all LSLs were fully replaced. In some cases, the DWSRF project description stated
that SRF funds would be used to assist the customer in replacing their portion of the LSL. The proposed
LCR revisions include a provision that would require the water system to remove the portion of the LSL it
owns when the customer-owned portion is replaced, resulting in full LSLR. It is also possible that the
water system-owned portion was never made of lead or has been partially replaced by the water system
in the past. Under these circumstances, replacing just the customer portion would result in a full LSLR.
The DWSRF project descriptions sometimes described that the funding would apply to the water
system-owned portion only. The EPA assumed full LSLR given the recent knowledge of the dangers of
partial LSLR and reasonable scenarios of how a full replacement could take place. For example, the
customer portion of the LSL may not be made of lead or may have already been replaced. Alternatively,
if the customer portion is an LSL, various funding and financing strategies have been demonstrated
across the country, which could fully fund or subsidize the customer-owned LSLR. For example, some
systems have used rate revenue, or the customer could pay full or a subsidized cost for the replacement
through a different grant or loan program. The proposed LCR revisions includes enhanced public
education to consumers served by an LSL, which could increase the likelihood that customers will be
willing to replace their LSL. For these reasons, when DWSRF is used for replacement of the water
system's portion, the EPA assumes the LSL will be fully replaced. Finally, where the DWSRF project
description did not specify ownership, the EPA assumed that the LSL would be fully replaced, for these
same.
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To estimate the number of LSLR from each project, the EPA examined the project description and the
loan or grant amount. Some project descriptions explicitly state how many LSLs would be removed using
the funding. If the project description did not provide a number of LSLRs, the loan or grant amount was
divided by the average unit cost of a LSLR to calculate the expected number replaced.
The EPA took the average of the number of full LSLR included in DWSRF applications in 2016, 2017, and
2018 to determine the average annual DWSRF utilization for LSLR. This rate was multiplied by 35 to
calculate the total number of LSLR that could occur from DWSRF over a 35-year timeframe.
To determine if the funds would be used for proactive LSLR, the EPA determined whether the water
systems using SRF for LSLR had exceeded the lead action level within two years of their DWSRF loan
application. If so, the EPA assumed that the DWSRF funding was being used for rule compliance
purposes. Otherwise, the EPA assumed proactive LSLR was conducted.
4.3	Results
The analysis (refer to "Analysis of SRF for LSLR" in the LCRR docket under EPA-HQ-OW-2017-0300 at
https://www.regulations.gov)). estimates that 149,200 lead service line replacements could occur from
DWSRF funds in the next 35 years. This represents 1.5-2.4% of the estimated 6.1 million to 10 million
LSLs nationwide. It is estimated that approximately 9% of the DWSRF funding is being used for LCR
compliance purposes, while the remainder funds proactive LSLR.
4.4	Uncertainty
The EPA analysis included LSLRs only when they were not coupled with other infrastructure work, unless
the project description explicitly stated the number of LSLs replaced. The EPA took a conservative
approach of excluding these LSLR from the analysis, which may result in an under estimation of full
LSLRs due to DWSRF funding. It is also possible that DWSRF projects that only listed work such as main
replacements would incidentally remove LSLs without explicitly describing LSLR in its project description,
which would also result in an under estimation.
The EPA assumes sustained interest in LSLR over thirty-five years. As proposed, the LCR revisions
include provisions such as publicly-available LSL inventories and improved public education, which is
expected to sustain demand for full LSLR over time. The EPA did not include a coefficient to increase or
decrease the rate of DWSRF utilization for LSLR over the 35-year period of analysis. It is possible that
EPA funding resources decrease over time, or that interest in LSLR decreases or competes with funding
for other priorities.
As proposed, water systems that exceed the lead trigger level or lead action level would be required to
remove LSLs as part of a goal-based or mandatory program. It is estimated that the proposed rule will
result in 146,000 mandatory full LSLR and 240,000 goal-based full LSLR, or an additional 97,000 and
240,000 LSLR from the current LCR over 35 years. While the EPA is aware of several water systems
using SRF funds for proactive LSLR, a few are using SRF for compliance with the LCR. The EPA's estimate
of DWSRF utilization for LSLR likely includes both proactive and compliance-based LSLR, however it is
unknown what percentage of the estimate is proactive versus compliance-based.
The EPA conducted a separate estimate of future LSLR that may result from improved lead public
education (see Section 2, "Assessment of Projected Voluntary Lead Service Line Replacement with
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Health Education"). The analysis is based on efficacy of public education in compelling homeowners to
implement radon remediation, to estimate the number of homeowners that would have their LSL
replaced. The study used as a basis for this analysis (Doyle et al.,1990) did not account for subsidized
homeowner radon remediation. Because DWSRF provides subsidization for LSLR, in whole or in part, it
is expected that more LSLR will occur than estimated from the radon study assumptions. While there is
likely to be some overlap between the two estimates (i.e., customers who are willing to pay full cost for
LSLR but utilize DWSRF subsidy offered by their water system), the EPA expects these two estimates to
be mostly additive, however it is unknown to what extent.
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5 Financing Full LSLR
The EPA has estimated an average cost of full LSLR of $4,700, ranging from $1,200 to $12,300 per line
replaced (see Chapter 5 of the LCRR EA, docket number EPA-HQ-OW-2017-0300 at
https://www.regulations.gov). As PWSs work to develop and implement LSLR programs, they have
continued to find ways to fund and/or recover costs from LSLR in their communities. As further
described below, PWSs have been using rate payer revenue; using Federal, State, and local grant and
loan programs; imposing special assessments, tax levies, and surcharges; and finding other, creative
ways to help fund LSLRs.
Ownership can also impact funding sources and cost recovery mechanisms for full LSLR that are
available to a PWS. The ownership structure of the PWS may affect whether the PWS can use rates to
cover the costs associated with LSLR programs (e.g., privately owned systems may be limited by public
service agency regulations), the process by which the PWS can change rates (e.g., public service agency
regulatory process, local government process), and other cost recovery mechanisms available to the
PWS (e.g., surcharges, tax assessments, tax liens).
In addition, state constitutional prohibitions on using public funds for private purposes may prevent
public funds from being used for full LSLR. These prohibitions are generally designed to ensure that the
state and all its political subdivisions (e.g., a county, city, village or township), only use its resources to
carry out designated governmental functions, and that public funds are preserved for public use and for
the public's benefit. There are many situations, however, where expenditures may benefit both public
and private interests. In these cases, if the primary purpose for the expenditure is a public one (i.e., the
promotion of the public health and safety or general welfare of all the inhabitants or residents), then the
expenditure may not be prohibited even if an individual is incidentally benefitted. For example:
•	Goho et al. (2019) conducted an in-depth review of 13 states (Illinois, Ohio, Michigan, New York,
New Jersey, Missouri, Indiana, Texas, Minnesota, Wisconsin, Massachusetts, Florida, and
Pennsylvania) that collectively have an estimated 4.2 million LSLs (over two-thirds of the
nation's remaining LSLs), and found that none of these states have constitutional or statutory
prohibitions on the use of rate funds to replace LSLs on private property. However, some
differences exist for publicly-owned and investor-owned utilities. Six of these states (Michigan,
New Jersey, Missouri, Indiana, Wisconsin and Pennsylvania) have adopted policies that explicitly
support this practice. See Section 5.1.
•	In Washington State, the Attorney General found that municipal sewer districts have statutory
authority to use public funds to repair or replace side sewers located on private property if
doing so will increase sewer capacity (McKenna, 2009).
•	In Texas, the legislature, by general law, can authorize a city or town to expend public funds for
the relocation or replacement of water laterals on private property if the relocation or
replacement is done in conjunction with, or immediately following, the replacement or
relocation of water mains serving the property. The general law passed by the legislature must
authorize the city or town to place a lien on the property, with the consent of the owner of the
private property, for repayment of the lateral's replacement costs (TX Const, art. XI, § 12).
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Full LSLR could serve a number of public purposes, including but not limited to the wide and well-
documented public health and societal benefits associated with lead exposure reduction and lower risk
and liability associated with the complete elimination of the lead hazard. Therefore, given that some
states and municipalities allow public spending with incidental private gain, it may be possible in many
cases to use public resources to help finance customer-owned LSLR.
Within this framework, some PWSs are finding cost recovery mechanisms and funding sources (and
combinations of those mechanisms and sources) that help to facilitate full LSLR within their
communities.
5.1 Using Ratepayer Revenue
One option for water systems to recover the costs associated with LSLR is to increase water rates paid
by all customers. Goho et al. (2019) specifically looked at the laws in 13 States having most of the LSLs in
the country and found that they support the use of ratepayer funds to pay for full LSLRs. The authors
noted that while they did not look at the laws in the other 37 States or the District of Columbia, they
indicated that they would expect them to also follow the recent trends and approve the use of
ratepayer funds to replace customer-owned LSLs.
The use of rate payer revenue to fund LSLR helps spread out the cost of the full LSLR program to all
water system customers, including those not served by an LSL. Rate subsidization can be especially
effective in systems when there is a small proportion of LSLs to the total service line inventory as can be
seen in:
•	Quincy, MA where less than one percent of service lines were LSLs and the LSLR program will
result in an increase per customer of approximately $6 per year or $60 total (Ronan, 2016).
•	Milford, MA where three percent of service lines throughout their system are LSLs and the
system plans to recover costs with a rate increase of about $4 per customer per quarter
(Commonwealth of Massachusetts DPU, 2016).
•	Pennsylvania American Water, a privately-owned utility, filed a rate case petition to the State
Public Utility Commission (PUC) to replace customer-owned LSLs over 10 years as it replaces
water mains, as well as coordinate customer requests to replace LSLs. The system estimates
there are 18,000 LSLs in its distribution system, or about three percent of all service
connections. The cost impact on customer water bills for the replacement program would be
approximately 10 cents per month, which the water system proposed to recover in a future rate
case or using the existing Distribution System Improvement Charge (DSIC) mechanism
(DeCusatis, 2018).
•	York Water Company, a privately-owned water system in Pennsylvania, received permission
from the State Public Utilities Commission to incorporate the costs of customer-owned LSLR into
its rate structure. The agreement will fund the full replacement of all remaining LSLs in the
service area by 2020 and even reimburse homeowners that have conducted LSLR on their own
in the past. (Arnold, 2017). The PUC approved a rate increase of about a dollar per month for
residents to cover this and other infrastructure improvement projects (Klar, 2019).
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Publicly-owned water system rates are generally set by local government and are not generally subject
to oversight by the state, with one notable exception being Wisconsin (Goho et al., 2019). Rate increases
by publicly-owned water systems, if used specifically for customer-owned LSLR, may be limited by public
fund usage laws (see discussion above).
In many states, privately owned systems are regulated by a Public Service Agency (e.g., a PUC or Public
Service Commission (PSC)) and therefore, to increase rates, these systems may need to:
•	Complete a Public Service Agency process of changing rates (i.e., notice and hearing) although in
some states there are emergency rate increase provisions that could be applied in the LSLR
context that would bypass the notice and hearing requirements.
•	Provide justification for the rate increase (e.g., show that the increase is needed to cover
environmental compliance costs or unanticipated repairs or improvements; or that a rate
change is necessary to continue providing adequate and efficient service).
•	Prove that rates are fair and just or apply equally across all service groups. Water system rates
are subject to either public service commission or municipal government oversight, who often
prohibit rates that are "discriminatory," "unjust," "inequitable," or other related criteria. Often
it is not specified whether providing financial assistance to the homeowner to conduct a
customer-owned LSLR would be prohibited under these criteria. The Wisconsin example below
(page 25) illustrates how this challenge played out at the state level.
Depending on the time frame surrounding the rate change process, systems can potentially use rate
revenue to either fund the LSLR program directly or to pay back funding obtained through another
mechanism such as loans. For example:
•	In Lansing, Ml, the city treated the LSLR program as a capital project, supported solely by water
rates (Lansing BWL, 2016). The Board of Water and Light's (BWL) rates are established by its
governing body, the Board of Commissioners and are not set or regulated by the state's Public
Service Commission (Lansing BWL, 2014). The 130-year-old BWL is a wholly owned city
subsidiary, so it could easily build the cost of new infrastructure into its rates. BWL also owns
the entire service line (Clark, 2016).
•	Quincy, MA approved a proposal to fund its LSLR program with a $1.5 million no-interest loan
from the Massachusetts Water Resources Authority (MWRA)8 which supplies Quincy's water.
The 10-year loan will allow the city to pay for the replacement of the approximately 150
customer-owned LSLs in the city. Quincy plans to repay the MWRA loan by increasing rates,
which will cost the individual ratepayer about $6 per year or $60 total (Ronan, 2016).
•	Milford, MA has structured a similar arrangement where the Milford Water Company is initially
covering the cost of the program through Drinking Water State Revolving Fund (DWSRF) monies
to encourage full participation from Milford citizens (MassDEP, 2017) but plans to recuperate
these costs with a rate increase of about $4 per customer per quarter (D.P.U. 16-192,
Information Request DPU-1-10). Rate increases would not affect customers immediately as the
8 The MWRA is a public authority that provides wholesale water to 50 communities, most which are in the greater
Boston and the Metro West areas of Massachusetts.
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Company has to apply for a rate increase during its next rate case, which it planned to do in mid-
to late-2017 (Milford Daily News, 2018). Below market-interest financing available through the
DWSRF enabled the city to minimize the future rate increase.
As discussed by Goho et al. (2019), six states have recently changed state laws or regulations to allow for
or clarify that rate revenue can be used to provide customer assistance to replace a customer-owned
LSL.
•	Michigan's Department of Environmental Quality (MDEQ) revised the State's version of the LCR
in June 2018 requiring utilities to replace the entire LSL at no cost to the customer, implying that
ratepayer funds would be used for this. However, in December 2018, Detroit, Ml and other
municipalities filed a lawsuit challenging the MDEQ rules.
•	In 2017, the Indiana General Assembly enacted legislation allowing the Indiana Utility
Regulatory Commission (IURC) to approve an investor-owned utility's proposal to pay for LSLR
on private property with ratepayer funds.
•	The Missouri Public Service Commission determined in May 2018 that the Missouri American
Water Company (MAWC) could fund its LSLR program through a rate increase approved for
infrastructure improvements. MAWC performs full LSLR when discovered during a water main
replacement. This decision has been challenged in court.
•	New Jersey enacted legislation in August 2018 authorizing municipalities to replace LSLs on
private property if the work is an environmental infrastructure project and is funded by loans
from either the New Jersey Environmental Infrastructure Trust or the State's Department of
Environmental Protection.
•	The Wisconsin State Legislature passed the "Leading on Lead Act", that allows municipalities to
provide financial assistance for customer-owned LSLRs. The legislation specifically deems that it
is "not unjust, unreasonable, insufficient, unfairly discriminatory, or preferential or otherwise
unreasonable or unlawful for a water public utility to provide financial assistance to a customer
solely for replacing LSLs if the financial assistance is allowed by local ordinance." (The Wisconsin
PSC has in the past interpreted its statute to mean that user rates cannot be used to recover the
cost of customer-owned LSLR by the utility because "it would be unreasonable and unjustly
discriminatory if public dollars generated through utility rates were used to subsidize a direct
benefit to an exclusive group of private property owners" (Wl Ct. App, 2002).) In addition, under
the bill, if a public water utility provides financial assistance for replacing LSLs, the PSC must
include the cost of providing that financial assistance in its determination of water rates (Wl
Assembly, 2017 and Senate, 2017).
•	In Pennsylvania, the 2017 passage of Act 44 allows municipal authorities to use public funds and
public employees to perform customer-owned LSLR and replacement of sewer laterals if the
municipal authority determines that such action will benefit public health or the public water
supply system. (PA Assembly, 2017). The passage of Act 120 in 2018 authorizes the State Public
Utilities Commission to allow water utilities under its authority (primarily privately-owned water
systems) to use ratepayer revenue to finance the proactive replacement of customer-owned
lead service lines as well as damaged customer-owned sewer laterals. The work is to be
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conducted concurrent with main replacement or under a Commission-approved replacement
program (PA Assembly, 2018).
5.2 Using Non-Ratepayer Revenue
Some systems have accessed other cost recovery mechanisms such as federal, state, and local loans and
grants; the levy of a tax lien or the imposition of special assessments (applicable to publicly-owned
systems) or surcharge; or other creative ways to fund their LSLR programs.
5.2.1 Federal Funds for Water System-Owned and Customer-Owned LSLR
There are many federal programs that may be used to fund LSLR programs. These include the Drinking
Water State Revolving Fund (DWSRF), Water Infrastructure Finance and Innovation Act (WIFIA) Program,
Water Infrastructure Improvements for the Nation (WIIN) Act of 2016 grant programs, and U.S.
Department of Housing and Urban Development's (HUD) Community Development Block Grant (CDBG)
Program. The list below includes a brief description of each federal program, as well as examples of LSLR
projects (where available).
•	Drinking Water State Revolving Fund (DWSRF): The DWSRF offers below market-interest
financing and funding opportunities for LSLR (USEPA, 2019b). Through the DWSRF Program, the
EPA allocates annual capitalization grants to states. Part of the funds are set-asides that States
may elect to use for drinking water program management and activities. The balance, along with
a 20 percent State match, is placed into a dedicated loan fund to finance eligible water system
infrastructure improvement projects (USEPA, 2018a). The EPA's DWSRF annual allocations for
fiscal year 2018 totaled $1,057 billion. States are providing funding from their DWSRF to
facilitate LSLR projects and are taking steps to modify their DWSRF programs to prioritize LSLR.
For example: Milford, MA received $1,158,000 financing from the MA DWSRF for its LSLR
project (MassDEP, 2017); Washington's Department of Health modified the eligibility criteria for
DWSRF construction loans to prioritize LSLR projects (WA DOH, 2016); and Michigan submitted a
supplemental Intended Use Plan (IUP) to EPA, to allocate $40 million in DWSRF for LSLRs in Flint
(Ml DEQ, 2017).
An EPA analysis determined the number of full LSLR that may be conducted as a result of DWSRF
funding over a 35-year timeframe. The DWSRF will fund the replacement, in whole or in part, of
an estimated 149,200 LSLR over 35 years.
•	Water Infrastructure Finance and Innovation Act (WIFIA): The Water Infrastructure Finance
and Innovation Act (WIFIA) program provides funds to eligible water projects through long-term,
low-cost supplemental loans for regionally and nationally significant projects (USEPA, 2016b). In
FY 2018, 39 projects in 16 States and Washington, D.C. were selected and invited to apply for
WIFIA loans; 12 of these are to reduce lead or other contaminants in drinking water For
example, American Water Capital Corporation in St. Louis, MO was invited to apply for $84
million in WIFIA loan funding to support its project to replace approximately 100 miles of main
and adjacent customer-owned LSLs (USEPA, 2018b). In 2019, the EPA announced the availability
of $6 billion for WIFIA loans and once again prioritized projects that reduce exposure to lead.
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•	Water Infrastructure Improvements for the Nation (WIIN) Act: Under the WIIN Act, which was
enacted in December 2016, three new grant programs were established related to reducing lead
in drinking water (assistance for small and disadvantaged communities, reducing lead in drinking
water, and lead testing in school and child care drinking water program) (USEPA, 2019). In 2017,
$100 million was approved for communities for which the President had declared an emergency
relating to public health threats associated with lead or other contaminants in drinking water
(USEPA, 2017). At that time, Flint, Ml was the only eligible community for this funding. The city
allocated $40 million of these funds towards LSLR. In 2018 and 2019, Congress appropriated $25
million under the WIIN Act for reducing lead in drinking water across the country, including
activities such as full LSLR.
Community Development Block Grants (CDBG): The Department of Housing and Urban
Development (HUD) has administered the CDBG program since 1974 and provides resources for
community development needs. CDBG funded projects must benefit low- and moderate-income
populations, prevent or eliminate slums or blight, or address urgent community development
needs, particularly those that present an immediate threat to public health (having a particular
urgency because existing conditions pose a serious and immediate threat to the health or
welfare of the community for which other funding is not available (HUD, no date). North
Providence, Rl's "Remove the Whole Lead Pipe Program" uses CDBG funds from HUD to fund
customer-owned LSLR at no cost to the homeowner. The grant is a one-time assistance program
and does not change ownership or maintenance responsibilities of the customer for the new
service line. The town has a goal of replacing every LSL in the community (Town of North
Providence, Rl, 2019).
5.2.2 State and Local Loan and Grant Programs
There are many local and state loan and grant programs that systems could access to help fund full LSLR.
Several states have taken action through prioritization of DWSRF funds for full LSLR or enacting
legislation to facilitate full LSLR financing. Some examples include:
•	The Wisconsin Department of Natural Resources (DNR) established a two-year program (State
Fiscal Years 2017 and 2018) to help disadvantaged municipalities replace LSLs on private
property for projects that result in full LSLR. Funding for LSLR on private property is in the form
of principal forgiveness (PF). According to the Wl DNR, "PF is additional subsidy, provided by the
Federal government, to assist municipalities that would experience significant hardship raising
revenue necessary to finance needed infrastructure projects;" it reduces the size, and therefore
the annual payment and interest, of a Safe Drinking Water Loan Program (SDWLP) loan (Wl
DNR, 2015). Projects must result in full LSLRs and municipalities have three years from the date
of their loan closing to expend funds for the LSL program. Between 2017 and 2018, 44 water
systems in Wisconsin received funding for LSLR (Wl DNR, 2018).
•	The Massachusetts Water Resources Authority (MWRA) established two loan programs that are
being used for LSLR projects.
o The Local Water System Assistance Program (LWSAP) provides $210 million in interest-
free loans to member water communities to perform PWS improvement projects.
Community loans are repaid to MWRA over a 10-year period. Loan funds are approved
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for distribution from fiscal year 2011 through fiscal year 2020. A few MWRA
communities have used LWSAP loans to fund LSLR projects (MWRA, 2017b).
o Lead Loan Program (LLP) is an addition to the LWSAP that provides up to $100 million in
interest-free loans to up to 45 of MWRA's member communities. These are also 10-year
interest free loans that must be used to, "create local programs to fully remove LSLs
from community water mains all the way to the home or business" (MWRA, 2017a).
•	In Washington, D.C., new legislation allocates District funds to support DC Water's full lead
service line replacement program. Residents can receive assistance to cover 100% of customer-
side replacement costs when DC Water replaces the portion of lead service line in public space
during capital improvement projects and repairs. Additionally, the legislation allocates funds to
redress previous partial lead service line replacements. Residents can apply for assistance
awarded based on household income to cover 50-100% of replacement costs for properties
wherein lead service lines remain only on the customer-side. Funds have been included in the
District's Fiscal Year 2020 budget that begins October 1, 2019 (City of Washington, D.C., 2018).
•	In New York, the legislature's Clean Water Infrastructure Act of 2017 required the State health
department to create a Lead Service Line Replacement Program (LSLRP). The program covers
the cost of full LSLR and associated activities such as administration fees and yard restoration.
The appropriated $20 million was distributed equally among 10 regions of the state, reaching 26
municipalities. Municipalities were chosen based on three criteria: lower median household
income relative to surrounding municipalities, age of housing stock, and elevated average blood
lead levels (NY DOH, 2018).
•	New Jersey's Environmental Infrastructure Financing Program (also called "Water Bank") details
LSLR eligibility and prioritization for DWSRF funds statewide. Water systems that exceed the
lead action level can be given loans with 90 percent principal forgiveness. The loans are capped
at $1 million per municipality and are prioritized for communities whose median household
income (MHI) is less than the county average MHI. The program notes that other lead service
line projects are available for Water Bank financing and receive the base rate, affordability rate,
or Nano financing. Trenton, NJ applied for the principal forgiveness funds after exceeding the
action level (TWW) (NJ DEP, 2018).
o Nano and Nano-lite financing may also be used for small drinking water systems serving
fewer than 10,000 customers. These systems would be ranked and would receive 75
percent Department of Environmental Protection (DEP) interest-free financing and 25
percent l-Bank Market Rate financing. Small systems serving fewer than 500 people
would receive 50 percent principal forgiveness in addition to 25 percent DEP interest-
free financing and 25 percent l-Bank Market Rate financing (NJ DEP, 2018).
o A New Jersey Water Supply Remediation "sub-account" can provide zero interest loans
for a term of not more than 10 years with a maximum amount for any single loan of
$10,000 "to owners of single-family residences, whose source of potable water violates
primary drinking water standards or violates a standard for... lead" (NJ DEP, 1999). The
loan program is managed by the New Jersey Housing and Mortgage Finance Agency and
loan priorities are based on those of the State's DWSRF program. A bill passed by
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Pennsylvania's State legislature in 2017 allows for the government, through the State's
Pennsylvania Infrastructure Investment Authority (PENNVEST)9 fund, to finance the
"improvement, extension, repair or rehabilitation" of customer-owned lead service lines
and sewer laterals. To use these funds, the government must deem such activity will
benefit the public water system. The law specifies that ownership or control of the
customer-owned LSL or lateral does not change should a water system provide financial
assistance to the homeowner to replace the customer's LSL or sewer lateral (PA
Assembly, 2018b). PENNVEST allocated $49 million ($13.6 million in grant dollars and
the other $35.4 million through a 1 percent low-interest loan) to finance 28,000 full LSLR
for the Pittsburgh Water and Sewer Authority (PWSA) (PENNVEST, 2018).
•	Providence Water is offering three-year zero percent interest loans to property owners for
customer-owned LSLR in part due to low participation in the system's LSLR program (Providence
Water, 2019). In response to a Rhode Island Public Utilities Commission (RIPUC) data request,
Providence Water reported that "only 2% of customers have replaced the private side
[customer-owned] of the lead service when Providence Water replaces the public side [water
system-owned] of the lead service" (Providence Water, 2017).
5.2.3 Special Assessments, Tax Levies, and Surcharges
Systems may have the ability to impose special assessments, tax levies, and surcharges to help fund LSLR
programs or help homeowners pay for the replacements. For example:
•	In Fond du Lac, Wl homeowners are responsible for the cost of replacing customer-owned LSLs
but can spread the cost out over 10 years through a special assessment on the tax bill if the
homeowner chooses to have a city contractor complete the replacement (Fond du Lac Wl, no
date). This ordinance allows property owners on their property tax bill, to finance special
assessments of $500 to $5,000 over a 5-year-period, or $5,001 or greater over a 10-year period
(Fond du Lac, 1993). This installment option also includes interest, determined by the city's
borrowing rate plus 2 percent. Fond du Lac's Public Works Director noted that the city had not
used this type of assessment in the past but that this is a new type of public improvement
project (Roznik, 2017c). On other recent assessments, the interest rate amounted to 4.25
percent (Roznik, 2017b).
•	In Milwaukee, Wl, customers are responsible for the cost of customer-owned LSLR which can be
paid in a lump sum payment or paid as a special assessment on taxes over 10-years. The
installment payment plan includes the imposition of an interest rate of the prime rate plus one
percent. The interest rate in effect at the time the special assessment is levied shall be fixed for
the 10-year duration of the installment payments (Milwaukee, 2016). The city however, is
9 PENNVEST has been empowered by Pennsylvania state law, Pennsylvania Infrastructure Investment Authority Act
16 of 1988, to administer and finance the Clean Water State Revolving Fund (CWSRF) and the Drinking Water State
Revolving Fund (DWSRF) pursuant to the federal Water Quality Act of 1987, as well as to administer the American
Recovery and Reinvestment Act of 2009 (ARRA) funds. PENNVEST also finances, through the issuance of special
obligation revenue bonds, water management, solid waste disposal, sewage treatment and pollution control
projects undertaken by or on behalf of private entities. (See http://www.pennvest.pa.goy/Pages/default.aspx).
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currently offering a subsidy to certain eligible homeowners.10 This subsidy is expected to cover
up to 2/3 of the cost of LSLR for eligible property owners. (Behm, 2016).
•	In Syracuse, NY homeowners have the option of making a lump-sum payment of the total cost
before April 1 of the calendar year in which the Commissioner certifies the cost of the LSLR, or
they can repay the cost through 10 equal annual installments on the property's annual city tax
bill, plus a seven percent annual interest rate. Each annual installment can be paid in four equal
installments in the applicable tax year, on the same general city tax schedule including all
interest, fees and penalties which are applicable to the general city taxes (Syracuse, 1974).
Some states regulate these cost recovery mechanisms, which may be leveraged to fund LSLR. For
example,
•	In Michigan, a municipality operating a water distribution system has a lien on the property to
which it supplies water as security for the collection of water rates, assessments or charges (Ml
Legislature, 1939); can levy a tax or special assessment for the improvements on a water supply
system (Ml Legislature, 1955); and can authorize the giving of "contributions" or "gifts" from the
system's operating revenues if the governing body of the municipality determines that these are
in the public interest and the legislative body of the municipality approves (Ml Legislature, 1939;
Ml Legislature, 1969).11
•	Public utilities in Missouri can make rate adjustments outside of the regular rate-case
requirements to cover certain environmental costs (i.e., the Environmental Cost Adjustment
Mechanism or ECAM) when several conditions are met, including: the utility being ineligible for
the infrastructure system replacement surcharge (ISRS); that the costs are not a result of
negligence on the part of the utility; and that the costs are in response to a federal, state, or
local law pertaining to the regulation or protection of health, safety and the environment (MO
PSC, no date).
•	Public Utilities Commission of Ohio (PUCO)-regulated utilities12 may be able to fund LSLRs by
applying to the Commission to "collect an infrastructure improvement surcharge ... from
customers located in the company's affected service areas and subject to affected schedules"
(OH Code, 2003).
5.2.4 Creative Funding Mechanisms
Systems are also finding novel ways to fund and reduce the cost of full LSLR.
10	To be eligible for the subsidy, the property must be a less than 5-family dwelling and the owner must agree to
have the work performed by a city contractor, sign a hold-harmless agreement, and execute a temporary right of
entry and construction easement (Municipal Code art. 2 §225-22.5 sub. 9b).
11	Note that water distribution system is not specifically defined in the Municipal Water Liens section of the statute
(Mich. Comp. Laws § 123.161-123.167). According to Mich. Comp. Laws § 124.281 "water supply system," includes
"all plants, works, instrumentalities, and properties used or useful in connection with obtaining a water supply, the
treatment of water, or the distribution of water"
12	PUCO regulates investor-owned water companies throughout the State, and thereby does not regulate
municipalities, counties, cooperatives or water districts (Ohio Rev. Code § 4905.02).
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•	The Wisconsin PSC previously did not permit water utilities to use rate-payer money to
reimburse property owners for LSLR. To address this cost barrier, Madison Water Utility rented
space on top of utility-owned water towers to cell phone companies and used the generated
revenue for the Lead Service Replacement Program. Madison Water Utility also coordinated 20
percent of replacements with pre-planned main replacement projects between 2007 and 2012
(Madison Water Utility, 2019).
•	In Kalamazoo, Ml, the city created the "Foundation for Excellence" (Kalamazoo, 2019), which is a
collaboration between the city and private donors to, among other things, "make key
investments to create a vibrant, forward-looking community that benefits everyone". The city
replaced 120 LSLs in 2016; however, at least 2,917 remained. The Foundation has funded 68
LSLRs (Barrett, 2017) and continued funding will allow the city to accelerate the replacement of
the LSLRs.
•	Green Bay, Wl, in addition to DWSRF funding, used $300,000 from Lambeau Field sales tax
rebates to provide grants to property owners for changing out their lead pipes (Srubas, 2017).
5.3 Targeting LSLR to Communities Most in Need
One implication of the high cost of LSLR is potential environmental justice (EJ) concerns, as the
customer-owned replacement cost may not be easily accessible to all customers. Loan or grant
programs, like some of those mentioned in Section 3 (e.g., New Jersey and Wisconsin), may lead to
better EJ outcomes because they decrease the cost to the customer for customer-owned LSLR. There
are some examples where water systems have directly addressed EJ concerns in their LSLR program
structure that prioritize funding to communities with the greatest need. For example:
•	In a new program to be implemented in October 2019, the D.C. government will pay for 50
percent or more of the cost of customer-owned LSLR for moderate to low income homeowners
served by DC Water. This is for cases where the water system-owned portion is not an LSL
(Morris, 2018).
•	Galesburg, IL gives higher priority for LSLR grants to homes with low to moderate income (based
on HUD's Low-Income Limits Documentation System), and have children aged six and under
living at the address (Galesburg, 2016).
•	The Wisconsin Department of Natural Resources (DNR) established a two-year program (SFY
2017 and SFY 2018) to help disadvantaged municipalities replace LSLs on private property for
projects that result in full LSLR. Funding for LSLR on private property is in the form of principal
forgiveness, which means no debt is incurred on behalf of the municipality for these funds. The
program is intended to assist individuals in disadvantaged municipalities since currently in Wl,
user rates cannot be used to replace the customer-owned portion of the LSL (DNR, 2018).
•	New York's LSLRP (Lead Service Line Replacement Program) awards funds to municipalities with
the highest need, based on three criteria: age of housing stock, median household income
relative to neighboring municipalities, and elevated average blood lead levels (NY DOH, 2018).
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In Pittsburgh, low-interest loans are available to homeowners meeting income eligibility
requirements for customer-owned LSLR through the Urban Redevelopment Authority's ROLL
program. (Pittsburgh URA)

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6 The Cost of LSLR
Cost is perhaps one of the main barriers of proactive full LSLR for water systems and customers. To
surmount this barrier, municipalities have sought various financing options, as outlined in the previous
section. Another strategy they've utilized is to reduce the overall cost of LSLR by coupling LSLR with
existing infrastructure projects and incorporating LSLR best practices to optimize the efficiency of LSLR.
Some are taking the approach of targeting assistance to the customers with the greatest need.
6.1 Coupling LSLR with Other Infrastructure Projects
The EPA assumes that on average systems will replace one percent of pipes annually as part of their
infrastructure replacement programs13. To increase efficiencies and reduce costs of LSLR, water systems
have coupled the customer-owned and water system-owned replacements. For example:
•	When conducting main replacements, emergency work, and Department of Transportation
(DOT) construction projects, DC Water replaces existing water system-owned LSLs and will offer
to coordinate the replacement of the customer-owned LSL at the customer's expense (DC Water
Construction Project Replacements). If a property owner meets specific requirements14 and
agrees to pay for the customer-owned LSLR, DC Water will coordinate and replace the water
system-owned portion at the same time (DC Water Voluntary Replacements).
•	Providence Water in Providence, Rl continued to replace LSLs as part of its water main
replacement program and during local and State road resurfacing projects even though the
Rhode Island Department of Health (DOH) suspended the mandatory LSLR program (Providence
Water, 2016). Providence Water has also continued to replace the water system-owned LSLs
when a property owner voluntarily replaces their customer-owned portion (Providence Water,
2019).
•	Both Milwaukee, Wl and Fond du Lac, Wl have passed ordinances that require customers to
replace the customer-owned LSLs if among other things, the utility-owned portion is being
removed on a planned or emergency basis (Municipal Code art. 2 §225-22.5 and Municipal Code
§ 642-5G). Both ordinances require the city to notify the customer before the commencement
of a planned water system-owned LSLR and upon receipt of notice, the customer has a certain
13	As reported in the 1991 LCR Regulatory Impact Analysis (USEPA, 1991), the 1988 American Water Works
Association (AWWA) Lead Information Survey (LIS) found that approximately 1 percent of all LSLs are replaced
each year as part of ongoing utility replacement programs. The Regulatory Impact Assessment did not indicate if
these replacements were customer portion or water system portion, or full replacements of the entire line.
14	The eligibility requirements include verification of property owner, proof of LSL on private property (i.e., photo
evidence, home or plumber inspection report, or other form of professional verification), having hired DC Water
contractor (or if using a private plumber, an approved permit and coordination with the DC Water contractor is
required), and water service pipe otherwise up to code. To avoid redundancy in excavation, water main or DOT
construction must not already be planned for that location.
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number of days to either replace the LSL by contracting with a licensed contractor or authorize
the city contractor to replace their portion of the LSL15
•	To help reduce costs to customers with LSLs, the Madison Water Utility crews left trenches open
after replacing water system-owned lines so that private plumbers could immediately replace
customers' lines for a lower cost (Madison Water Utility).
•	Ft. Worth, TX's water system always replaces LSLs during main replacement. Also, as a precursor
to another project, the city is obtaining GPS coordinates for every meter. At that time, staff will
also check and record if the service line or private plumbing is lead (Ft. Worth Water
Department).
6.2 Incorporating LSLR Best Practices to Improve Efficiency
As increasing public attention has been given to lead in drinking water and the replacement of LSLs,
PWSs and municipal efforts (and joint PWS/municipal/state efforts) are bringing about proactive LSLR
that go above and beyond the requirements of the current LCR. As more LSLR programs are
implemented, systems are becoming more effective at prioritizing LSLR in locations with the greatest
need, increasing the efficiency of LSLR, reducing costs in other areas of the LSLR program, and applying
lessons learned toward subsequent LSLR efforts. For example, Lansing, Ml reports that substantial
efficiencies have been gained during their 12-year LSLR program. The Board of Water and Light (BWL)
crews have learned over 12 years how to remove LSLs more efficiently: an LSL can be removed in about
four hours at a cost of about $3,600 as compared to when the work first started, the cost per line was
about $9,000 (Lacy, 2016). Depending on crew availability, the replacement pace was two to four service
lines per day (Lansing BWL Lead Water Services Survey). Learning from other water utility LSLR programs
as well as the ANSI/American Water Works Association standard operating procedures and best
practices for identifying and replacing LSLs (AWWA, 2017), a system can reduce the overall cost of their
LSLR program and the direct cost to customers as well.
Efficiencies can also be gained during inventory development. Water systems have reduced costs by:
•	Asking customers to self-identify LSLs (e.g., Lansing Board of Water & Light) rather than deploy
water system personnel to conduct inspections;
•	Sending surveys and holding community meetings to show people how to locate their service
line and do a scratch test to check for lead (City of Madison);
•	Potholing as opposed to digging with a backhoe;
•	Disclosing LSLs upon real estate change. The Environmental Defense Fund reports that three
States (Connecticut, Delaware and New York) require sellers to disclose whether there are lead
15 As of April 26, 2017, the mandatory customer-owned replacements in Fond Du Lac have been put on hold. The
contractor with the low bid for the project was unable to secure a performance bond, and the subsequent bid was
too high and would have forced an unreasonable increase in costs to the customers. For 2017 at least, the LSLR
program is voluntary with customers being eligible for a subsidy if they meet certain timelines and use a plumber
from the City's pre-qualified list (LSL Voluntary Replacement FAQ). The 148 homeowners that had been scheduled
for LSLR during the summer of 2017 will be given a waiver from the ordinance's requirements (Roznik. 2017).
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pipes, 27 States and D.C. have provisions that are silent or ambiguous on lead pipes or that
disclosure of lead pipes is voluntary, and that the remaining 20 States have limited or no
disclosure requirements related to LSLs. These disclosures could be used to add to or confirm a
PWS's inventory of LSLs, however they are limited in that: (1) disclosure is required only if the
property owner knows of the LSLs; (2) the owner does not always have a duty to find out if there
is a LSL; and (3) the PWS may not be told since the duty to disclose exists between the buyer and
seller.
•	In Pittsburgh, field crews are identifying LSLs using an innovative method developed by Field
Operations staff of accessing the curb box and taking photos of the exposed service line to
document the pipe material. This method avoids costly and potentially disruptive excavations
(Pittsburgh, 2018).
•	Researchers used a predictive, statistical model to help identify and prioritize LSLs for
replacement in Flint, Ml. The research team combined datasets from existing pipe materials
information, tap water sample results, and city records to determine which service lines were
most likely to be LSLs. The study asserts that use of the algorithm reduced the error rate
(excavations of copper service lines thought to be LSLs) to 2%, which lowered the effective cost
of each replacement by 10% and yielded approximately $10M in potential savings (Abernethy et
al., 2018).
•	Although they do not remove the lead source, pipe lining and coating technologies can be an
alternative to LSLR. A Water Research Foundation Report investigated these technologies and
found that they can reduce or eliminate lead release from LSLs (WRF, 2017). These technologies
require consideration of site-specific factors, so if a water system is evaluating these
technologies, its decision-making process may increase in complexity. For example, the
condition of the current service pipe, including scale deposits, corrosion, and bends or kinks may
prevent the use of a lining or coating technology. Another consideration is the possibility of
reduced water pressure at the residence, as the technologies reduce pipe diameter. Finally, the
uncertainty of the technologies performance over time may require additional monitoring to
ensure lead levels at the tap remain low. The added costs of site-specific evaluation, continued
monitoring, and eventual re-lining of the service pipe when it reaches the end of its useful life,
may reduce the cost savings associated with lining and coating technologies relative to full LSLR,
especially when compared to less expensive LSLR methods such as trenchless replacement.
35

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7 References
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Exhibit 1. Summary of Studies Identified in Literature Search for "Assessment of Projected Household Initiated Voluntary Lead Service Line
Replacement as a Result of Revisions to Public Education "
Author
Study
Intervention
Sample
Methods
Outcomes
Comments
Bain et al.,
2016
Examines a multi-faceted
communications effort
(material distribution, media
engagement) and integrated
health campaign (led by a
statewide coalition of
organizations known as the
Iowa Radon Coalition (ICCC)
to increase radon testing and
remediation in Iowa.
To increase
radon
awareness,
testing, and
remediation
General population of
Iowa which represents
a high radon area
where the majority of
homes have radon
levels above the EPA
action level. A specific
study sample is not
defined.
Qualitative and quantitative
data were collected on
radon knowledge, testing,
and mitigation. Radon
knowledge was assessed
through pre- and post-tests
at educational sessions and
events. Statewide testing
data from test kit labs and
mitigation data were used.
Data on program impact
were collected but methods
were not specified. No
sampling strategy was
specified.
Before implementation of the interventions in
2009, the number of radon tests completed in
Iowa was 19,600. In 2014, after
implementation, 23,500 radon tests were
completed (increase of 20%). In 2009, the
number of mitigations completed by certified
mitigators was 2,600; in 2014, mitigations
increased to over 5,400. The number of
certified mitigation specialists in the state
increased from 54 in 2009 to 76 in 2014. The
study does not quantify remediation rate as a
direct result of a public health campaign.
Radon levels, radon testing and
remediation rates were collected by
the Iowa Department of Public Health.
There is no control group for
comparison. The Iowa Radon Coalition
offers yearly community grants for
radon awareness and testing projects.
A collaborative approach was used to
increase levels of awareness, testing
and mitigation, and to introduce a
comprehensive radon control policy in
Iowa by engaging partners and
stakeholders across the state.
Interventions are initiated by the
coalition, and community partners and
stakeholders modify and implement
the interventions based on
characteristics of the community.
Examples of interventions are
community-based projects and
educational events with radon test-kit
distribution, IRC and ICC working with
the Iowa Bankers Association to offer
low-interest loans for radon
mitigation, the ICC partnering with a
healthy homes program to provide
testing and mitigation services to
communities with low socioeconomic
status.
Desvousges
et al., 1992
Comparison of two pilot
programs for encouraging
radon testing: a targeted
mass-media campaign (radio
public service
announcements, local
newspaper advertisements,
informational flier inserts in
utility bills) and a mass-media
campaign with a community
outreach program (radon
To increase
radon testing
Three communities in
Maryland that have
high home radon
levels. The study
included a baseline
telephone survey of
randomly selected
homeowners (initial
attitudes, knowledge
and levels of radon
testing) in each
community and a
Comparison of three
communities subject to 1)
targeted mass media
campaign (Hagerstown), 2)
mass media and a
community outreach
program (Frederick), and 3)
control group with no
special radon testing
information (Randallstown).
Baseline survey response rates were 48%
(Randallstown), 58% (Frederick), and 64%
(Hagerstown). Follow-up survey response
rates were ~80% for all three cities. Media
campaigns and community outreach programs
resulted in increased awareness, attitudinal
changes and knowledge. Frederick (media
campaign + community outreach program)
reached 15% radon testing during the 3
months of the program, whereas Hagerstown
and Randallstown remained at 5% testing.
Across each community, people viewed
Demographic data was collected in the
baseline survey. Respondents cited
expense as a reason for not mitigating.
Testing rates were higher among
respondents with higher income and
education levels. Study population
was not focused to only homes with
high radon levels.
44

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awareness week, posters and
presentations).

follow-up survey with
the same respondents
(n=500).

mitigation as expensive. A sizeable percentage
of people, 40% in Frederick and Hagerstown,
and 70% in Randallstown, felt property values
would decrease if radon were fixed.

Doyle et al.,
1990
Evaluation of existing radon
testing and remediation
strategies through two
studies evaluating (1) a
traditional radon information
and awareness campaign
(advertisements in
newspapers and TV,
discounted radon test kits)
targeted at the general
population in Washington DC
and (2) radon disclosure at
the time of home sale in
Boulder, CO.
To increase
radon testing
and
remediation
rates
Two cities were
evaluated. Washington
DC and Boulder,
Colorado. Households
in the Washington DC
area (high radon area)
who had purchased
radon test kits as part
of an intensive
information and
awareness program
(n=920), and
homebuyers in
Boulder, CO (n=303).
Washington DC sample:
Paper-based survey of
questions on radon levels,
remediation. A mail survey
was conducted of those
who returned test kits: a
stratified random sampling
design was used to sample
households across 4 radon
levels (<4, 4-20, 20-50, >50
pCi/l). 920 households were
sent surveys (<1% of total
test kits purchased).
Boulder, CO sample: 495
homebuyers were
identified through lists of
names published in a local
newspaper that publishes
all home sales and
contacted via phone survey.
Washington DC: Response rate: 77% (708 of
920). 100,000 radon test kits were purchased
(representing 6.5% of the target population)
as a result of the campaign. 55,830 test kits
(55% of total) were returned. Of the 920
surveyed households, 73% tested above the
EPA action level. 1.2% claimed some sort of
remediation. Of the 1.2% who claimed
remediation, only one-third (0.04%) retested
to confirm mitigation was effective. Survey
results were extrapolated to absolute
population estimates and transition rates
(from testing to confirmed successful
mitigation) of the entire pool of single-family
homes estimated to have high radon levels in
the DC area. <0.1% of all single-family homes
needing mitigation would successfully
mitigate.
Boulder, CO: Response rate: 61% (303 of 495).
50% (154 of 303) of recently purchased homes
were tested for radon gas at the time of home
sale and that this testing was often motivated
by information provided by a realtor. Of the
Boulder sample, 54% of the homes with
elevated radon levels underwent mitigation
(65 households or 21% of the original sample).
Results suggest that the education
campaign to the DC area may have
encouraged households to try their
own remediation measures instead of
contacting a professional. Results from
Boulder suggest that a radon
information and awareness program
targeted at the point of home sale,
when the transaction context provides
a strong economic incentive to repair
any problems a home might have,
could be highly effective in
comparison to information targeted at
the general public. No intensive health
campaign had been conducted in
Boulder, so any testing that occurred
was motivated by generally available
radon information. The authors argue
the most important bottlenecks are
getting people to purchase test kits,
and when residents are notified of
high radon levels but often fail to take
mitigatory action, or the action taken
is ineffective. This report also presents
an extensive review of potential legal
strategies for addressing radon
disclosure at the time of real estate
transfer.
Ford and
Eheman,
1997.
To examine data from the
1990 and 1991 National
Health Interview Survey
(NHIS) to study radon control
activity behavior
No direct
intervention
Nationally
representative sample
of the U.S. population
participating in the
NHIS which included
questions on home
radon testing and
mitigation. (n=41,104).
NHIS employed a multistage
complex sampling design.
Interviews were conducted
in person. Data was
analyzed using SESUDAAN
software and proportions
were calculated to obtain
national estimates. Raw
survey data and weighted
proportions with standard
errors were calculated.
Response rates were 86.3% (1990) and 92.2%
(1991). From the 1990 survey, participants
who were aware of radon 5.2% had their
home tested. Those who had their home
tested, 28% of homes had high radon levels
(>148 Bq/m3), and 19.8% of homes with high
radon levels indicated that physical
modifications (mitigation) to the home were
completed. 1991 survey responses on
mitigation in homes with high radon levels
were 48.4%; however, this increase in
mitigation rates may be due to the large
standard error in the estimates (+/-14.4%).
Method of mitigation was not
specified in the surveys. Demographic
data was not analyzed.
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Neri et al.,
2018
Study radon knowledge in
diverse populations with
varying radon-related laws to
inform radon-related cancer
control practices and
activities
To increase
radon testing
Homebuyers who
purchased single-family
homes in four states:
Illinois, Minnesota,
North Carolina, and
Ohio. (n=3,000)
Paper-based survey mailed
to homebuyers. 750 surveys
were sent to homebuyers in
each state. Hand MN had
existing radon notification
policies, Hand OH had
existing state-managed
professional licensure
requirements, and NC had
no existing radon-related
policies.
Overall response rate was 33% (n=995); 39%
in NC and MN, 33% in IL; and 21% in OH. 86%
of all survey respondents reported hearing of
radon-related health issues regardless of state
policies. Real estate agents and home
inspectors were cited as the most common
sources of radon information, 69% and 65%,
respectively. 58% of all respondents reported
their home tested for radon, regardless of
state policies. A majority of respondents had
discussed radon with their real estate agent
(60%) or signed paperwork for radon testing
(51%). Respondents in states with notification
policies were significantly more likely to
discuss radon testing with their real estate
agent.
No data on mitigation were provided.
Survey included demographic
information.
Nissen et al.,
2012
Study radon intervention in a
primary care setting to
increase radon testing and
mitigation.
To enhance
radon risk
perception,
and increase
radon testing
and
remediation
rates
Patients at two primary
care clinics located in
Minneapolis MN - a
high risk area for
radon. (n=797).
Primary care providers and
clinic staff provided radon
risk and testing information
to patients. A written
baseline survey and follow-
up survey were given to
patients.
Baseline survey response rate: 86% (692). 25%
of homeowners reported that their homes
had been tested. Remaining ~75% (521
homeowners) indicated either their home had
never been tested or were unsure if their
home had been tested. Of this subset, 250
homeowners participated in a follow-up study
and survey (received a discounted radon test
kit and contacted 12 months later). Of the 24
respondents from the follow-up survey who
had high radon levels, only 12 had their home
mitigated. <3% who tested their homes did so
at the recommendation of a healthcare
professional, and <20% who tested their
home did so at the recommendation of a
realtor.
Study did not report demographic
information. Authors state the
effectiveness of this intervention was
minimal. Despite receiving radon
information at the clinic and a coupon
for a discounted radon test kit, only
14.4% of participants in the follow-up
study tested their homes in the
following year.
Poortinga,
Bronstering,
& Lannon,
2011
Population-based study
evaluating a locally directed
radon roll-out program aimed
at increasing radon
awareness and testing rates
in radon-affected areas of
England and Wales.
To increase
radon
awareness and
testing rates
Residents age 16 and
older of actionable and
nonactionable radon-
affected areas of
England and Wales,
including participating
and nonparticipating
areas in local radon
roll-out programs
(n=l,578).
Cross-sectional study
assessing radon awareness,
risk perceptions, and
behavior. A multi-stage
sampling strategy was used
to select areas based on
radon affectedness,
participation in radon
program, geographic
location, and population
density. In person
interviews were conducted
using computer-assisted
personal interviewing.
The study surveyed 1,578 participants.
Participants living in local areas participating
in the radon roll-out program were more than
two times (167%) as likely to have tested their
homes than participants living in
nonparticipating areas (OR 2.67 (95% CI 1.83-
3.89, p<0.001)).
The concept behind this locally-
directed program was that households
would be more likely to carry out
testing (offered) and remediation if
they have someone local (i.e. Local
Authority - local government
organization) who they can go to with
questions. As part of the program,
local authorities actively contacted
households and supported high radon
homes by providing advice on
remediation options at "radon road
shows" and free house visits. No data
on mitigation were provided.
Demographic variables measured
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included age, gender, "social grade,"
and homeownership.
Riesenfeld et
al., 2007
To evaluate radon mitigation
practices of Vermont
residents participating in a
voluntary state health
department radon testing
program found to have high
radon levels
To increase
radon
mitigation
Sample of Vermont
residents with high
household radon levels
((>148 Bq/m3) that
received and returned
free radon test kits
from the VT Health
Department between
1995 and 2003 (n=286).
Paper-based survey sent to
homes by mail containing
questions on radon
awareness, testing and
mitigation behavior,
barriers to mitigation, and
demographic data. Authors
included a one dollar
incentive to complete and
return the survey.
Response rate: 63% (179). 89% stated they
were concerned about their radon level, and
74% tested because they were concerned for
their health. 16% (28) of homeowners stated
testing was done as part of a real estate
transaction. Mitigation rate was 43% (76); of
the homes that were mitigated, 67% (51 of
76) were completed by a contractor, and 32%
(24 of 76) were completed by a member of
the home or friend. 47% (36 of 76) claimed
mitigation costs exceeded $1,000, 32% (24 of
76) claimed mitigation costs were between
$100-$1,000, and 19% (14 of 76) claimed
mitigation costs were under $100. Common
reasons for not mitigating was lack of concern
for elevated radon and expense. A motivating
factor to remediate was concern for real
estate value.
Authors suggest associating radon
testing with real estate transactions is
likely to influence residents to
mitigate as home value appears to be
a significant concern. Demographic
information was collected. For the
respondents who mitigated, the types
of mitigation performed were
ventilation systems, cracks sealed, or
doors/windows opened; respondents
could indicate multiple answers for
the type of mitigation performed, so
there is not a direct correlation
between cost and mitigation action.
However, the EPA assumed
mitigations performed by a certified
contractor and mitigation cost over
$1,000 are sufficient in reducing home
radon levels
Ryan, D. and
Kelleher, C.,
1999
Investigate radon mitigation
actions of households with
high radon levels in the
Galway, Ireland area.
To increase
radon testing
and mitigation
All households with
high radon levels
measured by the
Radiological Protection
Institute of Ireland in
the Galway area
between 1989-1999.
(n=237).
Qualitative and quantitative
data on participant testing
and mitigation experiences,
attitudes and risk
perception of hazardous
substances, and radon
knowledge collected via
paper-based survey and in-
person interviews. The
entire sample pool (n=237)
was surveyed via paper-
based questionnaire. A
face-to-face interview was
conducted with 10% (14) of
all households who
participated in the paper-
based survey.
Written survey response rate was 61% (141).
43% accurately recalled their radon level. 65%
(91 of 141) of respondents stated some kind
of mitigation had been taken, but in most
cases, this is related to minor home
modification (frequently opening of windows);
respondents claimed remediation costs
ranged from $26-$2,600. Of the respondents
who claimed some sort of remediation, 59%
(83) performed a partial modification or a
minor home modification (opening of
windows), 6% (9) performed complete radon
remediation. Primary sources of radon
information were literature, the media, and
family members: 48%, 40%, and 18%,
respectively. Disincentives to action were
indecision (41%) and expense (29%).
For the 6% of respondents who
performed complete mitigation, we
are assuming the cost was near the
higher end of the claimed remediation
cost ($2,600). For the 59% who
performed partial (insufficient) or
minor home modification, we are
assuming the remediation cost was
near the lower end of the claimed cost
($26). No radon testing/remediation
targeted health campaign to the
Galway area was reported in the
study.
Wang et al.,
1999
Survey of radon remediation
in high radon homes (>148
Bq/m3) in New York State
that have been exposed to
the New York State
Department of Health's
(NYSDOH's) radon awareness,
To increase
radon
awareness,
testing, and
mitigation
Adult residents in high
radon homes (>148
Bq/m3) in New York
recorded in NYSDOH's
radon testing database
(n=l,522).
Cross-sectional statewide
telephone survey
administered from Sep.
1995 to Jan. 1996 to assess
radon risk perceptions,
testing, and remediation.
Using NYSDOH database of
radon testing results,
Response rate: 73% (1,113 of 1,522). Overall,
60% of survey respondents (665 out of 1,113)
reported performing some form of radon
mitigation in their homes: 26% (294 out of
1,113) reported opening windows/doors or
sealing cracks/openings (low-cost method),
while 32% (356 out of 1,113) reported
installing a powered system to increase
All survey respondents had requested
a radon detector (for a small fee) from
NYSDOH before and had their testing
results recorded in NYSDOH's
database. Therefore, all respondents
had been exposed to NYSDOH's radon
public awareness campaigns.
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testing, and remediation
campaign.


authors sampled all homes
with radon levels >370
Bq/m3 and used stratified
sampling by county to
select homes with radon
levels between 148 Bq/m3
and 370 Bq/m3.
ventilation or draw out radon (high-cost
method). About a quarter of respondents
participated in a radon diagnostic assistance
program which provides eligible homeowners
with up to $300 of financial assistance
towards radon mitigation (297 of 1,113). 77%
(229 out of 297) of these participating homes
reported performing some form of radon
mitigation compared to 53% (436 out of 816)
of non-participants. Overall, 72% (480) of
homes cited publicity about radon health
effects as the reason they performed radon
mitigation. 26% (165) of homes reported
requesting radon mitigation information from
NYSDOH and 76% (480) from a radon
contractor.
Some respondents were enrolled in a
radon diagnostic assistance program
that provided up to $300 towards
mitigation expenses for eligible
participants. These respondents had a
higher rate of overall remediation
(high- vs. low-cost methods not
specified) compared to respondents
not in the assistance program.
The study also looked at mitigation
rate by age, household income,
homeownership, and home radon
levels, and examined mitigation type
(high vs. low cost) by household
income and home radon levels. The
low-cost method was used by 74%
(99) of the highest income households
in the study ($75,000+) but only 18%
(2) of lowest income households
(<$12,500). In contrast, 82% (9) of
lowest income households reported
opening windows/doors or sealing
cracks and openings to reduce radon
levels (low-cost) compared to 25%
(34) of highest income households.
Wang et al.,
2000
Survey of radon awareness
and testing in high-radon
counties targeted by public
awareness programs and not
high-radon counties of New
York State.
To increase
radon
awareness and
testing rates
Adult residents in high-
radon (>148 Bq/m3)
and not high-radon
counties of New York
State (n=l,209).
Cross-sectional statewide
telephone survey
administered from Nov.
1995 to Jan. 1997 to assess
radon awareness, testing,
and remediation. Half of
interviews were conducted
in high-radon counties
(targeted by public
awareness programs) and
half in not high-radon
counties. Authors decided
what number of interviews
to conduct per county
based on the number of
owner-occupied housing
units indicated in the 1990
U.S. Census.
The study surveyed 1,209 participants.
Greater radon testing was found in counties
with higher radon levels (18%, 93 out of 510)
compared to other counties (12%, 59 out of
483) among the 993 respondents aware of
radon (i.e. who have heard of radon). Among
respondents aware of radon, 45% (69 out of
152) conducted self-tested for radon, while
24% (37 out of 152) had testing conducted by
radon contractors and 5% (8 out of 152) had
testing done by the Health Department. In
high-radon areas (targeted by public
awareness programs), 48% (45 out of 93) of
households self-tested while 20% (19 out of
93) hired a contractor and 6% (6 out of 93)
had testing done by the health department. In
other areas (not targeted by public awareness
programs), 41% (24 out of 59) of households
self-tested while 31% (18 out of 59) hired a
contractor and 3% (2 out of 59) had it done by
the health department. Among respondents
aware of radon, 152 (15%) had their homes
Authors attributed findings at least in
part to NYSDOH public awareness
programs which target high radon
areas but did not directly evaluate
them. No data on mitigation were
provided. The focus of the study was
on radon knowledge and the
relationship between knowledge and
radon testing. The study also looked at
radon knowledge by sex, age,
education level, homeownership,
county of residence (high/low radon
county). The authors also looked at
testing by these demographic
variables but only among respondents
who have heard of radon.
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tested, of which 12 (8%) got a positive test
result (>148 Bq/m3), of which 5 (42%) took
remedial action. Because numbers were small,
remediation was not included in analysis.

Zhang et al.,
2011
Audit and survey of the UK
radon program. London
homeowners who had high
levels of radon in their homes
were sent surveys on radon
knowledge, mitigation
actions, and demographic
information.
To increase
radon testing
and mitigation
All London
householders in the
national radon
database that have a
test finding high radon
levels (>195 Bq/m3)
since 2000. (n=8,834).
Paper-based survey of
radon levels, perceptions of
radon program and
provided information and
support, mitigation, and
demographic information.
Tenants in private housing
were included in the
sample, but not tenants in
social housing where
mitigation responsibility
falls elsewhere. An
unconditional logistic
regression model was used
to estimate the odds ratio
for remediation, comparing
remediated and
unremediated homes.
Response rate: 49% (4,326). 30% (1,441) of
respondents stated that they had done some
method of remediation to reduce radon
levels. 17% (767 of 4,324) reported mitigation
cost; remediation methods and costs were
reported ranging from $650-$4,000. For those
who adopted an effective method, reported
costs ranged from $1300-$4000. 79% (606 of
767) of those who remediated claimed they
spent less than $1300, and 21% (161 of 767)
spent more than $1,300 on remediation.
Factors that predicted low remediation rates
were high radon level, long length of time in
the residence, smoking, and being an older
(65+) resident.
Householders with higher incomes
and higher socio-economic status
were more likely than others to
remediate. Authors suggest
socioeconomic status is likely to
influence remediation rate and
likelihood of responding to the survey;
therefore, the remediation rate
reported in this study may be inflated.
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