Removing Lead Pipes while Advancing Environmental Justice in Salt Lake City

New federal laws in the United States are mandating water systems to take further measures against lead in drinking water.

While social equality concerns are being prioritized by cities and local governments in their water infrastructure plans, there is also a growing focus on environmental justice.

The Salt Lake City Department of Public Utilities (SLCDPU), one of the oldest retail water providers in the western United States, is one water utility that is taking the lead on both issues.

In its service area, which includes Salt Lake City, Cottonwood Heights, the City of Holladay, Millcreek, and the east bench of Salt Lake County’s unincorporated areas, SLCDPU provides drinking water to more than 360,000 people, businesses and industries.

As soon as the federal Lead and Copper Rule Revisions (LCRR) became effective, SLCDPU hired Jacobs to provide support services for a visionary compliance program.

Jacobs is assisting SLCDPU with a number of tasks related to LCRR compliance, including coordination with regulatory stakeholders, developing community engagement materials, and a funding options study that includes the evaluation of funding opportunities available through the Infrastructure Investment and Jobs Act, in addition to providing overall program management support for water, stormwater and wastewater capital improvements.

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SLCDPU’s initial priority has been the development of an inventory of its lead service lines.

These lines are components of the drinking water distribution system that typically span both public and private property – and can be a key source of lead contamination of drinking water.

Even though the LCRR requires lead service line inventories to be completed by October 2024, SLCDPU has already undertaken a series of proactive actions to identify lead lines in its service area – including reviewing tens of thousands of public documents, surveying customers and undertaking field investigations and water sampling in homes.

Salt Lake DPU really goes above and beyond those requirements to develop a program that embraces environmental justice.

They are not only proactive in their LCRR compliance.

We anticipate that other communities looking to put equity concerns at the heart of their water infrastructure programs will use their strategy as a model.

The selection of lead service lines in underserved communities has received significant attention, and the SLCDPU has prioritized social equality and fairness in all of its planning and decision-making.

With the assistance of Jacobs, SLCDPU carried out a spatial analysis of areas with a high likelihood of lead service lines using demographic information for low-income and minority communities from the Environmental Protection Agency (EPA) Environmental Justice Screening and Mapping Tool (EJScreen) as well as historical data and indicators like property age.

The resulting visualizations are being used by SLCDPU to pinpoint underserved areas that are most at risk of lead contamination.

SLCDPU Deputy Director Dr. Marian Rice states that “social equity, fairness, and environmental justice permeate everything we do as an agency and we want to ensure that our lead compliance program delivers on our commitment to equity and fairness.”

Jacobs has aided us in identifying the most vulnerable segments of our population and in strategically planning our interventions and financial commitments.

Dustin White, the regulatory program manager for the SLCDPU, adds, “We were able to start on this process early because of the overwhelming support from our leadership.

“Our team is committed to fairly protecting public health and consumer confidence in our community and is extremely passionate about this program.”

Jacobs is assisting SLCDPU in creating a lead service line replacement plan, another requirement of the LCRR, that will prioritize activity in underserved communities, keeping in mind the agency’s environmental justice principles.

An overall financial capability assessment study that Jacobs is carrying out for the SLCDPU, which examines the cumulative financial impact of drinking water, wastewater and stormwater charges on SLCDPU’s customers, is helping to assist this effort.

The study, which makes use of a number of resources, including the EPA’s EJScreen, has aided in identifying environmentally unjust neighborhoods and areas that could benefit from early lead service line action.

DPU is especially aware of the potential financial burden that lead service line replacements may have on underprivileged areas.

Our cost engineers assisted SLCDPU in creating a more precise estimate of the total cost of its lead service line replacement program in order to create a clearer picture of these impacts in conjunction with the overall financial capability study.

This estimation process determined that the overall program’s cost will probably fall between $125,000 and $200,000

These evaluations also put the SLCDPU in a better position to obtain a share of the $15 billion set aside by the Infrastructure Investment and Jobs Act, which gives priority to funding for underserved communities, for the replacement of lead service lines.

We are also assisting SLCDPU in the evaluation of additional funding sources, such as low-interest loan programs for low-income customers.

According to Jennifer Liggett, Jacobs Global Technology Leader for Drinking Water Quality, “Salt Lake DPU is not only proactive in LCRR compliance, but they’re really going above and beyond those requirements to create a program that embraces environmental justice.”

We anticipate that other communities looking to make equity a priority in their water infrastructure programs will use their strategy as a model.

Jacobs is assisting drinking water systems all around the United States in complying with the LCRR, including getting ready for the impending Lead and Copper Rule Improvements, which will impose even stricter regulations.

A guidance document with more details on the LCRR may be found here.

Source: Jacobs 

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