Lead Pipes Position paper

Replace Lead Water Pipes: A CLASH position paper.

February 14, 2022

CLASH recommends that the City of Cleveland Water Department (CWD) expand their efforts to replace lead service lines in the city of Cleveland using Federal Infrastructure funding which will be made available through the Water Supply Revolving Loan Account (WSRLA) later this year. In preparing to make an application for this funding, the Cleveland Water Department can build on the current efforts underway in the current pilot project which focuses on replacing Lead Service Lines (LSL) for child care facilities.

  1. Background.

Ohio ranks 2nd among Midwest states in the number of lead service lines and is in the top ten of all states. CWD has an online tool to assess whether a particular service line is likely to be lead.

  • CWD relies on interim controls to reduce how much lead leaches into the water system. These interim controls include use of orthophosphate and control of the pH of the water.

  • With an estimated 110,000 lead service lines in the City at an average cost of $4,000 per public-side replacement, approximately $440 million dollars will be needed to replace every lead service line in the City. At the same time, additional money would be needed to make the corresponding private-side service replacements, depending on site-specific considerations.

  • CWD complies with the US EPA Lead and Copper rule by spot checking water from customer taps. The EPA Lead and Copper Rule has recently been strengthened, calling for testing procedures that capture water which has been held in lead service lines longer while also lowering the permissible level of lead in drinking water samples. CWD will be required to meet the new standards by 2024.

  • CWD currently has a program to replace LSLs for 450 Child Care facilities. The program is funded by Ohio EPA’s Water Supply Revolving Loan Account (WSRLA) forgivable loan and a grant from Ohio’s H2Ohio Fund. Total project cost is $1,000,000. Under this program, CWD replaces both public service lines and service lines into the child care facility at no charge to the property owner.

  • Coordinating with CWD, the Ohio Department of Health is working on a pilot program (WIIN) to provide lead water testing and counselling to Cuyahoga County child care providers deemed to be high-risk areas based on risk factors such as their presence in areas with high incidences of Elevated Blood Lead Levels.

2. CLASH Recommendations

  • CWD should continue interim controls using orthophosphate and pH controls in the water treatment system in order to provide protection from lead as LSL replacement proceeds and to continue stabilizing lead in fixtures inside of the home. Maintaining interim controls will come with a cost of constant vigilance to increasingly more rigorous requirements of the Lead and Copper Rule.

  • CWD should implement the new requirements of the EPA Lead and Copper Rule as soon as possible. Getting support from the WSRLA will require a comprehensive plan that includes compliance with the Lead and Copper Rule. One side-effect of coming into compliance with the Lead and Copper Rule will be that CWD will identify more lead problem spots. CWD should provide water filters free of charge until public and private service line replacement can be performed at any location where an exceedance is detected, prioritizing low income areas.

  • Require child care facilities to show proof of LSL replacement in order to obtain a license to operate.

  • Expand the current LSL replacement program for Child Care facilities to include LSL replacement at schools. Funds from the Bipartisan Infrastructure Law (BIL) will be available through WSRLA later this year. In case BIL funding through WSRLA is not fully forgivable, CLASH recommends that additional funding be sought from H2Ohio or from the ODH fund for Lead Safe Innovations. Additional funding to address schools and federally assisted housing may become available if the Build Back Better bill is passed by Congress.

  • Support expansion of Ohio’s WIIN program to provide lead water testing and counselling to child-serving facilities that don’t have lead service lines, but may have internal plumbing and fixtures that have lead hazards. These facilities may be eligible for additional grants. In the event that Build Back Better funds become available, CWD should give priority to child care, educational and Federally assisted housing that are located in areas that have elevated blood levels (EBLLs).

  • In the event that Build Back Better funds become available, CWD should give priority to child care, educational and Federally assisted housing that are located in areas that have elevated blood levels (EBLLs).

3. Other recommendations to overcome barriers to lead line replacement.

  • Create a team of outreach professionals to educate and recruit child serving organizations to cooperate with CWD’s programs for LSL replacement and facility water testing where there are no LSLs that require replacement. It’s clear that the CWD’s outreach efforts using telephone, email and social media have not been as successful as is needed to enlist the cooperation of child serving facilities and this challenge is sure to increase as the program scales up. This same outreach team can be used to encourage child serving organizations to participate in Cleveland Department of Public Health’s mobile child lead testing van at their child care or educational facilities.

  • The Mayor’s Lead Czar should reach out to the Mayor’s appointees to the Cleveland Municipal School District and the Cuyahoga Metropolitan Housing Authority to urge both entities to establish liaisons between CMSD and CMHA and CWD. Both CMSD and CMHA should prepare plans for LSL replacement so they are ready to seek Federal financial assistance for LSL and fixture replacement through the Build Back Better Act, when it is passed by Congress and signed by President Biden.



Ohio has second most lead water-supply pipes in U.S.; infrastructure plan would replace them