Commitment and Purpose at All Levels

• Author: Suzanne Chiavari
• Position: Engineering director for treatment and asset resiliency at American Water
• Pages: 60-60

60 | THE ENVIRONMENTAL FORUM Reprinted by permission from The Environmental Forum®, November/December 2021.

Copyright © 2021, Environmental Law Institute®, Washington, D.C. www.eli.org.

THE DEBATE

positioned to drive successful LSLR

programs. Individual homeowners

across the country cannot do this on

their own.

On a federal level, EPA’s revised

Lead and Copper Rule includes a

number of important improvements

over the existing LCR and should ac-

celerate future replacement programs.

However, to achieve an impact level

closer to 100 percent, all utilities

with lead service lines — not just

mandated utilities — would need to

implement replacement programs.

Funding Drinking Water State

Revolving Loan Fund programs,

which were established under the Safe

Drinking Water Act, is also key to

accelerating the elimination of lead

pipes. All water systems should have

access to these programs, regardless of

ownership type, and state programs

should work to eliminate other per-

ceived barriers that may exist. Even

so, these programs are neither robust

nor comprehensive enough to reach

every utility with lead. Additional

tools are needed if lead service lines

are to be quickly eliminated across the

country.

Combining utility construction

dollars with state revolving loan

funds is an eective strategy to accel-

erate this work and make a broader

impact. American Water has worked

with numerous state public utility

commissions, consumer advocates,

state and local representatives, and

other stakeholders to drive solutions

that allow this work to be funded

within utility infrastructure replace-

ment programs. Note that our utility

LSLR programs are not driven by a

LCR regulatory requirement, since

we already comply with water quality

standards. Rather, they are driven by

a desire to serve the long-term inter-

est of our customers and the commu-

nities they live in, and help advance

the elimination of lead service lines in

areas where they still exist.

Experience in multiple states has

shown us that constructive regulatory

practice can support LSLR programs.

Legislation in Indiana and Pennsylva-

nia serves as a notable example. ese

states identify customer lead service

line replacements as improvements

eligible for inclusion in infrastructure

cost recovery mechanisms for rate-

making purposes. Another example

can be found in Virginia, where

American Water uses a combination

of utility construction dollars and

funding from a program established

by the Virginia Department of

Health. e department’s Drinking

Water State Revolving Loan Fund

program provides limited funding

specically designed to accelerate the

removal of lead pipes for both public

and private portions.

To make LSLR programs ecient,

it is better to focus available dollars

directly on funding replacements as

opposed to creating elaborate pro-

grams that drive up administrative

costs. Customer loan programs may

initially sound attractive, but they

can be costly due to customer credit

issues, defaults, and the diculty in

enacting property liens. Eorts are

better directed to nding solutions at

the local and state levels that can help

streamline LSLR programs. ese

actions could include bundling con-

struction contracts, and streamlining

processes for street opening permits

and plumbing permits, just to name

a few options.

American Water holds water qual-

ity and safety paramount. We take

critical steps during the water treat-

ment process to reduce the potential

for lead to leach from pipes into

the water. We are well aware that it

will take time to reach 100 percent

replacement, and note that there are

other actions that utilities take to

reduce the potential risk from lead

service lines. Our experience shows

that achieving these goals will require

commitment and tenacity of purpose

by all stakeholders involved, and le-

veraging the expertise and leadership

of utilities will be key to this success.

Suzanne Chiavari is engineering director for

treatment and asset resiliency at American Water.

Commitment

and Purpose at

All Levels

By Suzanne Chiavari

OUR nation’s water and

wastewater infrastruc-

ture is essential to public

health and safety, en-

vironmental protection, and com-

munity growth. American Water

appreciates the Biden administration’s

recognition of the need to invest in

our country’s water systems, and its

focus on lead service line replace-

ment, or LSLR.

American Water has been a leader

in developing practices for addressing

lead in drinking water systems for

many years. As the country’s largest

and most geographically diverse in-

vestor-owned water utility, we regu-

larly plan for the future and invest in

renewing our systems’ infrastructure.

Our future includes leveraging new

applied technologies to enhance ser-

vices related to water quality, water

pressure, energy eciency, and water

eciency. Lead pipe must not be a

part of that future.

What will it take to accelerate

LSLR programs across the country?

It will take commitment and tenacity

of purpose at all levels to overcome

barriers. American Water knows that

addressing the issues around lead in

drinking water, including removing

lead service lines, is a shared respon-

sibility. is includes customers,

regulators, health ocials, and water

utilities, among others.

We have direct experience in an-

swering this question. Since 2017,

we have replaced about 29,000 lead

lines across our service areas. Beyond

nancial resources, we also need to

recognize that this undertaking re-

quires skilled tradespeople, excellent

communicators, safety-focused con-

tractors, and eective construction

project managers. Many water utili-

ties possess such talents and are well