Lead Line Replacement: Missouri Geoff Marke, Chief Economist Missouri Office of the Public Counsel

The Lead State Largest lead deposits in the world. The largest and last (Dec. 2013) primary smelter in the US. Herculaneum, 300,000 ppm (2001 MO DNR) 4 mills, 6 mines and lead battery recycling plant US Department of Health and Human Services (2002) Health Consultation: determination if remedial actions are protective of public health. Herculaneum lead smelter site. http://health.mo.gov/living/environment/hazsubstancesites/pdf/Hercprotectiveaction.pdf

Prelude

School of Athens

Michelangelo

Goya, self-portrait

Into the 20th century

Lead presence still today US EPA (2017) Protecting your family from exposures to lead. https://www.epa.gov/lead/protect-your-family-exposures-lead

Service Lines

Lead Prevention policies and blood lead levels in children aged 1-5 Policy Statement from the American Academy of Pediatrics. Prevention of Childhood Toxicity (2016) Pediatrics . http://pediatrics.aappublications.org/content/early/2016/06/16/peds.2016-1493

Proposed Legislation

386.267 Rate schedules for interim charges or periodic rate adjustment for lead line replacement. Subject to the requirements of this section, any water corporation may make an application to the commission to approve rate schedules authorizing periodic rate adjustments outside of general rate proceedings to provide for the recovery of costs for the replacement of lead service lines and associated mains, valves and hydrants.

Key Points Recovery outside of a rate case; Extend infrastructure replacement outside of St. Louis County; and Include lead service lines. Bill did not move forward.

The Service Line

Main to service line

Interior plumbing

Interior Fixtures Until 2014, brass faucets could legally contain 8% lead by weight Solders and flux are considered lead-free when they contain 0.2% or less of lead

How big of a problem?

Incomplete records

Pilot Study showed estimates were only 63% accurate Flint, Michigan included an inventory of any and all available records of the city which were entered into a GIS database. In total: 43,404 active water accounts; and 12,632 vacant parcels. Based on the best available information it was estimated that Flint Michigan’s service lines broke down as follows:   53% copper pipe; 8% lead pipe; 18% galvanized pipe; and 21% unknown. Pilot Study showed estimates were only 63% accurate

Excavation

The Flint Report estimated the extraction process at $7,500 per household with additional considerations including (but not limited to):

Water and sewer service in same trench Fixture repairs Permits and Fees Total about $2,400 per site, or about 25% of the costs of the “average” replacement. Inspections Finished basements Garbage days Water and sewer service in same trench Fixture repairs Large pipe or odd-fittings Trees Contaminated soil Dust Worker identification Ridley, G. (2016) Flint lead water line replacement begins with controversy. Bridge Magazine Michigan Live http://www.mlive.com/news/flint/index.ssf/2016/03/flint_lead_water_line_replacem.html

Testing

Design can influence results What parameters? Pre? Post? On-site? Off-site? How many times? What conditions? Who conducts the test? Ratepayer? Utility? Government? 3rd party?

The difference two data points can make

Equity

The amount of lead in an American’s body tends to be a quantifiable proxy for socioeconomic status (“SES”) . . . We should also consider the possibility that in addition to SES being a proxy for lead exposure, it might also be, in part, a result of lead exposure. Bellinger, D. (2008) Lead neurotoxicity and socioeconomic status: conceptual and analytical issues. Neurotoxicology. 20(5) 828-838. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC2574977/pdf/nihms72904.pdf

Catch-22 Raising rates will have a disproportionate impact on low-income households. Low-income households will likely have higher % chance of lead service lines, fixtures and other lead-based material in place.

Who pays? Cost Allocation

Customer Specific Pricing

District Specific Pricing

Zonal Pricing

Single Tariff

Single State

Disclosure

Property Value and Resale

Environmental Defense Fund State Disclosure Polices for lead pipes McCormick, L. et al. (2017) Grading the nation: state disclosure policies for lead pipes. Environmental Defense Fund https://www.edf.org/grading-nation-lead-pipe-disclosure-policies

Rate Base Treatment

To be determined…

Who’s first?

Which customers get priority? What about past partial replacement ? Vacant homes and property? Schools? Homes with children?

Next Steps?

Missouri OPC’s position Acknowledges current practice is flawed Propose a pilot study 3rd party stakeholders Academic Institutions Non-profits Explore outside funding opportunities & education Dialogue with regulatory and legislative leaders Hard look at short and long-term opportunity costs and unintended consequences.

Questions? Additional Resources Lead Service Line Collaborative. http://www.lslr-collaborative.org/ American Water Works Association. https://www.awwa.org/resources-tools/water-knowledge/lead.aspx#192271121-search-for-more Geoff Marke, Chief Economist Missouri Office of the Public Counsel Geoff.marke@ded.mo.gov