Ald. Manaa-Hoppenworth Urges EPA to Strengthen Lead Service Line Rule
Administrator Michael S. Regan
U.S. Environmental Protection Agency
1200 Pennsylvania Ave., NW
Washington, D.C. 20460
Dear Administrator Regan:
We write today as elected officials representing constituents in Chicago, IL to submit public comments on the proposed Lead and Copper Rule Improvements (LCRI) issued by the U.S. Environmental Protection Agency (EPA). We share a common interest in protecting our communities from the adverse health risks associated with contaminated drinking water. Chicago has approximately 409,000 lead service lines, more than any other city in the country, and we seek your partnership as we build on our progress to expedite the replacement process.
We applaud the EPA’s leadership in unveiling the LCRI proposal and its commitment to fully replacing the nation’s lead pipes within 10 years. As you know, low-income communities and communities of color are disproportionately impacted by contaminated drinking water. Even the lowest level of lead exposure can cause emotional and behavioral issues in children and cardiovascular and maternal health issues in adults – sometimes fatal. The presence of lead pipes is a public health threat and an environmental justice issue, and it’s imperative that our most impacted communities are prioritized throughout the replacement process.
While there’s a lot to praise in the LCRI proposal, there are a few key components that we urge the agency to address in order to strengthen the rule:
Reconsider the exception to the 10-year removal mandate: Chicago would receive an extension of 44.6 to 55.8 years to replace our lead service lines. It is unconscionable to tell Chicago residents that they have to wait generations for safe drinking water. Although we appreciate the flexibility we have been offered, we would like to discuss a shortened timeline that’s coupled with adequate federal funding to complement our efforts.
Require water systems to fully pay for the removal of lead service lines: It can cost $30,000 or more for a resident to replace a single lead service line in Chicago. Although the Chicago Department of Water Management is exploring ways to reduce the cost of replacement and currently offers various programs to incentivize homeowners to take on replacement, we’ve seen in other cities that it’s less expensive, faster, and more equitable to have the utility cover the full cost of lead service line replacement. A resident should not be denied access to safe drinking water because of their lack of ability to pay or landlord absenteeism.
Enact strong protections for schools and childcare centers of all sizes, including filter installation: While some smaller schools and childcare centers that are serviced by a lead service line and/or lead fixtures may benefit from the proposed rule, larger schools and childcare centers will be left out because the proposal’s testing program retains weak elements from the previous rule. We urge the EPA to require comprehensive lead testing in all schools and childcare centers and point-of-use filters to protect the health and safety of our children, regardless of where they’re enrolled.
Reduce lead action level to 5 ppb: We applaud the agency’s step in reducing the lead action level from 15 ppb to 10 ppb, but it’s important that we take another step and lower the action level to 5 ppb to be on par with the drinking water standards of other countries, such as Canada and the European Union, as well as recommendations from the medical and public health community.
Although there is room for improvement in the LCRI proposal, we commend the EPA’s commitment to improving drinking water protections across the nation. Chicago has benefited from this commitment as a recipient of a $336M WIFIA loan to support our lead service line replacement efforts. As elected officials representing a renter-dominated city, we hope you consider our recommendations for the best way to achieve success, as we’ve seen in cities like Newark, NJ, and ensure that our most impacted communities are prioritized.
Thank you Administrator Regan, Assistant Administrator Fox, and all EPA members involved for your continued support and leadership.
Sincerely,
Chairperson Gilbert Villegas, Committee on Economic, Capital and Technology Development
Chairperson Maria Hadden, Committee on Environmental Protection and Energy Ald. Daniel La Spata, 1st Ward
Ald. Brian Hopkins, 2nd Ward
Ald. Pat Dowell, 3rd Ward
Ald. Lamont Robinson, 4th Ward
Ald. Desmon Yancy, 5th Ward
Ald. William Hall, 6th Ward
Ald. Peter Chico, 10th Ward
Ald. Julia Ramirez, 12th Ward
Ald. Jeylú B. Gutiérrez, 14th Ward
Ald. David Moore, 17th Ward
Ald. Ronnie Mosley, 21st Ward
Ald. Byron Sigcho-Lopez, 25th Ward
Ald. Jessie Fuentes, 26th Ward
Ald. Ruth Cruz, 30th Ward
Ald. Scott Waguespack, 32nd Ward
Ald. Rossana Rodriguez-Sanchez, 33rd Ward
Ald. Carlos Ramirez-Rosa, 35th Ward
Ald. Samantha Nugent, 39th Ward
Ald. Andre Vasquez, 40th Ward
Ald. Bennett Lawson, 44th Ward
Ald. Angela Clay, 46th Ward
Ald. Matt Martin, 47th Ward
Ald. Leni Manaa-Hoppenworth, 48th Ward
