Developing an effective lead service line replacement (LSLR) plan requires effort and expertise. While every approach is unique, there are best practices to follow. Cook County TAP highlights the elements of an effective LSLR plan. This includes real-life examples and strategies implemented in villages and cities across the county and beyond to provide the information you need to create a plan that fits your community’s unique needs.
Know Your Regulations
The first step is to understand the regulatory landscape for LSLR. Cook County TAP’s overview of state and federal regulations is an excellent place to start. In Illinois, community water suppliers must develop a plan to identify and replace lead and galvanized water service lines. The Federal Lead and Copper Rule Improvements released by the US EPA on October 8, 2024, will bring additional LSLR requirements.
Know Your Community’s Ordinances
Can ordinances or permitting requirements be modified to facilitate LSLR progress? Are there new ordinances that need to be considered to streamline efficiencies, such as accessing private property or mandating participation? Some Cook County communities are modifying their ordinances as they develop their LSLR plan. Others, like Chicago and Evanston, waive permitting fees for homeowners removing a lead service line on their own.
Water Service Line Material Inventory and Verification
Illinois’ Lead Service Line Inventory (LSLI) deadline was April 15, 2024, with limited exemptions granted to September 15, 2024. Use historical records, owner reporting, and predictive modeling to develop an LSLI. Verification using visual inspection by trained staff and/or potholing will confirm predictions. A finalized LSLI will help determine the capital needs of your LSLR plan.
As part of its LSLR plan, the Village of Arlington Heights summarizes its LSLI process and its improvement over time. This US EPA presentation also provides a more detailed overview of LSLI processes.
Steps for Completing a Lead Service Line Inventory
To create your municipality's service line material inventory, you might consider some of the following techniques:
- Building records review (e.g., building age and renovation history)
- Community records (e.g., date lead was last used for service lines, water atlas and tap cards, service line installation or maintenance records, property taxes, meter installation records, permits)
- Visual inspection (e.g., resident surveys/photos, utility staff inspection, meter inspection, partnerships with plumbers and other utilities)
- Water sampling (e.g., flushed samples, targeted service line sampling, sequential samples)
- Excavation (e.g., mechanical digging, vacuum excavation, potholing)
Funding
Knowing what funding is available will help shape your LSLR plan. Examples of state and federal funding sources are outlined on Cook County TAP’s Funding page. Other funding sources include property taxes, usage fees, water rate increases, bonds, and owner financial responsibilities. Are you looking to fund high-risk facilities like childcare providers or low-income or otherwise disadvantaged residents? Identifying who will be served can guide funding decisions.
The National Resources Defense Council’s “Deconstructing the Cost of Lead Service Line Replacement” report is a great place to start. The Village of Barrington proposes to combine Illinois EPA loans supplemented with revenue generated from the Village’s water and sewer fund.
Prioritization Plan (Capital Improvement Plan)
Your LSLI provides a baseline for building an LSLR plan. A comprehensive Capital Improvement Plan outlining the full scope of your community's water infrastructure needs can put LSLR needs in context and guide decisions. Use it to include LSLR planning with ongoing capital improvement efforts or to prioritize high-risk facilities for replacement. This will help create efficiencies within your capital improvement system and your LSLR plan. For example, you might plan LSLR work with water main repair/replacement or other water infrastructure projects.
The City of Evanston created a multi-tier implementation plan targeting high-risk facilities, a homeowner-initiated program, and LSLR as part of ongoing water main replacement activities.
Communications Planning
The key to the success of your LSLR program is clear communication with municipal staff, other agencies, community stakeholders, property owners, and residents. Careful communications planning is essential to address state and federal rules. Many require specific content and/or timing considerations. It's best practice to use multiple modes of communication and not wait for the next crisis to engage stakeholders. Build trust by reaching out early and often during your LSLR planning process.
The Village of Evergreen Park proposes some unique outreach strategies.
Design
You’ve gathered information. You understand the local regulations and community ordinances. Now it’s time to design your LSLR program. Who will perform the work? What is the timeline for completion? It's best practice to coordinate your LSLR efforts with other initiatives such as road repair or utility work. Think about your capacity: Do you have sufficient municipal staffing to carry out your LSLR plan or will you need to bid the work out? If you bid the work out, you may need to develop a Request for Proposal (RFP) process for both the replacement activities and additional administrative support.
The City of Evanston provides a general outline of its overall LSLR design with checklists and other templates.
Workforce Development
Nationally, lead service line replacement activities are estimated to generate 56,000 jobs and $104 billion per year, with more than 6,150 jobs created in Illinois alone. As you develop your LSLR plan, strive to keep the jobs and economic benefits – and your investments – in your community through workforce development. Help local businesses develop the skills needed to participate in the LSLR plan and recruit local jobseekers. As you develop a workforce plan, keep in mind your community goals, budget, current workforce supply and demand, and training needs.
The City of Evanston's LSLR plan details its plans to create 13 new positions related to LSLR, hire community members, and implement other workforce development initiatives.
Right of Entry Agreements
Depending on how you design your LSLR program, a Right of Entry (ROE) agreement will be needed to enter and work on a homeowner’s property. At a minimum, this ROE agreement will clarify what the community/municipality is committed to, what the owner(s) is responsible for, and any effective dates or timelines for starting and completing the work. The ROE agreement will provide contractors and workers the necessary permissions to inspect, locate, and remove lead service lines.
Here’s an example of an LSLR ROE agreement from Evanston, IL and here’s an online agreement example from Denver Water.
Program Data Tracking
Tracking progress and performance is an important part of LSLR planning. This information will help you optimize and adjust your LSLR efforts and meet your stated goals in terms of budget, timeline, and stakeholder support. For example, you might regularly update property records and, accordingly, your community’s lead service line inventory. You might track the number of jobs created as a result of your LSLR plan. You might also track the overall LSLR removal costs, lead-in-water testing results, filter distribution, and more.
Keep residents informed and engaged with public facing information about community LSLR efforts. Sharing your data and progress online like Denver Water and the Village of Hazel Crest is encouraged.
Final Checks
Create checklists to ensure all the elements of a successful LSLR are in place for the property. Are all permits pulled, notifications sent, contracts signed, and a coordinated timeline in place?
Here’s an example of the City of Evanston’s LSLR “day of” checklists and workflows.
Recruitment
You’ve designed your LSLR program, but how will residents access the service? How will services be prioritized? Seek to manage the rollout, community engagement, and implementation of the LSLR plan to address the needs of high-risk residents and institutions, and create efficiencies during the replacement process.
Cook County TAP has pulled together engagement strategies that can help with recruitment.
Documentation
Create a system to track your LSLR program and capture critical data. This may include documenting when and where replacements are completed, updating property records, tracking removal and replacement costs, and capturing lessons learned. Aim to create a system that tracks detailed and essential data yet is flexible enough to log unique circumstances.
Denver Water’s “Monitoring and Reporting” resource provides an overview of the types of data it tracks. Note that the Illinois EPA requires yearly updates on progress toward LSLR efforts.
Installation
A successful and efficient installation of the service line will depend on many elements – some of which are under the control of the plumber and some of which are not. Scheduling and communicating with the property owner or manager, being “job-ready”, and completing required paperwork are examples of LSLR elements you can control. The weather or competing projects and events are less controllable and will require flexibility on your part. A clear communication plan for community managers, contractors and plumbers, property owners, and other stakeholders will contribute to a smoother and more controlled LSLR program.
This Denver Water video highlights the coordination required before, during, and after the installation of a service line.
Sampling, Filtering, and Flushing
Following LSLR, it is critical to follow best practices for flushing, filtering, sampling, and aerator cleaning to ensure residents have access to safe drinking water. There are specific rules for these lead in water activities outlined in the Illinois Lead Service Line Replacement and Notification Act and the US EPA Lead and Copper Rule. Review LCR (40 CFR 141.84(e)(3)) for complete sampling, filtering, and flushing rules and sections of the Illinois LSLR and Notification Act. Your LSLR plan should clearly state how you will maintain accurate sampling records and how you will purchase and distribute filters.
The American Water Works Association’s "AWWA C810-17 Replacement and Flushing of Lead Service Lines” outlines minimum standards for flushing and testing water for lead.
Restoration
Surfaces can be disrupted during any construction work. LSLR can impact pavement, sidewalks, landscaping, interior walls, and other areas. Restoring these areas to pre-construction status must be addressed. It is critical to ensure residents know the timing, contacts, and process for restoration activities following their lead service line replacement. Residents should also understand any restoration activities they are responsible for prior to agreeing to LSLR.
For example, the Village of Hazel Crest lists various restoration standards. The City of Evanston will complete all exterior activities, but the building owner is responsible for interior restoration.
After Replacement Sampling
Removing the lead service line doesn’t automatically eliminate lead-in-water exposure. In fact, the LSLR process can initially increase lead concentrations in water at the tap. In addition, the water service line is only part of the entire plumbing ecosystem of a home. This must be communicated to the resident, and a follow-up lead in water testing must be completed. Additional resident counseling regarding other lead-in-plumbing issues will be needed if lead levels do not fall below the action level. Review LCR (40 CFR 141.84(e)(3)) for complete sampling, filtering, and flushing rules.
Don’t forget to document your successes and lessons learned as you implement your LSLR plan. You should also solicit feedback from stakeholders to help you adjust and develop an efficient LSLR plan that best serves your community. Here are some strategies and best practices:
- Provide digital and paper surveys to residents: Resident surveys will elicit feedback on how well your program serves community needs. An LSLR plan that fails to adjust to address issues raised by residents may fail in its goals.
- Celebrate your successes: Getting the lead out of your community’s plumbing system is truly something to celebrate. Use LSLR successes and case studies to drive positive attention and program participation.
- Strive for continuous improvement: Use lessons learned to update your LSLR policies and procedures or make recommendations to decision-makers supporting the program.
- Set a review schedule: Regular records reviews, including quality control, are recommended. Regular reporting to the Illinois EPA and others may also be required. Clean data will put you on solid footing to create accurate and timely reports.