Freshwater 510 Policy Brief

Milwaukee, Wisconsin as a Case Study for National Lead Drinking Water Infra-

structure Challenges

Executive Summary: Aging drinking water infrastructure is an issue facing many American cities; cost

estimates for upgrading the entirety of the nation’s drinking water infrastructure are in the hundreds of

billions of dollars. Lead infrastructure in particular is an issue of growing concern as many municipalities

are forced to face the reality of antiquated infrastructure reaching the end of its useful life. Existing poli-

cies regarding lead pipe detection and rehabilitation are outdated and need reconsidering in order to tack-

le these increasingly complex and prevalent issues.

In 2013, the United States Environmental

Protection Agency (EPA) completed its fifth assess-

ment of public drinking water infrastructure needs.

The results of this survey indicated that $384.2 bil-

lion is needed for infrastructure projects from 2011-

2030 in order to ensure that the entire population has

access to safe drinking water (US EPA 2013). The

EPA goes on to conclude that the nation’s water sys-

tem has entered a, “rehabilitation and rehab era”, as

infrastructure deterioration nears reaching critical

mass (US EPA 2013). The total cost was divided in-

to specific components in need of upgrades; trans-

mission and distribution networks were shown to

account for most of the need highlighting the fact

that the nation’s drinking water infrastructure is

quickly nearing the end of its useful life (Figure 1).

Lead drinking water infrastructure prevalence

A large part of drinking water infrastructure

needs includes replacing the high amount of anti-

quated lead pipe infrastructure throughout the nation.

The American Water Works Association estimated

in 1990 that there were over 3 million lead service

lines and over 6 million lead connections in the

homes and businesses in America (Schmidt and Hall

2016). Lead is a powerful neurotoxin that can cause

biological and developmental deficits and is espe-

cially dangerous to children; estimated societal costs

of lead poisoning in the United States have been tal-

lied in the billions (Hanna-Attisha et al. 2016).

Although most drinking water systems containing lead

infrastructure are able to use inhibitory agents, such as

ortho-phosphate, to prevent the corrosion of pipes and

associated leeching of this dangerous metal, situations

can still arise where exposure is inevitable. The ongo-

ing crisis in Flint Michigan highlighted this all too

well as the entire city was effectively poisoned due to

a combination of antiquated infrastructure and admin-

istrative negligence (Sanburn 2016). Dealing with out-

dated lead infrastructure is a challenge that absolutely

must be addressed in order to meet drinking water in-

frastructure needs.

The distribution of the millions of lead pipes in

the nation is not even; lead infrastructure is particular-

ly common in many Northeastern and Midwestern

states, such as the state of Wisconsin. A limited EPA

study concluded that there were over 176,000 lead

service lines throughout the state, with the highest

Figure 1. National drinking water infrastructure needs by cate-

gory. Source: EPA

Freshwater 510 Policy Brief

numbers in the more urban areas such as Mil-

waukee, Wausau, and Racine (Schmidt and Hall

2016). Milwaukee alone accounts for around

77,000 of these lead service lines and faces a

$500 million bill in order to remove all of them

(Behm 2016) (Figure 2). The city does use ortho

-phosphate inhibitory agents to prevent lead

from leeching, but this practice can have ramifi-

cations in terms of water quality in surrounding

areas, in this case Lake Michigan (Schmidt and

Hall 2016). There is also the risk for catastrophic

failure of the antiquated lead pipes, which has

prompted the Wisconsin Public Works Commis-

sion to put pressure on Milwaukee in the past to

increase its yearly rate of lead pipe removal

(Behm 2014).

Figure 2. Prevalence of lead drinking water infrastructure

in Milwaukee, WI. Source: Milwaukee Public Works

Department

Current policy for lead infrastructure

The majority of the current policy regarding lead

infrastructure replacement stems from the federal Lead and

Copper Rule. An EPA regulation enacted in 1991, the Lead

and Copper Rule requires water system administrators to

regularly test customers taps for levels of lead and copper.

If lead levels are in excess of 15 parts per billion (ppb) in

more than 10% of homes surveyed, then anti-corrosion

measures must be applied to prevent leeching (EPA Lead

and Copper Rule). However, the requirements for conduct-

ing surveys to detect the presence of these metals seems to

fall short of truly meeting the goals set out in the Lead and

Copper Rule. Due to a history of compliance, Milwaukee is

currently on a reduced surveying schedule and only has to

test for lead in 50 homes throughout the city every three

years (Schmidt and Hall 2016). Only surveying 50 homes

seems as if it would give a gross misrepresentation of the

prevalence of lead in the city considering that nearly

600,000 people call Milwaukee home. Furthermore, the

sampling protocol for the rule was evaluated and found to

consistently miss high levels of lead due to daily fluctua-

tions in homes serviced by lead lines (Del Toral et al.

2013). Lastly, the Lead and Copper Rule allows for 10% of

homes to be in excess of the 15 ppb cutoff. This means that

even though the city may be in compliance, there will still

be members of the population exposed to elevated levels of

lead in their drinking water. This is particularly disturbing

considering that the Safe Drinking Water Act’s (SDWA)

maximum contaminant level goal (MCLG), or contaminant

level at which there are no known health effects, for lead is

zero (EPA Table of Regulated Drinking Water Contami-

nants). While well intentioned, the Lead and Copper Rule

could use updating in order to adequately assess where lead

contamination may be prevalent as well as to keep the en-

tire population safe from the toxic effects of exposure.

If the aforementioned corrosion measures required

by the Lead and Copper Rule are ineffective or compliance

is breached further, then a municipality could be required to

increase its replacement rate of lead infrastructure, which

brings additional challenges (Schmidt and Hall 2016).

Freshwater 510 Policy Brief

Lead pipes in cities are found in both the large

water mains as well as the smaller service lines

that branch off of these mains and cross individ-

ual property lines to serve individual homes and

businesses. Municipal lead removal projects are

only able to focus on the portion of the infra-

structure that is owned by the utility, which ex-

tends only to the property line (Schmidt and Hall

2016). When the utility removes these mains but

leaves the lead lateral service lines intact, there

are two main issues that arise. The first is that

the lead lateral service lines remain which makes

the removal of the main almost superfluous in

terms of preventing lead from getting into the

water supply. Second, it has been shown that

removal of lead mains in neighborhoods that al-

so have lead service lines causes contamination

and extremely high levels of lead during the

construction process (Schmidt and Hall 2016)

(Del Toral et al. 2013). This predicament is what

prompted the city of Milwaukee to temporarily

pause its lead removal efforts while a plan is for-

mulated to address the issue before continuing

with water main replacement projects (Behm

2016). The Milwaukee County head of public

health, Paul Biedrzycki has commented on this

describing the situation as a tradeoff between

upgrading infrastructure and avoiding construc-

tion-induced lead contamination (Schmidt and

Hall 2016). It is clear that a new, integrative, and

well-thought out approach is needed in order to

safely replace both lead mains as well as lead

laterals without exacerbating lead contamination

problems.

Moving Forward

Updating the Lead and Copper Rule

seems as though it would provide a means to

better assess which communities have issues

with lead in their drinking water, as well as

where exactly in those communities to focus

replacement efforts. The present issues with sampling

schedule and technique illustrated by the Del Toral study

are disturbing in the sense that problems with lead drinking

water infrastructure could be underestimated (Del Toral et

al. 2013). In order to accurately assess the exact prevalence

of lead infrastructure in cities such as Milwaukee, surveys

should be expanded and combined with long-term monitor-

ing schedules. In this way, problematic areas can be more

easily defined and remediation efforts can be focused.

However, this type of approach has the potential to present

a trade-off scenario in which more resources may be ex-

pended only to find that there may not be as prevalent a

lead problem as previously anticipated. Fortunately, the

more data that is gathered regarding the exact location of

problematic lead infrastructure, the more accurate further

assessments and remediation projects will become.

The issues that arise from the practice of lead main

removal while lateral service lines remain are complex and

require a holistic approach to ensure that remediation ef-

forts are effective and not causing further fluxes of lead into

the water supply. Fortunately, there is a city near Milwau-

kee that was able to utilize such a holistic approach to re-

move virtually its entire lead infrastructure while minimiz-

ing complications. Beginning in 2001, Madison, WI entered

the construction phase of a decades-long lead removal pro-

ject in which they attempted to remove all of the lead mains

and laterals found throughout their city (Behm 2016).

Figure 3. A city of Madison crew works to replace a lead service line

leading into a private residence. Source: Wisconsin Watch

Freshwater 510 Policy Brief

References

Behm, Don. "Milwaukee Faces Daunting Costs with Lead Water Pipes." Milwaukee Faces Daunting Costs with Lead Water Pipes.

Milwaukee Journal Sentinel, 27 Jan. 2016. Web. 03 Mar. 2016.

Behm, Don. "Milwaukee Ordered to Step up pace of Water Main Replacement." Milwaukee Ordered to Step up pace of Water

Main Replacement. Milwaukee Journal Sentinel, 14 Sept. 2014. Web. 03 Mar. 2016.

Del Toral, Miguel A., Andrea Porter, and Michael R. Schock. "Detection and evaluation of elevated lead release from service

lines: a field study." Environmental science & technology 47.16 (2013): 9300-9307.

Hanna-Attisha, Mona, et al. "Elevated blood lead levels in children associated with the Flint drinking water crisis: a spatial analy-

sis of risk and public health response." American journal of public health 0 (2016): e1-e8.

"Lead and Copper Rule." EPA. Environmental Protection Agency, n.d. Web. 03 Mar. 2016.

"Table of Regulated Drinking Water Contaminants." EPA. Environmental Protection Agency, n.d. Web. 03 Mar. 2016.

Sanburn, Josh. "The Toxic Tap." Time 1 Feb. 2016: 32-39. Web.

Schmidt, Silke, and Dee Hall. "Lead Pipes, Antiquated Law Threaten Wisconsin's Drinking Water Quality." WisconsinWatchorg.

Wisconsin Watch, 01 Feb. 2016. Web. 03 Mar. 2016.

Schmidt, Silke. "First in the Nation: City of Madison Replaced All Lead Pipes." WisconsinWatchorg. Wisconsin Watch, 01 Feb.

2016. Web. 03 Mar. 2016.

United States of America. Environmental Protection Agency. Office of Water. Drinking Water Infrastructure Needs Survey and

Assessment: Fifth Report to Congress. Washington D.C. 2013. Print.

The impetus for this project was largely to avoid

eutrophication issues for the two large lakes sur-

rounding the city that could arise due to the use

of ortho-phosphate inhibitory agents (Schmidt

2016). Madison was able to achieve their goal of

removing all lead infrastructure by providing a

monetary incentive program for private property

owners to work with the utility to incorporate

lateral service line replacement during main re-

placement projects (Behm 2016). In this way,

they were able to solve the problem of laterals

remaining after lead replacement as well as the

construction-based lead flux issues all at once.

While Madison is significantly smaller than Mil-

waukee and had less lead infrastructure preva-

lence, their approach can serve as a useful model

from which to model Milwaukee’s own lead in-

frastructure replacement program.

Conclusion

The fact that the United States’ drinking water

infrastructure is nearing the end of its useful life has

been highlighted by studies from government agencies,

by the recent crisis in Flint, Michigan, as well as by the

struggles municipalities are experiencing in regards to

coming to terms with how to tackle these increasingly

complex problems. Unfortunately, antiquated 20th cen-

tury infrastructure is currently paired with antiquated

20th century-based surveying and rehabilitation policies

and practices. Moving forward, these policies and prac-

tices will need to be modernized in order to address the

drinking water infrastructure issues of the 21st century.

Modernization will be the first step towards continuing

universal access to clean drinking water for all.