Transparency

Transparency

A principle of effective risk communication is to be open and honest, even when you don’t have all the answers. Utilities that actively share information about lead risks, lead service lines and sampling results build trust and credibility with customers.

 

One of the more difficult aspects of communicating with customers and other stakeholders about lead is the fact that there are often unanswered questions. Given the age and composition of many water systems, it may be impossible to fully account for every lead service line. That should not dissuade utilities from communicating openly and fully about the potential presence of lead service lines in the communities they serve. 

The Lead Service Line Replacement Collaborative provides guidance for water utilities as they prepare inventories of lead service lines in their service areas.

EXTENT OF KNOWN LEAD SERVICE LINE INVENTORY

While most water utilities do not have a searchable, complete inventory of lead service lines in their communities, many have made inroads in identifying specific areas of concern based upon construction age or information gleaned from on-site inspections. Sharing that information with customers demonstrates transparency. Where feasible, visual depictions of the utility’s service area highlighting areas of likely lead service lines should be utilized.

While many variables (i.e. such as the age of the distribution system, quality and quantity of available records, staff resources to identify lead in the field and through records, etc…) determine how much utilities know about the presence of lead service lines in their service areas, most utilities fall into one of three categories:
Very little to no information available (DOC)
Service line inventory under way (DOC) 
Service line composition well understood (DOC)

The language options available above are designed to provide general guidance to help utilities communicate what is known and not known about lead service lines, and in so doing, reinforce that the utility is concerned about its customers’ health and is ready to work with them to solve this issue. They may be easily customized to suit a utility’s individual situation.

SAMPLING PROTOCOLS AND SDWA RULES

While a utility may not be able to tell a specific customer whether lead is present in their water supply, the fact that water suppliers systematically test for lead may be reassuring to many customers and reinforce the fact that utilities put customers’ health first. Explaining—in non-technical language—the concept behind the Lead and Copper Rule and the testing required of utilities is a good first step. In particular, utilities should be candid about the meaning of “action levels” and clearly articulate the results of testing.

STATUS OF LEAD REDUCTION EFFORTS

For utilities with known lead service lines in their distribution systems, the question may arise, “Why haven’t they all been removed?” As utilities know, replacing service lines is both time-consuming and expensive. 

While some entities are reluctant to talk about financial considerations, customers are far more understanding when utilities explain that it is ratepayers’ money being spent, and that—even if it were feasible from a project management perspective—an undertaking of that magnitude would likely result in significant rate increases. 

Sharing information about mitigation measures such as corrosion control programs and reassuring customers that the utility is systematically removing and replacing lead service lines reinforces its commitment to protecting residents while managing costs.

In February 2016, the EPA’s Office of Water issued a memorandum to all EPA Region directors that emphasized the importance of transparency on every level so the American public has enough information to make informed health decisions.

A specific near-term action EPA asked of states is that they “work with public water systems – with a priority emphasis on large systems – to increase transparency in implementation of the LCR by posting on their public website and/or on your agency’s website:

  • the materials inventory that systems were required to complete under the LCR, including the locations of lead service lines, together with any more updated inventory or map of lead service lines and lead plumbing in the system; and
  • LCR compliance sampling results collected by the system, as well as justifications for invalidation of LCR samples”

“Continuing to enhance public transparency and accountability is critical to reassure the public of our continuing work to protect the nation’s drinking water.”

- Joel Beauvais
Former Deputy Assistant Administrator, EPA


As all utilities should know, the Lead and Copper Rule has specific public outreach provisions that are triggered by lead occurrence in drinking water.  All indications are that the revised Lead and Copper Rule will build upon those requirements and require customer outreach by utilities, even if there has been no trigger of the LCR action level.

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