Tell EPA: Don’t Replace Lead Pipes with Plastic Pollution
EPA Administrator Michael Regan & Local Representatives
An estimated 22 million people in the US rely on toxic lead service lines for their water. Lead is a dangerous chemical known to damage kidneys, harm heart health, and affect brain development in children.
Lead pipes disproportionately impact BIPOC communities. This is a public health and environmental justice emergency. Thankfully, the federal government recently approved $15 billion dollars to be distributed to states to replace lead service lines.
However, as states begin replacing their lead pipes, we must ensure lead pipes are not replaced with plastic pollution.
To ensure access to safe drinking water during lead pipe replacement, communities must be provided with options for filtered water. Water filters are critical to reduce lead exposure risk before, during, and up to six months after service line replacement.
Single-use plastic water bottles are not the solution for clean drinking water. They are a health threat at every stage of their existence, from the air pollution emitted by plastic production facilities in fenceline communities, to the toxic chemicals and microplastics released by plastic when it is consumed and disposed.
The lead services pipes should be replaced with non-toxic materials, not plastics like PVC. Plastic pipe materials can similarly leach toxic chemicals and microplastics that accumulate in the environment and in our bodies.
Urge the EPA and your local representatives to provide Filtered, Not Bottled water and Plastic-Free Pipes during lead pipe replacement.
UPDATED January 19, 2024: On November 30, the U.S. Environmental Protection Agency (EPA) released the Draft Lead and Copper Rule Improvement (LCRI), a strengthened version of the Lead and Copper Rule that was originally published in 1991 to control lead and copper in drinking water. As strongly recommended by Plastic Pollution Coalition and other leading experts and community advocates, the newly drafted rule requires water systems with consistently high levels of lead to make available filters certified to remove lead from water, rather than single-use water bottles. This is a significant step forward. However, the draft language does not go far enough. The LCRI draft must be strengthened to:
Require water systems to distribute filters to water system customers at no cost to the customer.
Provide customers with education materials and training on filter efficacy, and filter use and maintenance.
Reduce the number of lead action level exceedances and time period required in order to mandate filter distribution, as well as the time for filter program implementation.
Ensuring expedient distribution of filters and proper education is critical to provide families with safe, clean drinking water as soon as possible, while mitigating the use and disposal of hundreds of billions of single-use plastic water bottles. The proposed rule also fails to recommend safe replacement pipe materials and advise against unsafe options such as PVC and CPVC plastic pipes which are a toxic pollutant throughout their production, use, and disposal. These measures are critical to ensure safe water access in the decades to come.
EPA Administrator Michael Regan & Local Representatives
From: [Your Name]
**This letter was updated on January 19, 2024 to reflect recent rule proposals made by the EPA Office of Ground Water and Drinking Water.**
First of all, thank you for taking the critical step to replace toxic lead service lines. Lead exposure is dangerous and I'm glad to know that my community will be protected from those risks.
I'm writing with two requests to make sure that the funds provided for lead service line replacements are used in a way that will protect the health and safety of my community.
I want to ensure my community has a reliant supply of safe water before, during, and after the lead service lines are replaced. During the replacements, lead can become displaced and affect water quality for up to six months. Providing options for filtered water is the best solution to give communities access to safe, drinking water free of lead and other toxics.
The most widely relied on alternative, single-use plastic water bottles, pose health problems during their production, use, and disposal. Single-use plastic water bottles are made from climate-warming fossil fuels and the continued production of single-use plastics will only dig us deeper into the climate crisis. Facilities that produce or process plastic and its fossil fuel ingredients pollute air, water, and soil, especially in fenceline communities, causing severe human health problems. I'm also worried about the health risks involved in the use of single-use plastic water bottles. Plastic water bottles contain toxic chemicals, some of which are banned in multiple countries outside the US, and are known to cause long-term negative health effects. Additionally, single-use bottles, like all plastics, break up into microplastic particles, which have been found in human blood, lungs, umbilical cords, placentas, feces, and breast milk.
The use of Filtered, Not Bottled water ensures lead pipes are not replaced with plastic pollution. Certified filters reduce lead exposure, as well as other toxic chemicals and pollutants. Therefore, I ask that every household that undergoes lead service line replacements is provided with water filters. In instances where filters are not applicable, water buffalos, tanks, reusable bottles, or other filtered, safe water sources should be utilized.
We are grateful to see the proposed Lead and Copper Rule Improvement included language requiring water systems that have consistently high levels of lead make filters available to customers. This is a significant step forward. However, the draft language does not go far enough. The LCRI draft must be strengthened to:
1. Require water systems to distribute filters to water system customers at no cost to the customer.
2. Provide customers with education materials and training on filter efficacy, and filter use and maintenance.
3. Reduce the number of lead action level exceedances and time period required in order to mandate filter distribution, as well as the time for filter program implementation.
Ensuring expedient distribution of filters and proper education is critical to provide families with safe, clean drinking water as soon as possible, while mitigating the use and disposal of hundreds of billions of single-use plastic water bottles.
Second, the EPA should ensure that new water service lines are made with safe materials, such as recycled copper. Plastic pipe materials like PVC and CPVC pose health risks during their production, use, and disposal. The EPA should research alternative materials and recommend that states and municipalities use the safest and most sustainable material available for the replacement service lines.
The EPA should make both of these recommendations to states when distributing the funds for the lead service line replacements.
Thank you for putting the health and safety of communities first.