Editor’s note: Providence resident Donald Pryor sent this letter to Dr. Nicole Alexander-Scott, director of the Rhode Island Department of Health, last month to express his concerns about lead in drinking water.
Providence Water has one of the poorest records in the country for lead-contaminated drinking water. The Rhode Island Department of Health has delegated responsibility for enforcing federal laws and rules to ensure safe drinking water, something that currently cannot be regarded as successful. As part of the latest Bilateral Compliance Agreement (dated April 2017), Providence Water was required to submit a Lead Service Line Replacement Plan.
The Lead Service Line Replacement Plan submitted Sept. 15 is, in fact, not a replacement plan but merely a statement of what is currently being done. It does not propose a goal for replacement, nor estimate what would be required to reach such a goal. The Department of Health cannot meet its responsibility by continuing to waive the 7 percent annual service line replacement requirement under the federal Lead and Copper Rule. The 7 percent replacement rate would mean nearly 15 years to complete replacement — hardly ideal but a big improvement over current prospects.
Virtually all experts agree that replacement of lead service lines has to be the goal. Corrosion control and flushing measures cannot be viewed as long-term solutions. Providence Water’s latest proposal to add orthophosphate to drinking water to reduce lead leaching is likely to do significant damage to freshwater lakes, streams and rivers in the state, impose significant added costs to wastewater treatment facilities, and undermine the effectiveness of stormwater management. The Rhode Island Department of Transportation alone has committed $100 million to meet its stormwater requirements that are largely driven by the need to reduce phosphorus in the environment.
Lead service line replacement is not without costs but those costs need to be estimated and Providence Water needs to commit to seeking and requesting the needed funds. Costs are likely to be only a fraction of Providence Water’s current water main rehabilitation and replacement program (which had previously been described as a 10-year program but the most recent rate increase request described as “continuing.”)
There continues to be confusion about partial lead service line replacement. There is near consensus among experts that partial lead service line replacement exposes consumers to elevated lead levels, perhaps for a short time but perhaps indefinitely. Providence Water lead service line replacement fact sheets say nothing about this risk. This appears to be an important factor in the low participation rate of customers in replacing private-side lead service lines. The fact sheet Deciding Whether to Replace Your Lead Service Line emphasizes why not but completely omits description of risks and financial incentives, such as the 3-year, zero-percent loan pilot program and North Providence’s Community Development and Block Grant. Increasing incentives and better communication of both risks and incentives is essential to improving private participation.
Providence Water has been inconsistent about opportunities for lead service line replacement outside water main project areas. Neither the plan nor the fact sheets discuss this. In a personal inquiry, I was told that a customer could replace his private side lead service line but Providence Water would not replace its portion of the service line except in project areas. The result would likely be the same increased exposure, as for any partial lead service line replacement.
There was a subsequent statement in materials sent with billings that stated the opposite — that Providence Water would arrange to replace its portion of lead service lines at the same time as a customer had the private side replaced. Unfortunately, the submitted plan says nothing on this issue.
Childhood blood lead levels in Providence have been decreasing but are still considerably above national averages. The Department of Health has emphasized prevention of exposure through lead paint and that effort is likely primarily responsible for the improvement. However, there has been very little improvement in exposure through drinking water — it needs to be addressed more strongly.
Providence Water’s proposed replacement plan should be returned with instructions on what is needed for such a plan to be acceptable. A real plan and public discussion is needed.