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LSL replacement

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Slideshow for Jackson Lead Service Line Replacement

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LSL replacement

  1. 1. LEAD SERVICE LINE REPLACEMENT City of Jackson’s LSL Replacement Prepared for: February 11, 2020 City Council Meeting Prepared by Office of City Manager City Engineer Department of Public Works
  2. 2. “The purpose of the Lead and Copper Rule (LCR) is to protect public health by minimizing lead and copper levels in drinking water. Lead and copper enter drinking water mainly from corrosion of lead and copper containing plumbing materials. The rule establishes action levels (AL) for lead and copper based on a 90th percentile level of tap water samples. An action level exceedance is not a violation but triggers other requirements to minimize exposure to lead and copper in drinking water, including water quality parameter monitoring, corrosion control treatment, source water monitoring/treatment, public education, and lead service line replacement. All community water supplies and no transient noncommunity water supplies are subject to the LCR requirements.” LEAD COPPER RULING 2018 LEAD COPPER RULE ADOPTED BY STATE OF MICHIGAN REGULATED BY: MICHIGAN DEPARTMENT OF ENVIRONMENTAL GREAT LAKES AND ENERGY - (FORMALLY MICHIGAN DEPARTMENT OF ENVIRONMENTAL QUALITY) CHANGES TO MICHIGAN SAFE DRINKING WATER ACT 2018: • Removal of all Lead service lines in Michigan beginning January 1, 2021 • Communities locate and prioritize lead service line removal • Action level for lead in drinking water lowered from 15 parts per billion (ppb) to 12 (ppb) on Jan . 1, 2025 • Banned partial replacement of service lines • Complete service line inventory submitted to EGLE by Jan. 1 2025
  3. 3. CITY OF JACKSON LEAD COPPER REPLACEMENT TIMELINE: "EGLE appreciates the City of Jackson's proactive LSLR planning efforts and looks forward to further discussions regarding implementation of these requirements. I am providing a quick summary of regulatory requirements relating to the identification and removal of lead service lines (LSL)." -Eric Oswald Director Drinking Water Environmental Health Division Michigan Dept. of Environment Great Lakes & Energy 2. During 2020, water supplies may conduct planning activities in preparation for ongoing LSLR replacement activities. Service line replacement requirements begin the year after completion of the PDSMI. The PDSMI deadline was January 1, 2020, therefore service line replacement requirements begin in 2021. Water suppliers may choose to begin service line replacement efforts in 2020, but LSLR is not mandatory until 2021. 3. Beginning calendar year 2021, water suppliers must replace an average of 5% of their LSLs per year, not to exceed 20 years, unless an alternate schedule in an asset management plan is approved by the department. EGLE is currently developing guidance and criteria by which water suppliers may apply for an alternate replacement schedule. EGLE is reviewing recently received PDSMI data and other information to help inform this guidance. 4. By January 1, 2025, water suppliers must submit a complete distribution system materials inventory (CDSMI) consisting of a robust, service line- specific inventory of materials throughout the distribution system. During or upon completion of the CDSMI, water suppliers may learn additional information that requires adjustments to their LSLR program that began in 2021. 5. Water suppliers are required to report to EGLE annually on the status of their LSLR activities. 1.By January 1, 2020, water suppliers were required to submit a preliminary distribution system materials inventory (PDSMI) to EGLE. This required suppliers to review existing service line records and provide an informed estimate of service line materials throughout the distribution system, with an emphasis on identification of lead service lines and galvanized service lines that are or were downstream of lead piping.
  4. 4. Lawsuit Filed by 4 Water Authorities against Michigan Dept. of EGLE regarding Lead copper rule December 11, 2018 dismissed: “PLAINTIFFS HAVE NOT PRESENTED A CONVINCING ARGUMENT AS TO WHY THE [LEAD AND COPPER] RULES WERE NOT RATIONALLY RELATED TO THE MSDWA’S [MICHIGAN SAFE DRINKING WATER ACT] PURPOSE . . . OF ‘ASSURING THE LONG-TERM HEALTH OF (THE STATE’S) PUBLIC WATER SUPPLIES AND OTHER VITAL NATURAL RESOURCES. AS A RESULT, THE [LEAD AND COPPER] RULES ARE NOT INVALID IN THEIR SUBSTANCE.” -JUDGE CHRISTOPHER MURRAY CHIEF JUDGE OF MICHIGAN COURT OF APPEALS JULY 26, 2019
  5. 5. CITY OF JACKSON LSLR COMMUNITY AWARENESS TIMELINE: • 2014 Flint Water Crisis -spurs action at the state level regarding new practices in safe drinking water • June 2018 -State of MI adopts Lead Copper Rule • August 1, 2018- City staff meet with Senator Shirkey and Representative Alexander to request support in rejection of the drafted LCR bill. Requested to draft a new bill that would allow City to fix lead service lines without a State mandate. • September 4, 2018- City of Jackson City Council files a concurrence in the GWLA request for declaratory ruling. • December 2018- GWLA, Detroit, and other SE Michigan Communities enter lawsuit against MI Dept. of EGLE • March 2019 –Jackson City Council approves increase to water rates to fund LSLR • April 23, 2019 –Jackson DPW Director Jonathan Greene presents to the public the City of Jackson’s proposed cost estimates for Lead Service Line Replacement • August 12, 2019- Jackson City Manager presents City’s Proposed plan for Lead Service Line Replacement at special meeting called by Jackson County Chamber of Commerce • September 2019- Jackson City Council votes to eliminate tier rate • September 11, 2019 - City Manager Patrick Burtch invited by Jackson County Chamber of Commerce to discuss what lead service line replacements will cost businesses. • September 19, 2019- City Administrative Staff meet in Lansing with MI Dept. of EGLE to discuss the City's Asset Management Plan to fund LSLR. EGLE indicates the City cannot delay implementation • October 11, 2019- City Administrative Staff are invited by Julie Alexander to meet at One Jackson Square with MI Dept. of EGLE. In attendance was Mike Shirkey, Michigan Dept. of Corrections, Henry Ford Allegiance Health, Consumers Energy, Blackman Twp., Jackson County Chamber of Commerce among others. • October 2019-Michigan Court of Claims rejects final complaint and dismisses lawsuit • January 27, 2020-Consumers Energy proposes contract to pay 52% of the residential rate in a 20 year contract • January 28, 2020- Jackson City Council postponed voting on the Consumers Energy contract until the February 11th meeting • January 29, 2020-Consumers Energy sues the City of Jackson to revert to an expired agreement giving them a 5th tier rated structure. The 5th tier would allow Consumers Energy to utilize more drinking water and pay only 38% of the residential rate per consumption estimates.
  6. 6. HOW DOES THE CITY OF JACKSON RELATE?
  7. 7. The total cost of the program is $232,288,000. This includes construction, engineering, service investigation, street resurfacing, water main replacement, smart meter upgrades, and office and equipment costs. Per line these costs are: Construction: $ 7,857 Engineering: $ 786 Investigation: $ 442 Street Resurfacing: $ 5,000 Water Main Replacement: $ 1,429 Smart Meter Upgrades: $ 429 Staff/Supplies/Equipment: $ 649 Total Program Costs: $ 16,592
  8. 8. $6,500 $4,500 $7,500 $10,000 $10,000 $14,000 $7,857 $6,000 $12,000 $8,706.33 $3,700 $3,200 $4,000 $8,000 $5,000 $4,000 $4,500 $5,000 $1,200 $4,288.89 $0 $2,000 $4,000 $6,000 $8,000 $10,000 $12,000 $14,000 $16,000 Lansing Board of Water and Light The City of Saginaw The City of Detroit The City of Birmingham The City of Newark, NJ SEMCOG The City of Jackson The City of Flint EPA Group Avg. PerUnitReplacementCost Community Estimated LSL Replacement Cost/Per Unit Replacement Only High Vs. Low LSL Replacement Costs High LSL Replacement Costs Low
  9. 9. HOW OTHER MICHIGAN COMMUNITIES COMPARE Saginaw MI: Estimates $60 Million full LSL Replacement in 25 years. Received $1 Million Grant from the State in 2018 Detroit MI: Estimates $500 Million CIP and LSL Replacement program over 5 years, bonded $16.5 Million for DWRF SEMCOG (Southeast Michigan Council of Governments): $2.5 Billion over 20 years Flint MI: Received $350 Million from State and $100 Million from Federal Government in grants for LSL Replacement and Associated Health costs. Flint has not finished full LSL Replacements SURVEY OF MICHIGAN COMMUNITIES ESTIMATED LSL REPLACEMENT COSTS
  10. 10. $7,150 $4,950 $8,250 $11,000 $11,000 $15,400 $8,643 $6,600 $13,200 $9,577 $4,070 $3,520 $4,400 $8,800 $5,500 $4,400 $4,950 $5,500 $1,320 $4,717.78 $0 $2,000 $4,000 $6,000 $8,000 $10,000 $12,000 $14,000 $16,000 $18,000 Lansing Board of Water and Light The City of Saginaw The City of Detroit The City of Birmingham The City of Newark, NJ SEMCOG The City of Jackson The City of Flint EPA Group Avg. PerUnitReplacementCost Community Estimated LSL Replacement Cost/Per Unit Replacement 10% Construction/Associated Fees High vs. Low LSL Replacement Costs High LSL Replacement Costs Low
  11. 11. WHAT WE LEARNED FROM LANSING BOARD OF WATER & LIGHT • OVER 90% OF LSL REPLACEMENTS FOR LANSING BWL CUSTOMERS WERE DONE IN CONJUNCTION WITH CITY OF LANSING INFRASTRUCTURE UPDATES. The City of Lansing and Lansing board of Water & Light are two separate entities. Lansing Board of Water & Light is a municipally owned utility locating in the City of Lansing. The cost of service replacements to Lansing BWL are confined to the utility and not a charge directly to the City of Lansing. • LANSING BOARD OF WATER AND LIGHT OWNS THE ENTIRE SERVICE LINE FROM THE MAIN TO THE METER. Lansing BWL worked to gain ownership of all of their service lines to reduce costs associated with legal fees for access on private property. Lansing BWL owned all of their service lines when they began their replacement program. • LANSING BWL BEGAN LSLR IN 2004, AND COMPLETED 1500 LINE REPLACEMENTS PER YEAR UNTIL THE RECESSION IN 2009. REPLACEMENTS DROPPED TO 300 A YEAR UNTIL THE 2014 FLINT WATER CRISIS. LANSING BWL COMPLETED FULL REPLACEMENTS IN 2016. Applying the rate of inflation for materials and construction costs, the cost to replace a service line would be 16% higher in 2020 than in 2016 when Lansing BWL completed their full LSL Replacement. • ESTIMATED COSTS FOR LSLR TO LANSING BWL WERE $3700/UNIT-IF LANSING BWL WERE TO PERFORM LSLR NOW OUTSIDE OF INFRASTRUCTURE UPDATES COSTS WOULD BE $6,500 A LINE. • RESTORATION OF PRIVATE/PUBLIC PROPERTY WAS DONE BY THE GOVERNMENT ENTITY (CITY OF LANSING) WHEN PERFORMED IN CONJUNCTION WITH INFRASTRUCTURE UPDATES.
  12. 12. 29.85% 25.48% 20.95% 9.81% 2.03% 1.41% 1.27% 1.11% 1.03% 1.00% 0.99% 0.98% City of Jackson Water Users by Consumption Industrial Users Consumers Energy Residential Users Michigan Dept Of Corrections Elm Plating Henry Ford Allegiance Health Eaton Aerospace Commonwealth Commerce Center Sun Communities Inc. Industrial Steel Treating Jackson Tumble Finish JSP International LLC Residential Users Consumers Energy Industrial Users MI Dept. of Corrections
  13. 13. COSTS TO RESIDENTS IF TOP USER RECEIVES 0% DISCOUNT After September 2019 City Council removed the tier rate structure for large water users. City Council determined it is inequitable to allow large water users a discount of a precious resource.
  14. 14. Qualifying Customer Assistance Program at or below 100% of Federal Poverty Level Qualifying families with income limitations at 100% or below the Federal poverty level would be eligible for this program. Customer Assistance Program City of Jackson is currently working to provide an Assistance Payment program for water customers. PA 113 of 1869 imposes limitations on municipalities in the formation of assistance programs. With help from local legislators and other lobbying firms, the City may be able to provide those with the fixed incomes financial relief for water bills. Qualifying Customer Assistance Program at or below 80% of Federal Poverty Level Qualifying families with income limitations at 80% or below the Federal poverty level would be eligible for this program

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