This document discusses the challenges of aging drinking water infrastructure in the United States, focusing on lead pipes as a particular issue. It estimates that $384 billion is needed to upgrade water systems by 2030. Lead pipes are a major problem, with over 3 million lines estimated in 1990. The EPA's Lead and Copper Rule requires testing for and addressing high lead levels, but its sampling methods may underestimate risks. Cities like Milwaukee face enormous costs to replace pipes but removing lines can increase lead levels without addressing private lines. The document examines Milwaukee as a case study and recommends updating policies and practices to better assess risks and replace all infrastructure to avoid health hazards.

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cies regarding lead pipe detection and rehabilitation are outdated and need reconsidering in order to tack-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

2. 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).

3. 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

4. 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.