Comments Submitted by RWJF on Drinking Water Regulations for Lead and Copper

The following comments were submitted by leaders of the Robert Wood Johnson Foundation (RWJF)—Dr. Richard Besser, president and CEO, and Dr. Julie Morita, former executive vice president—on the U.S. Environmental Protection Agency (EPA)’s proposed National Primary Drinking Water Regulations for Lead and Copper: Improvements (LCRI), Docket ID No. EPA–HQ–OW–2022–0801, published in the Federal Register on December 6, 2023.

RWJF is committed to improving health and health equity in the United States. In partnership with others, we are working to develop a Culture of Health rooted in equity that provides every individual with a fair and just opportunity to thrive, no matter who they are, where they live, or how much money they have. This includes supporting the development of the physical, economic, and social conditions in communities that enable all residents to reach their best possible health and wellbeing.  

Health is more than an absence of disease. It is a state of physical, mental, and emotional wellbeing. It reflects what takes place in our communities, where we live and work, where our children learn and play, and where we gather to worship. That is why RWJF focuses on identifying, illuminating, and addressing the barriers to health caused by structural racism and other forms of discrimination, including sexism, ableism, xenophobia, and prejudice based on sexual orientation. 

We rely on evidence to advance health equity. We cultivate leaders who work individually and collectively across sectors to address health equity. We promote policies, practices, and systems change to dismantle the structural barriers to wellbeing created by racism. We work to amplify voices to shift national conversations and attitudes about health and health equity. 

Safe, affordable water is fundamental to good health. While most water systems in the U.S. deliver safe drinking water, in every state, there are communities that lack access to safe water they can afford. Often, these are places where people with lower income, Black, Hispanic, and Indigenous people, and other people of color live. A long legacy of discriminatory policies and structural racism, including the lack of historic investment in communities of color, has created these inequities. Yet this water crisis can be solved. By upgrading our aging infrastructure and making water more affordable, we can make sure everyone, everywhere can turn on the tap without a second thought. 

Our comments on the Lead and Copper: Improvements (LCRI) are grounded in the perspectives and expertise of our grantees, who include policy experts, advocates, and organizers with deep expertise in public health, lead poisoning prevention, and environmental and water justice. Our comments also are based on the findings of RWJF-funded research. This includes a comprehensive 2017 report (known as the “10 Policies Report”) by the Health Impact Project, a collaboration of the Pew Charitable Trusts and RWJF, on evidence-based policies to prevent and respond to childhood lead exposure, including lead in drinking water.ⁱ

We highlight here some of the relevant public health and clinical experience of the co-signatories of this comment letter: Dr. Richard Besser, RWJF’s president and CEO, and Dr. Julie Morita, RWJF’s executive vice president. Dr. Besser worked at the Centers for Disease Control and Prevention (CDC) for 13 years, including serving as the acting director of the agency in 2009. He practiced as a volunteer pediatrician at community clinics across the U.S. for more than 30 years. Dr. Morita is also a pediatrician and helped lead the Chicago Department of Public Health for nearly two decades, first as a medical director, then as chief medical officer, and ultimately as commissioner where she oversaw the public health needs of 2.7 million residents in the nation’s third largest city.  

RWJF’s Commitment to Water Equity and Reducing Lead Exposure 

Building on the water justice efforts sparked by the Flint, Michigan water crisis that began in 2014, RWJF has made more than $15 million in grants and investments in the past several years to advance water equity and reduce lead exposure. RWJF and our grantees have coordinated with EPA on the Lead Accelerator initiative, the more recent Get the Lead Out initiative, and the implementation of the $15 billion set aside of Bipartisan Infrastructure Law funding for lead service line (LSL) replacement. Some examples of these investments include funding to:

• The Environmental Policy Innovation Center to support multiple communities in implementing LSL replacement programs and to make recommendations for improving the Consumer Confidence Reports;
• The Natural Resources Defense Council to pursue stronger federal, state, and local lead policies as well as policies that advance water affordability;
•  New Jersey Future, which has helped to galvanize support for some of the most aggressive LSL replacement programs in the country;
•  The Little Village Environmental Justice Organization to advocate for more effective LSL program implementation for historically marginalized communities, including entire neighborhoods in Chicago that have been disproportionately burdened by lead; 
• The National Center for Healthy Housing to build local capacity to reduce childhood lead exposure in homes and to advance evidence-based lead poisoning prevention efforts through policy and systems change.
  

Recognizing that water is one of many sources of lead exposure, RWJF also has supported the National Center for Healthy Housing to support a cohort of cities around the country in advancing policies to prevent exposure from lead-based paint hazards. As a member of the Lead Action Funders Network—a collaborative of philanthropic organizations committed to reducing childhood lead exposure—we have developed several tools and resources for financing lead remediation. We have also funded Altarum Institute to create the Value of Lead Prevention website, which enables state and community leaders and the public to easily calculate the cost of lead exposure in their state and the economic benefits of key interventions to reduce lead exposure. 

Comments on the LCRI 

As outlined here, RWJF’s comment on the LCRI presents research that underscores the importance of LSL replacement and key provisions of the LCRI; documents the unequal burden of lead on people with lower incomes, Black, Hispanic, and Indigenous people, and other people of color; and makes recommendations to strengthen the LCRI.  

I.    The LCRI would have a profoundly positive impact on public health and economic wellbeing. 

II.   Communities where Black, Hispanic, and Indigenous people and other people of color live are disproportionately impacted by LSL

III.  EPA should strengthen the 2023 Proposed Rule to maximize protections for people and places at greatest risk for lead exposure. 

I.    The LCRI would have a profoundly positive impact on public health and economic wellbeing. 

RWJF strongly supports the Administration’s commitment to replacing all LSLs. If finalized, the LCRI would help to realize that goal. The public health impact of the implementation of the LCRI would be enormous: more children thriving at home and at school, stronger and more equitable communities, and longer, healthier, and more productive lives.  

Thousands of studies have concluded that lead has wide-ranging effects on the health of young children and significant costs to taxpayers. Even at very low levels, lead exposure affects the brain’s ability to control impulses and process information. Children with lead poisoning are more likely to struggle in school, drop out, have encounters with the justice system, underperform in the workplace, and earn less throughout their lives, independent of other social and economic factors. The cost of these outcomes includes billions of dollars in public spending on special education, juvenile justice, and other social services.ⁱⁱ

EPA’s 2024 Integrated Science Assessment for Lead found clear and consistent evidence of negative health effects of lead exposure among children and adults. Lead exposure is associated with decreased attention, increased impulsivity, and increased hyperactivity in children—effects that recent studies observed at blood lead levels less than or equal to 5 ug/dL. There is no evidence of a threshold for the observed neurodevelopmental effects. Scientists have found negative effects of lead on cognitive function in populations of children (ages 4–10) at blood lead levels in the range of 2–8 μg/dL. Studies show that cognitive effects and neurodevelopmental effects may persist into adulthood. Lead exposure in adulthood can negatively affect cognitive function and harm an array of organ systems, including the cardiovascular and renal systems.ⁱⁱⁱ

Although indoor plumbing fixtures and lead solder can contribute to elevated lead levels in drinking water, research indicates that LSLs account for the largest share of lead in drinking water.^iv Studies show that U.S. residences with LSLs are at risk of lead exposure if corrosion control techniques are not effective at preventing lead from leaching from pipes and leaded fixtures into drinking water. A robust body of academic literature from the U.S. and Canada links lead in drinking water to increases in blood lead levels.^v For example, one cross-sectional study of 183 children randomly selected from urban areas found that an increase in water lead concentrations from background levels to 15 ppb was associated with a nearly 14 percent jump in the share of children with estimated blood lead over 10 µg/dL^.vi

The LCRI will meaningfully contribute to the reduction of lead exposure in the U.S. Key provisions of the LCRI that RWJF supports include the following: 

1. Universally mandating the replacement of LSLs over 10 years; 
2. Steady removal of lead connectors and galvanized steel lines, which present a public health risk;^vii
3. Reduction of the lead action level, though we believe that the action level should be further lowered from 10 ppb to 5 ppb as discussed in section III below; 
4. Improvements to the tap sampling protocols; 
5. Increased transparency between water systems and consumers about lead in tap water; 
6. Continuing to discourage partial LSL replacements, though as discussed in section III below, we believe EPA can do more in this rule to ensure the full line is replaced;  
7. The inclusion in the rule’s cost-benefit analysis of recent evidence regarding the effects of lead on cardiovascular disease in adults.

II.   Communities where Black, Hispanic, and Indigenous people and other people of color live are disproportionately impacted by lead and LSLs. 

Due to systemic factors discussed further below, race and ethnicity are strongly associated with children’s risk of exposure to lead. 

• A national survey found that Black children’s average blood lead levels were well above those of non-Hispanic White and Mexican-American children.^viii Although the survey did not control for social and economic factors, other studies have shown that race and ethnicity are associated with elevated blood lead levels in children regardless of family income.  
• One study of more than 1 million blood tests from Chicago collected between 1995 and 2013 found that, after controlling for socioeconomic factors, children from predominantly Black, and to a lesser extent Hispanic, neighborhoods had higher rates of lead poisoning than their White counterparts, even as blood lead levels fell dramatically citywide.^ix
• The Chicago-area Metropolitan Planning Council found that the composition of the communities in Illinois with 94 percent of the state’s LSLs was 65 percent Black and Latinx residents, 42 percent Asian-American and Native American populations, and 30 percent White.^x

These disparate impacts by race and ethnicity are a direct consequence of racist policies and practices in the water and housing sectors throughout our nation’s history.  

• During the Jim Crow era, Black and Hispanic people and other people of color were disproportionately burdened by degraded water quality and infrastructure disinvestments through practices such as redlining, exclusionary zoning, and discriminatory lending practices. These practices enabled municipal decisions to restrict services and waterworks access for majority-Black communities and neighborhoods. During this period, federal waterworks funding and services continued to decrease for communities with majority-Black populations and Indigenous people, which were already historically excluded from, or severely limited in accessing, federal investments.^xi
• After World War II, communities of color were excluded from water and sewer services through “under-bounding,” which was a practice of annexing White neighborhoods within a town’s boundaries, and then denying or limiting water and sewer services for adjacent or nearby communities of color.^xii One study showed that Black and poor White neighborhoods received town water and sewer services a half century or more after affluent White communities.^xiii In subsequent decades, some White suburbs created their own private water utilities instead of using existing municipal ones, which reduced the revenue and market share of older, public, urban systems serving communities of color.  
• EPA has noted that so-called “disadvantaged communities”^[1] have never received their fair share of federal investment. Contemporary studies show that smaller municipalities and those with larger populations of color are statistically less likely to receive federal water assistance.^xiv

III.  EPA should strengthen the LCRI to maximize protections for people and places at greatest risk of lead exposure. 

RWJF recommends that EPA strengthen the LCRI in the following ways to better protect children and families from lead exposure and to more effectively advance racial and health equity. 

1. Require systems to pay for full LSL replacement.  

The replacement of LSLs is a matter of public health. Evidence shows that requiring homeowners to pay for the portion of the line on their property is both inequitable and a public health risk.^xv Therefore, EPA should clarify that water systems are expected to replace the full LSL. This will likely save water utilities time negotiating with property owners, which will expedite replacements. Finally, EPA should require that utilities replace LSLs first in neighborhoods with the greatest risk of lead exposure.  

2. Close the “control” loophole.  

EPA should not allow water systems to avoid complying with the rule by claiming that they do not have control of a property. Clarity on this point would serve as an incentive to water systems to proactively uncover and address state and local legal barriers to full LSL replacement. Additionally, EPA could condition Safe Drinking State Revolving Fund and other drinking water funding on changes to state and local laws and administrative policies to clarify that water systems may replace the part of the LSL on private property.  

3. Make October 2024 the effective date of all aspects of the LCRI.  

EPA proposes that implementation of the LCRI would begin three years after the rule is finalized “unless the Administrator determines that an earlier date is practicable.” Given that EPA’s review of the current lead and copper rule found that leaving millions of LSLs in place would result in “generations of Americans being at risk of significant lead exposure through their drinking water,” RWJF strongly recommends that EPA make October 2024 the effective date for compliance with all aspects of the final rule.  

Starting implementation three years after the rule is finalized puts far too many children and families at risk of exposure whereas swift implementation would bring meaningful benefits to communities impacted by LSLs. The RWJF-funded 10 Policies report found that removing leaded drinking water service lines from the homes of children born in 2018 (one birth cohort and not including the adults in these homes) would protect more than 350,000 children and yield $2.7 billion in future benefits for families, federal, state, and local governments, and the private sector.^xvi

It is not only in the interest of public health but also feasible for water systems to begin implementing the LCRI in October 2024. EPA made water systems aware in December 2021 of the agency’s intention to require replacement of all LSLs. As EPA notes in the LCRI, several states have already mandated full LSL and many cities have completed this work.  

Further, moving directly to the implementation of the LCRI will avoid the confusion of temporarily implementing some or all the provisions of the 2021 Lead and Copper Rule Revisions (LCRR), which are set to take effect in October 2024. The LCRI should replace the LCRR as the LCRI is a strengthened version of the LCRR and based on the latest evidence. EPA could include a year or two of “compliance assistance” whereby enforcement is phased in. HUD’s Office of Lead Hazard Control and Healthy Homes implemented such an approach when it finalized its sweeping lead safe housing rule.   

4. Eliminate the exceptions to the 10-year replacement timeline.  

RWJF recommends that the final rule does not permit exceptions to the ten-year LSL replacement deadline for communities with a high proportion of LSL relative to their total number of households served or a high total number of LSLs. Rather than offering deferred compliance deadlines to water systems in these communities, EPA should target grant funding and compliance assistance to enable water systems in these communities to complete LSL replacements within ten years. EPA could also incentivize smaller water systems to pursue community-led consolidation and regional partnerships to ease compliance with the rule’s requirements.  

5. Use more inclusive definitions and language that include people who rent their homes.  

Most of the informational requirements in the LCRI apply to “customers,” which is generally interpreted by EPA and water systems to mean those who receive the water bills. Wherever the LCRI refers to customers, it should also include those who reside in the household, regardless of whether they pay the water bill. Anyone residing in a home should receive information about lead test results and system-wide lead monitoring information. Additionally, when a water system contacts customers for access to a property for LSL replacement, household members should also be contacted since a renter may encourage the owner to participate. Newark, New Jersey allows adult occupants of a residence, including renters, to agree and provide access to LSLs  in order to replace them. This is particularly important for overcoming the barrier of gaining access to buildings owned by absentee landlords. 

6. Strengthen the proposed requirements for schools and childcare centers.  

RWJF recommends that community water systems provide water filters to childcare facilities and filtration systems to schools while testing protocols are carried out. RWJF is aware of many communities that are moving to a “filter first” approach. EPA should consider whether this would be a more cost effective and public health protective approach than testing programs. EPA should also require community water systems to make public the results of the tests performed in schools.

7. Further lower the action level for education, filter provision, and source water monitoring from 10 ppb to 5 ppb. 

Evidence suggests that every increment of lead exposure matters and earlier action is warranted. For example, in the 10 Policies Report, researchers noted that EPA’s Integrated Exposure Uptake and Biokinetic model estimates a 0.042 µg/dL change in blood lead per 1 ppb increase in water lead. A Canadian study looked at cumulative lead exposure and found that for children between the ages of 1 to 5, an increase of 1 μg/L in water lead would result in an increase of 35 percent of blood lead after 150 days of exposure.^xvii

There is evidence that utilities can achieve a level of 5 ppb through optimized corrosion control, including EPA data cited in the LCRI, which shows that the vast majority of systems serving more than 10,000 people would meet a 5 parts per billion standard today.^xviii Furthermore, technology improvements, regional partnerships and consolidation, training, and the LCRI will help reduce levels over the next decade, making this lower action level technically feasible. Finally, as EPA points out in the LCRI, this level has previously been used as a trigger; the current lead and copper rule already requires optimized CCT when 90th percentile lead levels exceed 5 ppb. Thus, water systems already are acting at 5 ppb.  

In addition to lowering the action level, EPA should strengthen its oversight and enforcement efforts, including by requiring direct electronic reporting of monitoring results and action level exceedances to EPA. More rigorous enforcement should also include mandating and enforcing state reporting of violations, which audits have found that states vastly underreport to EPA.

8. Strengthen the filter requirements.  

RWJF recommends that EPA require water systems to distribute filters for any exceedance of the action level instead of the LCRI requirement action after 3 exceedances in five years. Under EPA’s proposal, the requirement to distribute filters would not begin until the end of the first five-year cycle, which is insufficient to protect public health and could disproportionately burden disadvantaged communities that are more likely to experience exceedances. In addition to requiring water systems to annually notify households that they have an LSL, galvanized service line requiring replacement, or unknown service line, EPA should require water systems to provide filters and instructions for their use to households that have an LSL, galvanized service line requiring replacement, lead connector material, or unknown service line. This will help protect public health during the many years it will take to replace these materials. 

9. Monitor the equitable implementation of the rule.  

EPA should collect and report data on the implementation of the rule, including an equity analysis that shows the number and percent of replacements in water systems by race, ethnicity, income, and rental versus homeownership status. Additionally, EPA should develop a national LSL inventory where all cities and states report their respective inventory and progress as well as include the LSL inventory in the EPA EJScreen and the Climate Economic Justice Screening Tools.  

10. Require lead pipe replacements to be done using copper, or polypropylene when copper is not feasible, as new pipe materials.  

Plastic pipes can potentially contaminate drinking water by leaching—when pollutants seep from groundwater or soils through the walls of plastic pipes^xix—and can release toxic chemicals into drinking water when exposed to wildfire temperatures.^xx

Going Further: Addressing the Financing Needs of Disadvantaged Communities

RWJF recommends that EPA create an ongoing source of long-term, non-competitive grants to facilitate implementation of the LCRI so that the lowest income customers do not have to choose between affordable drinking water and quality drinking water. This recommendation is a critical aspect of equitable implementation that RWJF believes is important for EPA to proactively address.

As with most aspects of water infrastructure, it is disadvantaged communities within larger cities and smaller communities that will be most significantly impacted by the changes outlined in the LCRI. While larger cities can finance compliance with the LCRI through rate structures that are predominantly paid by higher-income households, disadvantaged communities do not have the economic base to implement similar programs.

To support utilities serving disadvantaged communities in covering the cost of full LSL replacement, EPA could require states to account for the extent and cost of LSL replacement separately, broken down by population categories, which EPA has done for wastewater needs assessments. This would enable EPA and states to target funding for replacement costs to the smallest and poorest communities. Such funding could be made available through the Safe Drinking Water Act’s programs for Small and Disadvantaged Communities or Lead Reduction Project Program for disadvantaged communities^xxi, a new funding mechanism, or by allowing states to use repayments to their Drinking Water State Revolving Funds (SRF) or their principal forgiveness funds.

Recognizing that it may take time to set up a new funding mechanism for disadvantaged communities, RWJF recommends that EPA take immediate steps to modernize its SRF program—the principal source of funding for LSL replacement—so that it advances the Administration’s Justice 40 objectives. Many of RWJF’s grantee partners have experienced barriers in accessing SRF funding. While an exhaustive discussion of SRF reform is beyond the scope of this comment letter, RWJF makes the following high-level recommendations to help achieve equitable implementation of the LCRI:

• EPA should continue to promote state adoption of the definition of “disadvantaged community” developed by EPA and that advances Justice 40 objectives;
• Prioritize loan forgiveness for disadvantaged communities;
• Reduce the complexity of the application process;
• Make the Intended Use Plans process more transparent, accessible, and inclusive;
• Ensure that all project predevelopment expenses are recoverable through SRF; and
• Ensure that environmental finance centers have the necessary financing experience to guide communities through the development of a full financing package given that many communities will likely need to activate several sources of public and private funding.

We encourage EPA to work with disadvantaged communities to elevate and address these and other challenges to access SRF.

Conclusion 

Where you live should not determine whether you have safe water to drink. We appreciate the opportunity to submit comments on the LCRI and urge EPA to move forward with a strong rule that maximizes the protections for the populations and places that are at greatest risk of exposure. The proposed rule goes a long way toward strengthening drinking water protections for children and families and promoting more equitable outcomes for those who have long been unjustly burdened by lead. With more aggressive implementation timelines, elimination of loopholes and exceptions, and the other improvements noted above, the Administration can achieve its goal of replacing all LSLs in 10 years.  

1. The Foundation’s preference is to use the term “marginalized” when referring to some neighborhoods, schools, institutions, and communities that have experienced historical and ongoing exclusion from equitable distribution of resources. However, the term “disadvantaged community” is used in this comment letter because that is the term used by EPA in the LCRI.   

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i Health Impact Project, a collaboration of the Robert Wood Johnson Foundation and The Pew Charitable Trusts, "Ten Policies to Prevent and Respond to Childhood Lead Exposure: An Assessment of the Risks Communities Face and Key Federal, State, and Local Solutions," accessed August 30, 2017, http://www.pewtrusts.org/en/research-and-analysis/reports/2017/08/10-policies-to-prevent-and-respond-to-childhood-lead-exposure, published August 30, 2017. 

ii Ibid. 

iii U.S. Environmental Protection Agency, “Integrated Science Assessment (ISA) for Lead (Final Report)” (2024), https://assessments.epa.gov/isa/document/&deid=359536.    

iv Sandvig, Anne et al., “Contribution of Service Line and Plumbing Fixtures to Lead and Copper Rule Compliance Issues” (Denver: AWWA and EPA, 2008), https://archive.epa.gov/region03/dclead/web/pdf/91229.pdf. 

v Triantafyllidou, Simoni, and Marc Edwards, “Lead (Pb) in Tap Water and in Blood: Implications for Lead Exposure in the United States,” Critical Reviews in Environmental Science and Technology 42, no. 13 (2012): 1297–1352, http://dx.doi.org/10.1080/10643389.2011.556556; Brown, Mary J, and Stephen Margolis, “Lead in Drinking Water and Human Blood Lead Levels in the United States,” Morbidity and Mortality Weekly Report 61 (2012), https://www.cdc.gov/mmwr/pdf/other/su6104.pdf; Edwards, Marc, Simoni Triantafyllidou, and Dana Best, “Elevated Blood Lead in Young Children Due to Lead-Contaminated Drinking Water,” Environmental Science and Technology 43, no. 5 (2009), http://dx.doi.org/10.1021/es802789w; Ngueta, Gerard et al., “Use of a Cumulative Exposure Index to Estimate the Impact of Tap Water Lead Concentration on Blood Lead Levels in 1- to 5-Year-Old Children (Montreal, Canada),” Environmental Health Perspectives 124 (2016): 388–95, http://dx.doi.org/10.1289/ehp.1409144. 

vi Lanphear, Bruce P et al., “Environmental Exposures to Lead and Urban Children’s Blood Lead Levels,” Environmental Research 76, no. 2 (1998): 120–30, https://doi.org/10.1006/enrs.1997.3801. 

vii Deshommes, Elise, Shokoufeh Nour, and Michèle Prévost, “Bioaccessibility of Pb particles from tap water: Results from field and laboratory,” Water Quality Technology Conference and Exposition 2010 (2010): 3087-3113. 

viii Wheeler, William, and Mary J Brown, “Blood Lead Levels in Children Aged 1-5 Years—United States, 1999— 2010,” Morbidity and Mortality Weekly Report 62, no. 13 (2013): 245–48, https://www.cdc.gov/mmwr/preview/mmwrhtml/mm6213a3.htm. 

ix Sampson, Robert J, and Alix S Winter, “The Racial Ecology of Lead Poisoning: Toxic Inequality in Chicago Neighborhoods, 1995-2013,” Du Bois Review: Social Science Research on Race 13, no. 2 (2016): 261–83, http://dx.doi.org/10.1017/S1742058X16000151; Lanphear, Bruce, Michael Weitzman, and Shirley Eberly, “Racial Differences in Urban Children's Environmental Exposures to Lead,” American Journal of Public Health 86 (1996): 1460-1463. 

x Williams, Justin and Tara Jagadeesh. ”Data Points: The environmental injustice of lead lines in Illinois.” Data Points (blog). Metropolitan Planning Council, November 10, 2020. https://www.metroplanning.org/news/9960/Data-Points-the-environmental-injustice-of-lead-lines-in-Illinois. 

xi DigDeep, “Closing the Water Access Gap in the United States” (2019), accessed January 25, 2024, https://static1.squarespace.com/static/5e80f1a64ed7dc3408525fb9/t/6092ddcc499e1b6a6a07ba3a/1620237782228/Dig-Deep_Closing-the-Water-Access-Gap-in-the-United-States_DIGITAL_compressed.pdf. 

xii Parnall, Allan M, "The Persistence of Political Segregation" (2004); Leker, Hannah G, and Jacqueline M Gibson, "Relationship Between Race and Community Water and Sewer Services in North Carolina" (2018). 

xiii Troesken, Werner, Limits of Jim Crow (2002). . 

xiv Environmental Policy Innovation Center and the Natural Resources Defense Council, “A Fairer Funding Stream: How Reforming The Clean Water State Revolving Fund Can Equitably Improve Water Infrastructure Across The Country” (2022), accessed January 23, 2024, https://www.nrdc.org/sites/default/files/clean-water-state-revolving-fund-infrastructure-report.pdf.  

xv Baehler, Karen J et al., “Full Lead Service Line Replacement: A Case Study of Equity in Environmental Remediation,” Sustainability 14, no. 1 (2022): 352, https://doi.org/10.3390/su14010352. 

xvi Health Impact Project, a collaboration of the Robert Wood Johnson Foundation and The Pew Charitable Trusts, "Ten policies to prevent and respond to childhood lead exposure," accessed August 30, 2017, http://www.pewtrusts.org/en/research-and-analysis/reports/2017/08/10-policies-to-prevent-and-respond-to-childhood-lead-exposure, published August 30, 2017. 

xvii Ngueta, Gerard et al., “Use of a cumulative exposure index to estimate the impact of tap water lead concentration on blood lead levels in 1- to 5-year-old children (Montreal, Canada),” Environmental Health Perspectives 124 (2016): 388–395, https://doi.org/10.1289/ehp.1409144. 

xviii National Primary Drinking Water Regulations for Lead and Copper: Improvements (LCRI). U.S. Environmental Protection Agency. Volume 88. 88 FR 84878. Page 84941, Exhibit 5. December 6, 2023; Prévost. Michèle, and Élise Deshommes, “Calculation of Reference Water Levels for Lead Service Line Replacement”; Triantafyllidou, Simoni et al., "Low Contribution of Pb02-Coated Lead Service Lines to Water Lead Contamination at the Tap" in “10 policies to prevent and respond to childhood lead exposure,” Pew Charitable Trusts (2017), available at: https://www.pewtrusts.org/-/media/assets/2017/08/hip_childhood_lead_poisoning_report.pdf. 

xix Liu, Ze-Hua, Hua Yin, and Zhi Dang, "Do estrogenic compounds in drinking water migrating from plastic pipe distribution system pose adverse effects to human? An analysis of scientific literature," Environmental Science and Pollution Research. 24 (2017): 2126–2134, https://doi.org/10.1007/s11356-016-8032-z. 

xx Water Research Foundation, Impact of Hydrocarbons on PE/PVC Pipes and Pipe Gaskets, October 17, 2007, https://www.waterrf.org/research/projects/impact-hydrocarbons-pepvc-pipes-and-pipe-gaskets; U.S. Environmental Protection Agency, "Addressing Contamination of Drinking Water Distribution Systems from Volatile Organic Compounds After Wildfires," accessed September 2021, https://www.epa.gov/system/files/documents/2021-09/addressing-contamination-of-drinking-water-distribution-systems-from-volatile-organic-compounds-after-wildfires_508.pdf. 

xxi Safe Drinking Water Act. Pub. L. No. 93-523, § 1459A & 1459B, 88 Stat. 1660. 

About the Robert Wood Johnson Foundation

The Robert Wood Johnson Foundation (RWJF) is committed to improving health and health equity in the United States. In partnership with others, we are working to develop a Culture of Health rooted in equity that provides every individual with a fair and just opportunity to thrive, no matter who they are, where they live, or how much money they have.