EPIC Calls on EPA to Improve Lead Service Line Funding Allocations
On February 11, 2025, the Environmental Policy Innovation Center (EPIC) submitted public comments in response to the EPA’s request for comments on the 8th Drinking Water Infrastructure Needs Survey and Assessment (DWINSA) process.
EPIC’s recommendations focused on improving the accuracy of lead service line replacement (LSLR) cost assessments and ensuring that federal funding is distributed in accordance with state needs more efficiently by:
Leveraging existing inventory data to increase accuracy and efficiency
Improving LSL cost assessments
Designing a fairer allotment formula
What is the DWINSA, and why does it matter?
EPA uses the Drinking Water Infrastructure Needs and Assessment (DWINSA) survey to assess state water infrastructure needs and allocate Drinking Water State Revolving Funds (DWSRF) accordingly. This survey is administered to a sample of water systems across the country every four years.
Starting with the 7th DWINSA, EPA included survey questions on service line material to allocate the $15 billion Congress directed towards lead service line (LSL) replacement.
These survey responses are critical to determine how much money states will receive for lead service line replacement since funds are allocated based on states’ estimated proportions of lead pipes. Given the survey’s limitations to accurately assess needs and account for missing data, we encourage EPA to make adjustments to this survey to ensure funding can reach the states with greatest needs as quickly as possible.
Smarter and more efficient funding allocations
Leveraging Existing Inventory Data to Increase Accuracy and Efficiency
EPIC supported EPA’s proposal to rely on service line inventory data collected under a recent regulation.
Since all water systems are required to submit and annually update LSL inventories, this data provides a more accurate and comprehensive basis for estimating the number of lead pipes nationwide. Using inventory data will also reduce duplicative data collection efforts and administrative burdens.
Improving LSL Cost Assessments
Average costs to replace lead service lines vary substantially depending on factors considered in such estimations, from $1,880-$7,600 on the low end, to estimates as high as $19,835-$37,000. To improve LSL replacement cost estimates, EPA should collect information on cost factors such as permitting, labor, and administrative expenses. Likewise, we recommended the EPA also include questions on service line length, as it is a key factor in replacement cost estimations that is currently missing from EPA’s survey. By incorporating these details, the country will have a clearer picture of actual LSL replacement costs, and EPA can distribute funds more effectively.
Designing a Fairer Allotment Formula
EPIC also urged EPA to update its LSL replacement funding allotment formula to ensure that states with the greatest needs can receive adequate financial support as quickly as possible. Two changes are especially important:
Weighing LSL estimates by inventory completeness to prevent states with largely incomplete inventory data (i.e., high proportions of unknown and unreported service lines) from receiving disproportionately high funding.
Using external data, such as age of housing stock, to refine LSL estimates where service line materials remain unknown or unreported. Given that lead plumbing was federally banned in 1986 and largely supplanted by copper piping by the mid-1950s, this data could help identify areas at highest risk of exposure to lead in drinking water.
Fund Smarter, Not Harder
EPIC’s recommendations aim to streamline EPA’s needs assessment process, reduce unnecessary data collection, and ensure that federal funds are allocated where they are needed most. By leveraging existing inventory data and refining cost estimates, EPA can improve the speed and efficiency of lead service line replacement across the country.
For more details, read our full comments on the EPIC website.