SEMCOG Supports Comprehensive Approach to Lead and Copper

Over the past few years, the impact of lead and copper on drinking water has drawn significant attention. SEMCOG, its member governments, and the Southeast Michigan Partners for Clean Water support an approach to infrastructure that promotes and prioritizes protection of public health. Reduction of lead exposure is, rightly, a priority for the State of Michigan, but it is important to address known sources in a comprehensive and strategic manner.

SEMCOG has joined a coalition of agencies to collaboratively address proposed changes to the state’s lead and copper rules from the Michigan Department of Environmental Quality. The coalition includes Great Lakes Water Authority (GLWA), Detroit Water and Sewerage Department (DWSD), Oakland County, Michigan Section of American Water Works Association, Michigan Municipal League, and Michigan Townships Association.

This coalition drafted messages that were presented at the Public Comment Hearing on March 1, 2018. In addition to messages, the coalition drafted comments that outline a comprehensive, solutions-based approach in response to the proposed rule that were provided to respective membership groups and were submitted to the MDEQ prior to the public comment deadline of March 21.

These messages included the following points:

1. Lead exposure is a public health priority for state and local governments, including environmental and public health departments in addition to water service providers.
2. The primary role of all water service providers is to protect public health.
3. Eliminating lead exposure needs a comprehensive and collaborative approach across all these departments
4. Removing lead service lines must be a shared responsibility between water systems and property owners.
5. All lead service line removals should be completed as part of a community’s asset management program and driven by three elements: exceedance of the action level after installation of corrosion control technology; schedules in coordination with asset management programs; and mitigation of elevated levels at known sources.
6. Lead paint and dust are still primary sources of lead exposure. Data from Southeast Michigan health department investigations has not shown drinking water as the source. The estimated costs to eliminate the 500,000 estimated lead service lines across the state at a conservative cost of $3,500 each is at least $1.75 billion. This does not address household plumbing.

As stated in the key messages provided by the coalition, costs, other difficulties, and a lack of scientific proof that drinking water is a significant source of lead exposure in Southeast Michigan, wholesale replacement of infrastructure to comply with the proposed rules would cost millions of dollars with unknown benefits.

In addition to the statewide lead and copper rule updates, SEMCOG provided comments to the Environmental Protection Agency (EPA) in the form of a letter that promoted coordinated actions across federal, state, and local agencies; encouraged a shared responsibility for lead exposure reduction; and endorsed a holistic asset management approach to removing lead from water systems.