The Case for a Lead Service Line Replacement Playbook – And Some Key Plays

By: Cathy B. Bailey, Executive Director, Greater Cincinnati Water Works

When it comes to Lead and Lead Service Line (LSL) Removal, some of the “larger” utilities in the United States, including Greater Cincinnati Water Works (GCWW), have a plethora of readily available resources—from grant application writing and social media content development, to graphic design, messaging, and marketing campaigns.

These resources have enabled us (and other large cities) to be quite successful in developing and implementing our Lead Service Line Removal programs. However, in speaking with my colleagues across the country, I have found that small and medium size utilities do not necessarily have these resources at their disposal.

Large utilities have the benefit of well-developed strategic plans, innovative technological solutions, and ample resources to complete daily tasks, long-term capital projects and game-changing programs. This was certainly the case with Greater Cincinnati Water Works when we gathered at the table in 2016 and created the Enhanced Lead Program to proactively remove lead service lines in Cincinnati OH. Twenty-five employees--executives, engineers, scientists, accountants, lawyers, IT professionals, call center staff, administrative support teams, safety leads, around a table weekly for over a year creating an award-winning program that later became a model within the industry for lead line replacement. It was not easy, especially since there was not a roadmap or a well-defined program that we could adapt for our community. While it was not what our lawyers wanted to hear, we were out on a limb and ‘making this thing up.’ That is not the norm for well-established, anchor institutions like water utilities. We perceived this daunting task necessary and overwhelming at times, but in hindsight, it was a privilege to have the time and resources to make this happen. Knowledgeable staff to do this work while others fulfilled day-to-day operations and even picked up the slack where needed; limited gaps in planned projects and new initiatives, and a good understanding of finances to decide and reprioritize work to implement this program were in fact, an easy road for us and likely other large water utilities. At the end of the day, we have the means to get this work done (outside of finances of course!).

But what about small and medium size water utilities? Those utilities that already have long lists of repairs and changes that they need at their treatment plant and lead line replacement really isn’t on their radar. If they had to prioritize their work, lead line replacement is not on the list. Then there are those that have limited staffing, so if they did know how to create a replacement program, they likely will not have the funding to hire additional employees to do this work. From their view, existing challenges that might include old pumping systems, outdated treatment practices, paper records, obsolete equipment and fleet, aging workforce, the inability to raise rates, governance shifts, and even violations are and have been their priorities before the directives to remove lead service lines.

While we continue to learn from existing resources such as the Lead Service Line Replacement (LSLR) Collaborative and regular meetings and presentations at conferences, a solid ‘playbook’ would be helpful. What comes to mind is a document like the compendium of Drinking Water and Wastewater Utility Customer Assistance Programs created by USEPA. This report documented how drinking water and wastewater utilities were implementing customer assistance programs. I found this document helpful, particularly the care and attention to highlight programs by providing case studies and giving brief description of the programs. GCWW has contacted utilities often just from gaining knowledge from programs listed in the report.

In a similar fashion, a new lead service line replacement program ‘play book’ could provide ample examples and case studies on various aspects of a replacement program by utilities that are currently doing the work. Many topics could be included, several come to mind and are listed below.

• Trust is a Must. We have learned you can only move at the speed of trust with this challenging work in the community. Evaluate your levels of trust within segments of your community and determine new ways to regain trust to move the program forward in all neighborhoods. We have fifty-two (52) neighborhoods in Cincinnati so learning the characteristics of each is a tall task, but worth it. Understanding each neighborhood is how we can then show up for success with the right tools to engage our neighbors to agree to the program.
• Take time to counsel the council. Don’t assume your board or council members are familiar with and engaged in your work. Do they know the basics of regulations and ordinances that prior boards passed? Are they familiar with your planned replacement program? Regular updates, one-page summaries, committee presentations are helpful to governing bodies and their staff members so they can advocate for your program and carry messaging in the community.
• Aim to frame a solid ground game. Establishing a regular practice of community outreach and education is key. It is imperative to meet customers where they are. Comfortable meeting at a library? No problem. A church? No problem. A brewery? Yes, please. Whatever works, allowing customers to be comfortable to listen and learn will help them get to yes on the replacement. The ‘ground game’ is essential to success.
• Uncover the vines to define the lines. Put in the work to know the service lines in your area. What do your ‘vines’ of information look like? It could be a combination of paper records, spreadsheets, GIS records, verbal updates from customers that all contribute to show a vivid picture of your replacement landscape. So many records and processes intertwined that will need someone to take ownership to figure it all out. Uncover everything to get the best picture to help you define the work ahead. Share the results, post the map so customers can help fill in the gaps on prior replacements.
• The dream team constantly needs new steam. It sure would be nice to have a dedicated team to ride the replacement efforts out until the end. I am hoping someone is out there enjoying that experience. We are not. This is repetitive work that often involves administrative job titles to complete the task. This can then show up as a lot of movement amongst employees, people on and off the team, promotions, and transfers. Such is the case as we are on our fourth program manager in 7 years. But this is not a bad thing, as each team lead has ushered in innovative ideas, helped develop team members, embraced technology and contractor relationships in different ways, and brought new perspectives and vision to the program. While it seems unfortunate to have these changes, it all continues to work out.
• Got plumbers? Where? There? Where? It is hard to find plumbers that know how to do this work and keep them engaged in the program. Some stay, but others come and go through the years of the program. If you are trying to use the local workforce to complete this work, strong strategies with trusted partners in the community to attract, train, and retain plumbers and contractors are key.
• It is fact, you need a contract. This is true for our city; I envy those cities that do not have this requirement. Yes, we need a contract to gain access to the property to replace the service line. With over 1200 replacements per year right now, that is a lot of paper, electronic signatures, DocuSign packets moving all over the city. We aim to triple this in three years. This step alone is enough to lose sleep over. Strong, consistent procedures are needed.
• Say less to impress. This always seems to be a lesson learned the hard way. Countless efforts of updating and sending glossy photo documents, tri-fold brochures, lengthy personalized letters, links to long web pages, emails that never stop, when the best attention grabber might just be a black and white postcard sent to the home that is easy to pick out of all the other never-ending mail to the home. When it comes to figuring out your educational materials, less will impress and get the attention of customers.
• A cool prioritization tool will rule. Let’s face it, DEI is still a big unknown in the water utility industry. What it is, how it will show up, what it means are still challenging conversations in trying to get people to understand this element of our work. But what about a prioritization tool that takes into consideration several daily living factors and helps you better justify and explain prioritization of replacement projects? Income, poverty rates, housing age, race, elevated blood lead levels, health insurance coverage, healthy food access, childcare facilities, lead line presence and more all in a tool to provide data to prioritize neighborhoods for replacements. Granular data that more people can relate to versus grouped in a DEI category (and labeled “DEI”) has proven more helpful and acceptable within our community.
• Have your people call my people so we can do this. This program is the perfect time to collaborate with trusted partners and lean on relationships with organizations in the community. Who are your partners? What long-standing relationships do you have and how can they help make the community lead-safe? Have your people call my people so we can gather at the table to develop action items that we all can achieve to reach success.
• Ordinances, policies, regulations, OH MY! It is more than a notion to try to figure out all the ordinances, policies, and practices, changing regulations associated with lead service line replacements. However, many utilities have been at this for several years. In Cincinnati, we have eight years under our belt as we revamped our program starting in 2016. This gives us some strong lessons learned, the good, bad, and ugly as I often call it. Which means we can share our documents, policies, and procedures, so others do not have to travel the long way around. Talking with other utilities and learning their positive impacts and moments of success are key to constantly refreshing your program to increase replacement rates.
• Social Media. Don’t ignore it and be mad; use it and be glad. Some thought social media was just a fad years ago. So far from the truth. An inexpensive way to tell the utility story is via social media. Since ‘storytelling’ is not a familiar task with most utilities, why not start through an outlet that is easy to learn, used by many of your customers, and allows you to share regular messaging to educate your customer base.
• Motivating landlords will be worth the reward. Not all customers are motivated to remove their lines. Some groups will take more time, effort, and persuasion to replace their lines. More education, outreach and partnerships with other city departments will help overcome the challenge.
• Data is your friend. We love data. Collecting data. Storing data. Saying that we have data. But are we using the data? The data certainly can guide you to better prioritization practices, communicating with customers, strategizing to obtain a higher replacement record in low-income, disadvantaged communities. You must commit to and use the data regularly.
• School is In. Testing helps Win. It can appear overwhelming at the beginning, but proactive testing and partnerships with schools are game changing moves in a community. Schools are not aware of testing practices and in many cases have limited resources to tackle testing, however, they want it and want to make sure it is done correctly. Leading the way with this initiative just makes sense for local water utilities.
• The chant is simple, more grants, more grants, more grants. But the work is hard trying to find them. We all need more grants; some cities have been more successful than others in securing grants. Understanding the successful path to grants will be helpful to all.
• Funding for the program. Well, yes, we all need more funding. Period. That is it. More money. More funding. More loot. More dollar bills. However you want to call the financing, we need it.

These quick comments are my opinions and observations and from the early and ongoing learnings at Greater Cincinnati Water Works. While I have taken a playful tone of providing some context around these critical aspects of a lead service line replacement program, know that we take this work seriously and these are a sampling of topics and experiences that might be helpful to others. There are so many more lessons to share with countless numbers of utilities doing the work to replace lines.

A playbook covering these key topics and more would be most helpful to small and medium size water utilities, but we all can benefit from learning from others and adapting known practices to our community needs. With many utilities contributing their trials and real-life experiences on this long, ever-changing journey, a playbook will be a helpful start and reference for utilities to create thorough replacement plans. I am looking forward to the contributions of many outlined in a new playbook so we all can help each other implement successful, equitable lead service line replacement programs across the nation.

Cathy Bernardino Bailey is the Executive Director of Greater Cincinnati Water Works for the City of Cincinnati. Ms. Bailey is the first woman and African-American woman to lead the utility since its formation 200 years ago.

This blog was prepared following a convening by The Joyce Foundation and the Federal Reserve Bank of Chicago on January 10, 2024. The goal of the convening was to identify the information and resources communities need to tackle lead service line replacement. The Chicago Fed and the Joyce Foundation have prepared a report on the convening, “Identifying information gaps to help communities navigate lead service line replacement.” This blog is intended to provide deeper perspective on the need for a solid playbook to help guide small- and medium-sized utilities in developing lead service line replacement programs.