Temporary Filter Distribution for Identified Lead Service Lines as Part of Lead Service Line Replacement Program

Case Example of Direct Filter Distribution in Denver, CO

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Project Overview

In 2020, Denver Water initiated the Lead Reduction Program, a comprehensive effort to reduce lead exposure from drinking water. The program includes the replacement of lead service lines (LSLs), distribution of free water pitcher filters, and adjustments to water chemistry to reduce lead leaching. By proactively engaging the community and implementing swift measures, Denver Water aims to safeguard public health and serve as a model for other municipalities.

Background

Although the water supplied by Denver Water is lead-free, lead can enter drinking water through customer-owned lead service lines and household plumbing.

In 2018, Denver Water faced a critical decision regarding how to reduce lead levels in its drinking water. The traditional approach, required by the Environmental Protection Agency’s (EPA) Lead and Copper Rule, involved adding orthophosphate—a corrosion inhibitor that forms a protective layer inside pipes to reduce lead from leaching into the water. However, the addition of orthophosphate to the water supply posed potential environmental challenges. Elevated phosphate levels could contribute to nutrient pollution in downstream ecosystems, potentially leading to algal blooms and other ecological disturbances. Therefore, Denver Water proposed an alternative strategy, leading to a request for a variance from the Environmental Protection Agency (EPA).

Rather than solely focusing on corrosion control, DenverWater proposed a holistic Lead Reduction Program Plan, which included accelerated lead service line replacements, the distribution of water filters to affected residents, and adjustments to water chemistry through pH and alkalinity modifications. The goal was to address lead contamination at its source—by removing lead service lines—while providing immediate protection to residents.

Program Implementation

Denver Water’s Lead Reduction Program comprises several key components:

  1. ‍Lead Service Line Replacement (LSLR): The utility plans to replace an estimated 60,000 to 64,000 lead service lines with copper lines by 2034, at no direct cost to customers. Priority is given to critical facilities such as childcare centers and schools, as well as underserved communities. ‍
  2. Free Filter Distribution: To provide immediate protection, Denver Water supplies free water pitchers and filters certified to remove lead to all customers with known or suspected lead service lines. Customers are advised to use filtered water for drinking, cooking, and preparing infant formula until six months after their lead service line has been replaced. ‍
  3. Water Quality Treatment: Adjustments to the pH and alkalinity of the water are made to reduce the risk of lead and other metals leaching into drinking water from service lines and household plumbing. ‍
  4. Community Outreach and Education: Denver Water conducts extensive outreach to inform and engage the community, including virtual meetings, educational materials, and partnerships with local organizations to ensure residents are aware of the program and understand how to use the provided filters. 

Funding

Denver Water’s Lead Reduction Program is funded through a combination of federal assistance and Denver Water’s internal resources:

  • In December 2022, Denver Water secured $76 million in federal funding from the Bipartisan Infrastructure Law to accelerate the replacement of lead service lines. This funding was provided in the form of a low-interest loan from the Colorado Drinking Water State Revolving Fund, with$40 million of the loan forgiven as part of the federal infrastructure investment. 
  • Prior to receiving federal assistance, Denver Water financed the Lead Reduction Program through water rates, bonds, and revenue from hydropower sales. The combination of federal funds has enabled the utility to expedite the replacement process, increasing the number of LSL replacements from 5,000 per year between 2020 and 2022 to 7,000 in 2023 and nearly 8,000 in2024. 
  • The program is provided at no direct cost to customers.Denver Water is identifying lead service lines using a combination of investigative methods, including property records, water tests, and visual inspections. 
  • Additionally, Denver Water offers a reimbursement program for property owners who choose to replace their lead service lines independently, providing a one-time payment of $3,800, which is approximately half of the utility’s cost for replacement. 

Through this multifaceted funding approach, Denver Water demonstrates a strong commitment to public health and infrastructure improvement, setting a precedent for other utilities aiming to address lead contamination in drinking water systems.

Denver by the Numbers

  • ‍1,000,000 Filters: Over a two-month period in 2020, Denver Water distributed over 100,000water pitcher to residents. Denver Water continues to send filter replacement until six months after the lead service line has been replaced or confirmed to be non-lead, with nearly 1 million filters being distributed since the program launched. This large-scale distribution ensures that households have immediate access to lead-free water while awaiting service line replacement.‍
  • 83% Filter Compliance: As part of its innovative program, Denver Water measures actual filter adoption by its residents enrolled in the program via a biannual survey to those residents. As of October 9, 2023, more than 4 in 5 enrolled residents use the filter provided as intended.‍
  • 30,000 Replacements: With additional funding from the Bipartisan Infrastructure Law, the utility accelerated the replacement pace in 2023, putting it on track to complete the replacements ahead of the initial 15-year schedule. In 2024 alone, Denver Water replaced nearly 8,000 lines, bringing total replacements to over 30,000.‍
  • 42,000 & 1.3 Million: Number of event attendees and mail, digital and phone outreach (respectively) to date of Denver Water’s public outreach & education campaign around its lead reduction program.‍
  • Nearly 120,000 service line investigations conducted.‍
  • 40,000 water samples collected.‍
  • 65% reduction in lead levels across the service area due to pH adjustment.

Best Practices Implemented

  • ‍Proactive Communication: Denver Water sends advance letters to residents before distributing filters, ensuring they are informed and prepared. All communications are provided in both English and Spanish to owners and tenants. Consistent branding and clear instructions are included with each filter kit to facilitate proper use.‍
  • Data-Driven Prioritization: The utility employs a predictive model using machine learning and known pipe and water quality data to identify and prioritize lead service line replacements, focusing efforts on high-risk areas and vulnerable populations. ‍
  • Continuous Improvement: Denver Water has refined its approach over time, conducting investigative sampling to identify lead service lines and later implementing a protocol to offer customers lead testing kits five to six months after replacement to confirm the absence of lead.‍
  • Collaborative Partnerships: The program includes partnerships with local organizations to enhance outreach and education efforts, ensuring diverse communities receive information and support tailored to their needs.

Community Feedback

Denver Water sends a survey to customers via email (and as a link in other email communications) with the primary goal to better understand the customer experience and to gauge the level of perceived program value. Key takeaways regarding program value and communications include:

  • 95% of all respondents support the continuation of the Lead Reduction Program.
  • 91% of respondents report that the LRP is very important to the well-being of our community, including public health protection and improving property values.
  • Nearly 90% of respondents were supportive of the goal to remove all lead service lines.
  • 82% of respondents report that communications and materials from Denver Water are helpful.

2022 letters of support:

Denver Water’s Lead Reduction Program serves as a national model on how water utilities can protect public health by reducing exposure to lead in drinking water through a holistic program that provides layers of protection for the consumer. The program is the first of its kind in the nation, and despite challenges created by the COVID-19 pandemic, supply chain issues and labor shortages, Denver Water continues to exceed all milestones of the variance on or ahead of schedule. In addition to protecting public health, the Lead Reduction Program also protects water quality in the South Platte watershed, a critical resource to both the immediate and downstream communities, farmers and ranchers who depend on this water. The Lead ReductionProgram protects aquatic health and avoids potentially dangerous algal blooms in downstream rivers and reservoirs, while also saving hundreds of millions of dollars in wastewater treatment costs.
‍– excerpt from letter from former DenverMayor Michael Hancock

The Colorado Department of Public Health and Environment (CDPHE) strongly supports Denver Water's Request for Variance and the Lead Reduction Program Plan submitted to EPA on March 18, 2022. The department concludes that the variance request demonstrates that implementing this alternative treatment technique is at least as efficient in lowering the level of lead in tap water as the designated Optimum Corrosion Control Treatment technique of orthophosphate addition. Furthermore, the department believes this approach better protects public health and the environment because the primary source of lead in tap water will be removed, and potential environmental impacts from orthophosphate will be avoided. Denver Water has committed to the Lead Reduction Program Plan since the original variance was approved in 2019, exceeding minimum performance goals and greatly reducing lead exposure to the public by removing thousands of lead service lines. This work was accomplished while adequately distributing pitcher filters to homes that may be served by lead service lines as well as by tightly controlling the pH of the distribution system to 8.8 standard units. The overall lead levels have continued to decrease in the distribution system through the last three years, even as the Denver Water crews have rapidly been removing lead service lines.
– excerpt from letter from Nicole Rowan, Division Director at the Water Quality ControlDivision of CDPHE.

Conclusion

Denver Water’s Lead Reduction Program exemplifies a proactive and comprehensive approach to addressing lead in drinking water. By combining large-scale filter distribution, systematic lead service line replacements, water quality treatment, and robust community engagement, the utility effectively protects public health and serves as a model for other communities.

 

Recommendations for Other Communities

Develop Comprehensive Lead Reduction Strategies

Implement programs that combine immediate protective measures, such as filter distribution, with long-term solutions like service line replacements.
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Leverage Technology for Prioritization

Use predictive modeling and data analysis to identify high-risk areas and efficiently allocate resources.
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Engage and Educate the Community

Maintain transparent communication and provide educational resources to ensure residents are informed and involved in lead reduction efforts.

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Seek Collaborative Partnerships

Work with local organizations, government agencies, and stakeholders to enhance program effectiveness and outreach.

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By adopting these best practices, communities can effectively reduce lead exposure from drinking water and protect the health of their residents.