Automatic Enrollment Case Study: Detroit’s Policies Accelerate Replacements

Case Study: Detroit Water and Sewerage Department

EPIC has previously written about household engagement and property access best practices that we call Automatic Enrollment policies. We drew on Detroit’s mandatory replacement, no direct charge, owner-initiated opt-out, and occupant-facilitated access policies to inform our whitepaper on Automatic Enrollment policies. This blog highlights how the Detroit Water and Sewerage Department (DWSD) implemented these policies to effectively engage whole neighborhoods to access properties and accelerate lead service line replacements (LSLR).  Detroit has replaced almost 16,000 LSLs, including 12,000 since 2023 when DWSD started replacing LSLs through a neighborhood-level project approach. 

I recently met with DWSD representatives to learn more about how automatic enrollment policies have supported replacements. DWSD will be joining a webinar on May 19 to discuss their program in more depth, you can register or find a recording here

DWSD’s Program and Automatic Enrollment Policies

Detroit has had a dedicated replacement program since 2018 and has adopted policies to help improve engagement and property access. DWSD launched its lead service line replacement program in 2018 with policies designed to maximize participation and accelerate replacements at scale. From the outset, replacements were mandatory, DWSD covered the full replacement cost with no private-side cost share, and both property owners and occupants were permitted to authorize access agreements for replacement work. These policies were implemented prior to the Michigan Lead and Copper Rule taking effect and helped position Detroit as a national example for large-scale lead service line replacement programs. 

Michigan’s landmark Lead and Copper Rule revisions took effect in 2018, requiring utilities and municipalities to take action to replace LSLs. The revisions, which preceded the federal Lead and Copper Rule Improvements enacting similar requirements nationwide, made Michigan utilities responsible for replacements and required them to fund the private-side cost, establishing the strongest lead service line replacement requirements in the county.  DWSD’s program policies aligned closely with these public health-centered principles from the beginning, including full public funding for replacements and mandatory replacement requirements. Detroit financed replacements through a combination of state and federal public funds, municipal bonds, and water rate revenue. 

How Automatic Enrollment Policies Have Helped Detroit  Replace LSLs  Faster and More Cost-Efficiently

Automatic enrollment policies have helped DWSD engage communities, control costs, and accelerate replacements.

Starting in 2018, Michigan required utilities to replace all LSLs over the next 20 years. From 2018 to 2022, DWSD performed 3,000 replacements.  The Michigan requirement, DWSD’s policies, and state funding laid the foundation for DWSD to scale up its replacements through a “neighborhood-by-neighborhood” approach. DWSD has replaced 12,000 LSLs since 2023 and set a goal of replacing Detroit’s 80,000 LSLs over 10 years, ahead of regulatory deadlines.

As part of regular, holistic reviews of the LSLR program, DWSD implemented a comprehensive customer engagement and a program centered on public health and safety to build trust and effectively replace LSLs at the neighborhood level. DWSD’s policies of no direct charge and occupant facilitated access helped DWSD meaningfully connect with communities through direct outreach to occupants. Since the policy empowers occupants to facilitate replacement, engagement with DWSD is practical and impactful. Inability to pay is also not an issue; occupants can engage confidently with DWSD without worrying they might get cut out of the program due to affordability or an unresponsive landlord. DWSD said that these policies help demonstrate their commitment to public health and boost community trust in the program. With this trust, DWSD can reduce the number of times they reach out to occupants and property owners, but make each engagement more meaningful.

Not only have automatic enrollment policies helped DWSD replace LSLs at neighborhood scale, they have helped DWSD control costs. DWSD used its own employees at a cost of $9,700 per replacement in 2024, while contractor prices were around $13,000. DWSD says occupant-authorized access is essential to keeping costs down because it reduces resources spent following-up with owners and keeps projects on schedule. This policy and the no direct charge policy also help ensure that households are included in neighborhood-scale replacement projects. Without these policies, DWSD would need to perform more expensive, one-off follow-up replacements and undertake additional documentation and follow-up per the LCRI. 

Conclusion

DWSD pioneered Automatic Enrollment policies to better engage customers, scale up replacements, and control costs. To hear more about Automatic Enrollment and DWSD’s program, register for or view the webinar here. You can also reach out to Erica Galante-Johnson at erica@policyinnovation.org or Sonali Patel at Sonali.Patel@detroitmi.gov

Jack Travis

Jack is the Water Law Fellow at EPIC. He recently graduated from NYU School of Law with a JD. As a student, he interned at EPIC, NRDC, and the Office of the New York Attorney General and was the digital executive editor of the Review of Law and Social Change. Jack previously worked as a healthcare technology project manager and consultant. He holds a bachelor’s degree in economics from the University of Wisconsin-Madison.

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