Automatic Enrollment Policies Can Make Lead Service Line Replacement Projects More Efficient and Expedient
Efficiency has become something of a buzzword, well, just about everywhere. We here at EPIC have long had efficiency on our minds, especially when it comes to replacing lead service lines (LSLs). At the heart of implementing an efficient LSL replacement (LSLR) program is protecting public health. This requires figuring out how to maximize scarce resources to replace LSLs. From our work with LSLR thought leaders (i.e., utilities, local governments, and community groups), we identified that the customer engagement and enrollment phases of LSLR projects can be unnecessarily resource-intensive.
To address this, we’ve taken a deep dive into LSLR programs, drawn lessons from other utility infrastructure efforts, and developed a set of best practices to streamline these phases of the project—what we call automatic enrollment policies. This set of policies aims to make the LSLR process as automatic, customer-friendly, and efficient as possible to allow communities to maximize the resources devoted to actual replacements.
Specifically, these policies reduce the number of steps customers need to take to participate in block-by-block LSLR programs and make it easier for water systems to access customer-side LSLs for replacements. These policies help water systems replace more LSLs and bring the joy of safe drinking water to more people.
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In this blog, we describe what automatic enrollment policies are and provide a resource with details on how states, municipalities, and public works programs have already put these policies into practice. We will also publish a follow-up blog that explores common scenarios water systems face when replacing LSLs and how automatic enrollment policies help expedite replacements in each scenario. We hope these can be a starting point for policy advocacy and adoption.
How Do Automatic Enrollment Policies Make LSLR Programs More Efficient?
LSLR program enrollment and property access processes are often resource-intensive for utilities and time-consuming for customers. Water systems typically require significant numbers of utility staff, consultants, or contractors to conduct outreach to property owners, while residents must enroll in the program, provide consent, schedule work, and facilitate payment. Despite intensive efforts to guide residents through these steps, these processes often have a high failure rate.
Automatic enrollment reduces the time and resources spent gathering paperwork and facilitates the efficient scheduling of projects for timely completion by contractors. While community outreach and education about planned LSLR projects is still required, automatic enrollment makes LSLR mandatory and enrolls customers by default. This significantly reduces the time and money water systems would otherwise spend ensuring customers complete paperwork to enroll and participate. Systems can plan projects that include even the properties of unresponsive owners because automatic enrollment policies allow occupants to facilitate access to LSLs. Together, these policies enable contractors to more confidently schedule efficient, block-by-block LSLR projects with the presumption that the work will go forward at the scheduled addresses within the scheduled project window.
We realize that water systems are sometimes constrained by state law that may preempt or otherwise prohibit some of the automatic enrollment policies recommended here. While these policies complement each other, they can also be implemented separately. We pulled them from water system LSLR programs that implemented just one or a few of the policies.
This blog and the follow-up blog will emphasize how these policies can support each other—enabling water systems to maximize efficiency by putting into practice all automatic enrollment policies. As the attached resource illustrates, Newark, NJ’s innovative program pioneered almost every one of these policies, helping it become one of the first cities to remove practically every LSL. Other municipalities and water systems, however, have streamlined replacements even without implementing the whole suite of policies.
Automatic Enrollment Policies and Example Resource
An automatic enrollment program may include some or all of the following six policies:
Mandatory LSLR
LSLR at no direct cost to property owners
Default enrollment
Opt-out through customer-initiated LSLR
Occupant facilitation of entry for LSLs
Water service restoration after LSLR
This section describes each of the policies above and concludes with a resource that provides examples from states and municipalities that have implemented these policies as a separate PDF file for you to download.
Image: Automatic enrollment graphic
Mandatory LSLR
An LSLR mandate is the foundation of automatic enrollment. A mandate requires property owners to replace the LSL either through a water system project or through their own initiative. An LSLR mandate provides the impetus for other automatic enrollment policies like enrolling customers in the system’s program by default, requiring proof of customer replacement to opt-out, and allowing occupants to facilitate replacement entry.
No Direct Cost to Property Owners
Programs that replace LSLs at no direct cost to the property owner can increase participation in block-by-block projects and more effectively implement other automatic enrollment policies.
Charging property owners for LSLRs creates barriers to block-by-block replacement projects for several reasons. First, some customers simply can’t afford it. Requiring a replacement and charging for it may also be perceived as unfair, since property owners likely had no role in the connection or selection of service line materials and may not be aware that they own the service line. Finally, even when affordability isn’t a major concern, a direct charge can discourage property owners’ cooperation with the water system.
The opportunity to get a replacement at no direct cost encourages property owner participation in block-by-block projects, which decreases more expensive, piecemeal or scattered replacements later. To realize these cost-efficiencies, systems should explore funding replacements through government grants, loans, bonds, or adjustments to customer rates; though we recognize that not all water systems can afford no direct cost replacements due to their financial situation, customer base, or other factors.
Default Enrollment
Water systems that enroll customers by default in block-by-block projects—without requiring owners to complete enrollment or consent forms—can reduce unnecessary and potentially confusing communications. Water systems should still collect an acknowledgement and information to schedule and facilitate entry for the LSLR through an access facilitation form. However, systems should have the ability to enroll customers in the project and proceed without such an acknowledgement, as our follow-up blog will outline in more detail.
Access facilitation forms should clearly explain key aspects of the program to occupants and property owners and facilitate water system access to replace the LSL. Our follow-up blog will dive deeper into form content.
Opt-out Through Customer-Initiated Replacement
LSLR programs that require owners to prove they’ve replaced their portion of the LSL within a specified timeframe as a condition of opting out of enrollment prevent delays and scattered follow-up replacements later. The policy places the onus on property owners to demonstrate that they should not be included in water system block-by-block projects. This enables water systems to finalize project scopes more quickly and complete replacements more efficiently.
Occupant Facilitation of Entry for LSLRs
To replace the LSL, workers must access the water meter, which is typically located in the basement or elsewhere within the property. As such, entry to the property is often necessary. Water systems that can replace LSLs through occupant-allowed access will be able to complete block-by-block LSLR projects more quickly by cutting out time spent chasing recalcitrant landlords. State law should empower tenants to facilitate access by ensuring that neither occupants nor water systems are held liable for occupant-facilitated replacements.
Water Service Restoration After Replacement
During any LSLR project, water systems must temporarily disconnect water flow to the property while workers replace the LSL. Reconnecting only after the replacement can facilitate LSLRs and reduce the need for LCRI-required tracking and outreach after a system is unable to replace an LSL. Water systems that can condition reconnection on access for replacements will be able to replace more LSLs through cost-efficient block-by-block replacement projects. In this way, water systems can channel more resources to replacements instead of the tracking and reporting of unreplaced LSLs.
Coupling this policy with the no direct cost to property owners policy ensures that water systems do not indirectly stop water service due to a customer’s inability to pay. If water systems charge directly for replacements, customers may refuse because they cannot afford the replacement, and then lose water service because of their refusal. Offering the LSLR at no direct cost means that customers who otherwise could not afford LSLRs are not at risk of water service disconnection. After replacement, service should be promptly restored regardless of any customer arrearages to ensure that: 1) customers don’t lose service based on an inability to pay and 2) customers can confidently engage with future LSLR projects without fear that participation will result in losing service because of arrearages.
Resource: LSLR Policy Examples
Our LSLR Policy Examples resource contains examples of states and municipalities that have implemented the above policies in LSLR or other public work programs. The tables in this resource list the state or locality, summarize the policy, and link to the relevant statute, ordinance, or other source for the policy.
Conclusion
Automatic enrollment policies save time and resources by reducing the need to follow up with property owners and reducing uncertainty about project scope. This enables water systems to schedule work more efficiently and avoid costs associated with tracking down property owners, project delays, and performing follow-up replacements. The cost savings can be reinvested to support additional projects and replacements.
These policies support more efficient and larger LSLR projects and simplify the experience for customers. Ultimately, this means more replacements, greater public health protection, and more households and communities that experience the joy of safe drinking water.
Watch out for our upcoming follow-up blog. It will review common scenarios water systems encounter during LSLR and illustrate how automatic enrollment policies help expedite replacements in each case.