There are lead service lines in older communities across Michigan. Because of their age and population size, it’s fair to say the bulk of Michigan’s lead service lines are in cities in Southeast Michigan.
I spent a lot of time trying to determine which Detroit suburbs have lead service lines and how many. I wanted to see how far out into the suburbs lead was found in underground water pipes.
It was relatively easy (albeit an expensive FOIA bill near $2000 for these "public documents") to track down which communities were testing lead lines. But figuring out how many lead pipes were in each community is nearly impossible.
More than 60% of communities on this map with lead service lines do not know how many there are.
The Lead and Copper Rule requires cities to gather this basic information of how many lead service lines they have and where they are. That rule was adopted in the summer of 1991.
Now, Michigan’s Department of Environmental Quality is likely to require cities to make a renewed effort to gather this information, either as part of asset management plans or the agency’s current effort to strengthen state lead in water rules.
One of the potential changes being considering would more directly affect the 100+ communities that get water via The Great Lakes Water Authority. The state’s draft rules say the consecutive monitoring program in place in the Detroit area could be eliminated.
Under consecutive monitoring, many Detroit suburbs are permitted to test fewer homes for lead in water than the Lead and Copper Rule would otherwise allow.
For example, water systems in Jackson, Port Huron, Eastpointe and Southgate each serve 30,000-35,000 people. Each city has lead pipes. None of these cities know exactly how many or where their lead lines are.
Under the Lead and Copper Rule, Port Huron and Jackson are required to test water at 30 total homes every three years for lead. But Eastpointe and Southgate only have to collect 6 water samples. That’s because Eastpointe and Southgate are part of The Great Lakes Water Authority.
Only half of those must be from homes with lead service lines. So Eastpointe, as an example, only had to test 3 homes with lead service lines in 2015.
Warren, a city with unknown lead service lines that serves roughly 135,000 people, only has to sample 26 homes (13 with lead lines). But Ann Arbor, a city without lead lines that serves roughly 114,000 people, is required to test 50 homes every three years, because Ann Arbor is not served by GLWA.
This agreement was hashed out in the early 1990s. Officials from Detroit’s Water and Sewerage Department, the then Michigan Department of Public Health (MDEQ didn’t exist then) and the U.S. EPA all signed off on the modified sampling requirements.
The idea was to strike a balance between two very different possible interpretations of the newly passed Lead and Copper Rule.
No one wanted Detroit, and each community on the water system, to be treated as one giant system; only required to take 100 samples in total. That wasn’t a realistic option being considered, I’m told. But they didn’t think the other extreme, where each community using essentially the same water would have to take numerous, duplicative tests, was a good approach either.
James Cleland headed up the drinking water division at the time this monitoring system was put in place. He remembers the rule was a big change for his staff and water system operators. In Detroit, he says they wanted to come up with a compromise of sorts.
“Because this (same) water flows through these systems, it just didn’t seem economically prudent to have to collect that full number of samples where you were just going from one community to the another across the street and you were tacking on another big monitoring burden,” Cleland said.
“We got as representative of a sample pool but at a far reduced cost.”
So the state, with support from DWSD, proposed a modified approach to U.S. EPA based on population served in each community. The EPA approved the modifications and that’s held up to this day.