Improving public policy through qualitative research: Lessons from homeowners about lead service line replacement under the federal Lead and Copper Rule

The Environmental Protection Agency's (EPA's) Lead and Copper Rule (LCR) of 1991 was issued to protect consumers from lead in drinking water. Key among the Rule's provisions is that when a jurisdiction's drinking water tests high for lead, the responsible utility must implement a program to replace lead service lines (LSLs). This provision mandates only "partial" replacement – that is, replacing the publically owned portion of a LSL. Replacement of the privately owned portion, which results in "full" replacement, requires homeowner willingness to cover the cost of the work. To date, the vast majority of LSL replacements in the US under the LCR have been partial. Concerns about health risks associated with such replacements surfaced in the early days of the LCR's inception, but relying on unexamined assumptions about homeowner decision-making, EPA deemed that the benefits of the provision would outweigh the risks. Twenty years after the Rule's adoption, however, the Centers for Disease Control and Prevention (CDC) found a link between homes with a partial LSL replacement and elevated blood lead levels among children. Our study, sponsored by the Robert Wood Johnson Foundation, set out to identify potential gaps in the LCR's LSL replacement provision that might contribute to unintended public health harm. We will present data from ethnographic interviews with homeowners in Washington, DC and Providence, RI – two cities with extensive LSL replacements – to shed light on consumers' first-hand experiences with, decisions about, and assessments of the LCR's LSL replacement requirement. We will conclude with the recommendation that EPA reexamine the safety of the LCR's LSL replacement provision, not only by reassessing its original assumptions, but also by examining the possibility that the requirement it created to eliminate an important source of lead in water may be contributing to environmental injustices in communities across the country.