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Editor’s note: The Environmental Protection Agency on Oct. 8, 2024, again tightened its regulations around lead in drinking water. The EPA issued a new rule (read the EPA’s announcement here) requiring drinking water systems nationwide to identify and replace customer-owned lead service lines within their service areas within 10 years. Denver Water began this work several years ago and, through its Lead Reduction Program, expects to have replaced all customer-owned lead service lines within the utility’s service area before 2035.

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In October, federal rules designed to reduce the risk of lead in drinking water will receive their first major update in more than three decades.

Called the Lead and Copper Rule Revisions, an update to rules that took effect in 1992, the new revisions represent a major step in the Environmental Protection Agency’s efforts to remove lead from infrastructure of the nation’s drinking water systems. 

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The water Denver Water provides to homes and businesses is lead-free, but lead can get into water as it moves through lead-containing household fixtures, plumbing and water service lines. 

The utility has worked for years to reduce the risk of lead in drinking water for its customers, including through its groundbreaking Lead Reduction Program launched in 2020. 

The EPA’s new rules will slightly alter some aspects of that program. 

“These new rules represent a major shift from a national perspective. But for Denver Water, most aspects of our Lead Reduction Program will remain business as usual. We will continue to replace lead service lines at no direct cost to the customer, communicate with customers about their property, send filters to customers in the program and maintain the pH of the water we deliver,” said Alexis Woodrow, the utility’s program manager. 

“But you’ll also see a shift in our inventory of lead service lines, how we communicate about those lines and how we test for lead in drinking water,” she said. 

Denver Water hosted a virtual community meeting Aug. 22, 2024, to answer questions about these changes and encourage customers to contact the utility with property-specific questions. Click here for details and a recording of the meeting.

Denver Water’s Lead Reduction Program started in 2020 and is expected to be finished before 2035. 

As of July 1, the utility has: 

• Replaced more than 26,000 customer-owned lead service lines at no direct cost to the customer. 
• Provided tens of thousands of filters designed to remove lead from drinking water to customers enrolled in the program to use for drinking, cooking and preparing infant formula until six months after their lead service line is replaced with a lead-free copper line. 
• Developed, posted and regularly updated an interactive map of lead service lines for all properties within its service area. (Find the map at denverwater.org/Lead.)
• Communicated regularly with customers about their property, the use of filters and what they can do to protect themselves and their families from lead. 
• Raised the pH of the water it delivers to protect customers with lead lines or plumbing fixtures from lead getting into their water. 

The EPA estimates there are more than 9 million old, lead service lines in use across the U.S. 

They’re a legacy of a time when lead — a common, inexpensive and easy-to-work-with metal — was the industry standard for the smaller service lines that carry water from a utility’s delivery pipes under the streets into homes and buildings. 

The federal bipartisan Infrastructure Investment and Jobs Act, signed by President Joe Biden in 2021, included $15 billion for lead service line replacements. Denver Water received about $76 million at the end of 2022, allowing the utility to accelerate its replacement work. 

Mapping lead service lines

A major part of the EPA’s new rules that take effect in October requires utilities to locate lead service lines in their service area and to notify customers if they have a lead service line serving their property. Denver Water started work on that initiative a decade ago, work that resulted in a regularly updated inventory map posted at denverwater.org/Lead. 

Denver Water’s system has about 312,000 service lines.

When the program began in 2020, Denver Water estimated the number of lead service lines in its service area to be between 64,000 to 84,000. Now, program managers believe that number to be closer to the 60,000 to 64,000 range, of which 26,000 lead service lines already have been replaced. 

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“That new estimate represents hundreds of people conducting thousands of investigations — including looking at public records and inside customers’ homes, testing water samples for lead, asking customers to send us water samples, potholing in streets and yards to physically look at the service lines — to accurately categorize the lines and make sure our customers are safe,” Woodrow said. 

Changes to the inventory map

Under the new rules, Denver Water’s public inventory map of lead service lines is being streamlined to three categories of lines, down from four. 

The three categories are: 

• Confirmed lead service line, including galvanized steel service lines that must be replaced. No change in terminology. Customers in this category are enrolled in the Lead Reduction Program.
• Unknown service line material. Denver Water’s map previously had broken this category into “likely to have a lead service line” and included in the program, or “unlikely to have a lead service line” based on the information available and the potential for lead at the location.
• Non-lead service line. No change in terminology.

About 17,000 properties that had previously been listed as “unlikely to have a lead service line” will move to the new Unknown category. These are properties the utility needs more information about, such as conducting a free water test (request a test kit at denverwater.org/LeadTest), in order to confidently shift the property to the “lead” or “non-lead” categories.

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“Denver Water has been working since before the program began to learn which customer-owned service lines contain lead or galvanized steel and which don’t. We’ve frequently communicated with customers about their property and asked them to help us determine the material of their line, and that work will continue until we can confirm whether or not their service line contains lead," Woodrow said. 

Denver Water customers can request a free kit to collect water samples to be tested for lead to help confirm the composition of their water service line. The utility also has a new, online tool, at denverwater.org/ServiceLineMaterial, to help customers complete a scratch test and report the material of their service line.

Additional communication 

Under the EPA’s new rules, all properties in the Lead or Unknown categories will receive a communication from Denver Water every year with information about the type of material in their service line until the service line is replaced or confirmed to be non-lead. 

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Learn more about the Lead Reduction Program at denverwater.org/Lead. 

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The new communications will include warnings that exposure to lead in drinking water can cause serious health effects in all age groups, from infants and children to adults. 

And these annual notices will be in addition to the regular communications Denver Water conducts with its customers as part of the Lead Reduction Program. 

Testing protocols 

Denver Water has tested customers’ drinking water for lead since the Lead and Copper Rule took effect in 1992. That testing will continue, with some required changes that Denver Water has already implemented, Woodrow said. 

The changes, such as collecting more water samples from homes known to have lead service lines, will help utilities better assess if the home’s drinking water has lead in it.

The federal rules also require utilities to offer to test water samples from schools and daycares for lead. 

In 2022, Colorado passed a law requiring child care centers, in-home care providers and schools that serve any grades preschool through fifth grade to test their drinking water for lead by the end of May 2023 and remediate if needed. Public schools serving grades six through eight must test their drinking water for lead by Nov. 30, 2024. 

The rules also create a new trigger level requiring utilities to act. If more than 10% of homes tested have lead levels above 10 parts per billion, a water utility would have to take steps to reduce lead in drinking water. However, the EPA’s action level remains set at 15 parts per billion.

Test results for Denver Water indicate the utility will be below the new trigger level of 10 parts per billion, Woodrow explained. 

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Since 2020, Denver Water has adjusted its Lead Reduction Program to help customers in a variety of ways, including:

• Creating a Lead Reduction Program website in Spanish, at denverwater.org/Plomo.
• Creating an online form for customers enrolled in the program to request new or additional water pitchers and filters certified to remove lead from drinking water. 
• Creating an online consent form (and allowing tenants of a property to sign the form) permitting the lead service line to be replaced at no direct cost to the property owner. 
• Creating an online tool, at denverwater.org/ServiceLineMaterial, to help customers complete a scratch test and report the material of their service line.

“Replacing lead service lines is good for public health, and the EPA’s new rules will help make that happen,” Woodrow said. 

“At Denver Water, we are and have been committed to replacing all service lines in our communities and working closely with customers to accomplish this.”