City public works staff are continuing their efforts to prepare for new federal regulations pertaining to lead levels in public drinking water that are set to go into effect in October 2024.

The rules will lower the amount of detectable lead in the water that triggers treatment actions and data reporting, with the potential for significant cost to the City of Great Falls.

The new rules are from the U.S. Environmental Protection Agency and city officials have said in multiple public meetings the revision for stricter compliance was triggered by the 2014 Flint, Mich. water crisis in which public water supplies were contaminated with lead.

City staff have been briefing commissioners on the new rule for two years and updated City Commissioners on their progress during a June 4 work session.

City continuing effort to inventory water service lines ahead of new EPA rules

City staff are looking at options to use state revolving loan funds toward the anticipated costs of replacing lead water lines, which the EPA will require municipalities to do under the new rule, which is still being finalized.

City staff had initially planned to use the state funds for a pilot program to help homeowners cover the costs of lead line replacement, but determined the funds weren’t allowed to be used in that manner.

The state funds are through a loan, with 60 percent forgiven and the other 40 percent has to be paid back.

Staff is now considering using those funds itself to pay for the replacement costs, but then the the 40 percent payback would have to be paid by the city, meaning that cost would be spread over all city water ratepayers, rather than the individual property owner.

If the city doesn’t use the state loan funds, it’s only other funding options are Community Development Block Grant funds, which are federal funds for eligible projects in low to moderate income areas; or property owners carry the full replacement cost.

City planning pilot program to replace lead lines for upcoming EPA rule [2023]

Chris Gaub, city public works director said, told The Electric that CDBG and state loan funds can’t be mixed, so the use of one eliminates the ability to use the other.

During the June 4 work session a commissioner asked if there was an incentive for property owners to replace their lead lines.

Gaub told The Electric that if they don’t, the city will have to pay for it and that cost would be spread to all water utility rate payers in the city.

He said the incentives he could think of for property owners to replace their lead lines are:

• for their own health since their lead lines would only affect the water supply to their property
• to not further burden their fellow rate payers
• to potentially not negatively affect the sale of their property

Jesse Patton, city engineer, told commissioners that staff was looking for some direction from them on whether staff should pursue using the state loan funds to help pay for the service line replacement and then spread the repayment costs across all ratepayers.

How far will Montana’s push to remove lead from school drinking water go? [2023]

The EPA is requiring a public inventory of lead, galvanized and unknown water service lines.

Gaub said staff is working through what that will look like.

He said they’re awaiting the EPA’s copper and lead line regulations, possibly released in October, and that those regulations will guide staff’s way forward on determining how to implement those rules locally.

“That said, EPA typically gets more restrictive versus less,” he said.

Under the new rules, the inventory will have to show what water service lines are not known as lead, those that are known as lead and those that are unknown.

City developing plans for new federal rules on lead in drinking water [2022]

The city adopted rules in the 1960s or 70s that prohibited lead pipes and they can use that documentation to help identify what type of pipes are where in the city.

The city has been using historical records to identify as many service line materials as possible, and sent 10,000 letters to property owners who might have non-copper service lines over the summer of 2022 asking them to do identification tests of their pipes.

As of May 2023, the city had identified 14,846 or 67.8 percent lines as non-lead; 142 or 0.6 percent as lead; 502 or 2.3 percent as galvanized; and 6,423 or 29.3 percent as unknown.

Only about 3,000 people had responded to the letters about identifying service lines, James Hewitt of public works told commissioners during their June work session.

GFPS working to replace, fix faucets, sinks where lead detected under new state rule [2022]

Staff has been following up with phone calls. Hewitt said they ask homeowners to return the info or staff will go out and help them get the info to identify the line material.

Hewitt said homeowners aren’t returning messages, hanging up on staff or choosing not to participate.

Hewett told commissioners during the June 4 meeting that they’d completed the follow up calls with roughly 7,500 homeowners.

As of April 2024, staff had identified the following water service lines in the city limits:

• non-lead: 15689 or 71.6 percent
• lead: 149 or 0.7 percent
• galvanized: 591 or 2.7 percent
• unknown: 5,486 or 25 percent

Unknown lines are considered lead until proven otherwise under the EPA regulations.

Gaub said during the June 4 work session that the city had spent $387,159 in staff time making those calls and working on plans to meet the new EPA rule.

The city received a technical assistance grant through the Montana Department of Commerce for 100 hours of engineering hours at no cost to the city.

AE2S, an engineering firm with a Great Falls office that has assisted the city on a number of water related projects, has been assigned to the city for the grant.

They’ll help the city prepare the inventory that will be submitted to the EPA and Montana Department of Environmental Quality in October. Once that’s submitted, the city has three years to finalize it, Gaub said.

Once the inventory is complete, Gaub said city public works staff will refine their proposed strategy to meet the new requirements and present that plan during a September commission work session.

Patton said that the current version of the EPA rule will require municipalities to replace lead lines at a rate of 10 percent per year.

With the current estimate of lead and unknown lines, staff estimates the city will have to replace lines a year at a cost of $10,000 each for $920,000 annually.

That equates to a rate increase of $41.82 annually or $3.48 per month for city water customers. That rate increase would be in addition to any other rate increase needed to cover any other facility improvements or increased costs.

Over 10 years, staff estimates a $9.2 million cost to the city.

He said the city wants to identify the unknown lines so they don’t have to replace them if they aren’t otherwise required to be replaced.

Staff has been preparing for the rule for two years and Patton said, “every time we look into this, the news gets worse.”

City Manager Greg Doyon said it’s a frustrating rule and “basically, EPA is making us be the bad guy in this.

He said the options for the city “aren’t awesome” and the city would have to use the water fund, which is user fees, to offset the cost of replacing the lead service lines.