In this blog, law student Maria Lucas reflects on the City of London’s progress to remove lead from their drinking water.
Fourteen years ago today, the London Free Press revealed that residents in the City of London had been tolerating high lead levels in their drinking water for at least 12 years. Despite there being a provincial standard of 10 micrograms per litre (µg/L), there was no provincial regulation to mandate municipal water testing for lead.
Today, CELA is checking in on London’s progress to fully address the lead-in-water issue.
Lead can leach into drinking water through lead service lines that connect a municipality’s water main under the street to the water meter in a home, in some circumstances. Generally, municipalities take the position that the portion of the lead service line that runs on municipal property (from the water main to the property line) is owned by the municipality, and the portion running from the property line to the water meter belongs to the property owner.
Beginning in 2006, the City of London developed a three-pronged strategy to reduce lead levels at consumers’ taps. The strategy consists of: (1) education and awareness; (2) water chemistry changes; and (3) lead service replacements.
1) Education and Awareness
The City of London posts information on the City’s website and uses several “Enviroworks” flyers to educate and raise awareness regarding lead exposure and lead water service lines. In each of these communications, residents are informed of the City’s free lead testing program and are encouraged to call and arrange a home visit for a water sample to be taken. The laboratory results of all samples taken are mailed to homeowners with an explanatory letter. If the lead level in the water sample is elevated, an information package is provided to the homeowner. These packages are prepared by the Middlesex-London Health Unit and contain important information regarding potential health effects related to lead exposure and steps that can be taken to reduce exposure to all sources of lead.
In 2019, the Tainted Water investigation revealed dangerous levels of lead in drinking water across Canada. In Ontario, government data posted online showed 919 lead exceedances of the federal guideline of 5 micrograms per litre (ug/L) in lead tests of tap water from about 2017 to 2019. Exceedance rates reached as high as 50 per cent in some municipalities. In London, half of the 36 tests conducted exceeded the federal guideline. London’s exceedances were in homes and businesses targeted by the city because they had lead service lines and as a result, were expected to have higher lead levels.
These findings suggest that some London residents are still vulnerable to lead exposure despite the City of London’s longstanding outreach efforts regarding the lead-in-water issue.
2) Water Chemistry Changes
In 2007, after the story about high lead levels was revealed in the Press, the City of London began to adjust the pH levels in the City’s drinking water. The City found that raising the pH of the water following treatment would significantly reduce lead exposure. In late 2007, pH adjustment equipment was installed at the water treatment plant near Grand Bend, which is part of the Lake Huron Primary Water Supply System (this system services the vast majority of older London homes). In January 2008, gradual pH adjustment began and continued to 2017 with a target pH value of 7.9.
3) Lead Service Replacements
Lead water service lines are replaced in London under 3 different programs: (a) the lead service replacement program; (b) the capital water main replacement program; and (c) the targeted lead service replacement program.
Under the lead service replacement program, both the public and private portions of the lead service lines are replaced, resulting in a full-service replacement. The average cost to the homeowner of replacing the private portion of a lead service line under this program is $1,500.
Under the capital water main replacement program and the targeted lead service replacement program, the public portions of the lead service lines are replaced, but the homeowners may or may not choose to replace the private portions. Where a homeowner chooses to replace the private portion, the homeowner will pay on average a cost of $1,100.
The City of London communicates to residents that a full-lead service line replacement is best in terms of reducing exposure to lead. To assist homeowners with private-side lead service line replacements, the City of London established a low-interest loan program whereby the City will lend homeowners the full amount required to replace the private portion of the lead service line. The loan is then collected over a 10-year period along with the property tax payments. The average loan payment is less than $15 per month.
As of 2017, a total 4,666 public lead service lines were replaced in London since 2006, for an average of 424 replacements per year. In 2017, it was estimated that approximately 4,350 full lead service lines remained in London. The 2019 Tainted Water investigation revealed that there were an estimated 10,000 lead lines on private property in London.
Lead Levels in London at Present
After the London Free Press story broke in 2007 regarding alarmingly high levels of lead in the City’s drinking water, the Ontario Ministry of the Environment ordered municipalities across the province to test for lead in drinking water. As mentioned, Ontario’s drinking water quality standard for lead is 10 µg/L. Some of London’s 2019-2020 lead test results reveal that the City’s lead levels exceeded the provincial standard of 10 µg/L. These exceedances are reflected in samples taken from plumbing in the City’s distribution system. The exceedances ranged between 11 and 42 µg/L.
Further, the City’s plumbing standing and flushed drinking water samples taken from public schools reveal some lead exceedances above the provincial standard. For example, a plumbing standing drinking water sample taken from a public school called Stoneybrook revealed a lead exceedance of 350 µg/L.
These results indicate that although London is making progress in reducing lead exposure, there is still a long way to go, particularly in mitigating lead exposure in public schools. The City of London should continue its efforts to ensure safe, clean drinking water for London residents, as exposure to lead can have significant adverse impacts on their health.
The big takeaway from this update is that even in communities that are actively working on addressing drinking water threats, such as the City of London is doing with lead, there is still a need for constant monitoring and vigilance by drinking water utilities. The role of public health is crucial in building public awareness and trust. You can anticipate that CELA will be calling on the province to ensure that all communities expedite their actions on getting lead service lines removed from private residences.