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NASUCA 2017 MID YEAR. Should Water Utilities Replace Customer-Side Lead Pipes?. Who should pay to replace the customer-owned portion of a lead service line?. Introduction. Edward Kaufman – Indiana Office of utility consumer counselor Geoff Marke, PHD – Missouri office of public counsel
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NASUCA 2017 MID YEAR Should Water Utilities Replace Customer-Side Lead Pipes?
Who should pay to replace the customer-owned portion of a lead service line?
Introduction • Edward Kaufman – Indiana Office of utility consumer counselor • Geoff Marke, PHD – Missouri office of public counsel • Gary naUmick – American Water Works
DISCLAIMER • The views expressed in this presentation are mine. • They do not reflect any policy positions or recommendations on behalf of the OUCC or the Utility Consumer counselor.
Issues • Both portions of the pipe should be replaced at the same time • partial replacement can increase lead levels • same time replacement is less expensive • Replacement is Costly to customer • Many customers have low incomes • Apartments and non-user owners • Timing - programs may take many years • Communications with customers
Ratemaking Issues • Who will own the replaced pipes? • Depreciation vs. Amortization? • Some customers may already have replaced their portions of the led line • Does lead line replacement displace other Utility investment?
Indiana House enrolled act 1519 • Passed in 2017 • Indiana Code 8-1-31.6: Customer Owned lead service lines • The water Utility must first obtain commission approval for its plan to replace customer-owned lead service lines • The utility’s plan must address: • The availability of grants or low interest loans and how the water utility plans to use them. • A description of how the replacement of customer-owned lead service lines will be accomplished in conjunction with distribution system infrastructure replacement projects.
Hea 1519 (cont.) • The estimated savings in costs per service line for the utility replacing the customer owned-portions. • The number of lead mains and lead service lines estimated to be in the utility's system. • An estimated range of how many customer-owned lead service lines will be replaced annually. • An estimated range for total feet of lead mains to be replaced annually.
Hea 1519 (cont.) • The utility's proposal for addressing unusual site restoration work costs. • The utility's proposal concerning whether it or its customers will be responsible for future replacement or repair of the portion of the new service line. • The estimated total cost to replace all customer-owned portions of the lead service lines within or connected to the utility's system with an estimated range of the annual cost.
Hea1519 (cont.) • The water utility's proposal to: • (A) communicate replacement plan information with its customers; and • (B) document the customer's consent or lack of consent to replace the customer-owned portion of the lead service line.
Questions? • Edward Kaufman, CRRA • Indiana Office of Utility Consumer Counselor • 317-232-2777 • ekaufman@oucc.in.gov