Department of Utilities
Reference: An Ordinance Amending Article 13 of the Brighton Municipal Code for Inspection of Water Service Lines
To: Mayor Gregory Mills and Members of City Council
Through: Michael P. Martinez - City Manager
Prepared By: Scott Olsen - Director of Utilities
Date Prepared: November 11, 2024
PURPOSE
Requesting City Council approval of an ordinance to allow the City of Brighton to investigate service line materials on customer-owned lines. This ordinance will ensure the required number of lines are investigated in an efficient and cost-effective manner. The City does not believe there are lead service lines but must prove we do not have lead lines. State regulators have approved using a statistically random subset of the inventory to visually inspect service lines. The City is required to visually inspect the service lines of at least 317 addresses. Responses to the initial notifications has been very low, approximately 0.1%. Plus, experience gained from other utilities indicates customers have not engaged to the level required for this work to proceed. If this ordinance is passed, the City will have the ability to do the required investigation efficiently. Customers will be notified of the work and the area of the pothole will be returned to original condition.
BACKGROUND / DISCUSSION
This item was originally presented to City Council at the December 10, 2024, Study Session.
On December 16, 2021, EPA finalized the Lead and Copper Rule Revisions (LCRR), which further strengthens the protections against lead in drinking water. The Colorado Department of Public Health and Environment subsequently adopted the rule into Regulation 11: Colorado Primary Drinking Water Regulations.
The LCRR contains several new requirements for water systems. One of the key changes is a requirement to develop a system-wide lead service line inventory of water service lines both on the customer side (owner side) and the City side (utility side).
Lead is a natural element that has been used in a variety of industries and poses significant health concerns. Lead was once used as a material in plumbing products but has long since been banned. Lead is not found in our drinking water after treatment at the Brighton water treatment facility. Risk of lead exposure comes from old plumbing, where lead in pipes, solder, fittings or fixtures may get into the drinking water under certain conditions. Currently, the inventory does not include any lead service lines. However, the service line materials on older homes must be characterized. The CPDHE has decided that there is likely no lead in service lines installed after 1959, so the focus will be homes 1959 and older and these are called “unknowns” until the inventory is complete.
The service line is the line from the water main to the home. The City owns the portion of the line up to, and including, the meter and the customer owns the portion from the meter (or curb stop in some cases) to their home. Both sides must be investigated. Since the customer owns their side, they must participate in the process.
The inventory currently shows about 1,712 unknown service lines in the city. On October 16, 2024, in conjunction with the report to CPDHE, Brighton posted an online map of our inventory. In addition, the owners and occupants of these homes or businesses were notified by November 15, 2024, that their line is unknown status. In this notification, we asked customers to help by giving permission to investigate their line.
In 2025, a project to pothole a statistical representative subset of properties to show there is no lead in the system will be started. Potholing involves using water to excavate a small hole over the service line to determine the material. This process will need to be completed on both sides of the line for at least 317 properties.
STAFF RECOMMENDATION
Staff recommend approval of the ordinance, as drafted, to allow the City of Brighton to investigate service line materials on customer-owned lines and to protect public health.
ATTACHMENT
● Ordinance
● PowerPoint Presentation