PSC Ghassan Korban Commissioner of Public Works Preston D. Cole Director of Operations . of Mllwal ee Department of Public Works Milwaukee Water Works Carrie M. Lewis Superintendent of Water Works January 20, 2016 Sent via ERF System Jeff Stone, Administrator Water, Compliance 8: Consumer Affairs Public Service Commission of Wisconsin 610 North Whitney Way, 2nd Floor lWadBon,VVl53705 Dear Mr. Stone: During 2015, the Milwaukee Water Works (MWW) replaced 15.2 miles of water main in the distribution system, in compliance with the Final Decision and Order of the PSC as part of docket The Decision required between 15 and 20 miles of water main be replaced each year through 2020. As MWW water main replacement miles increase, so do the number of lead services impacted by the construction. Water industry and public health research have shown that disturbance of lead services can cause elevated lead levels at the customer?s tap. In 2015, MWW initiated a pilot to see if these effects were present in the Milwaukee water system. The design of the pilot and review of the results were accomplished with the input of the Milwaukee Health Department, Wisconsin Department of Health Services, Wisconsin Department of Natural Resources, and the US Environmental Protection Agency Region 5. Twenty-one residences were invited, and residents of six properties agreed to participate. They received comprehensive water testing for lead before water main replacement construction commenced, the day after the lead service to the property was connected to the new water main, and again approximately four weeks later. Results were consistent with studies performed by other agencies. At all six residences on the day after the lead service was connected to the new water main, the number of samples in which lead was detected and/or the levels of lead in samples had increased. With this information, the MWW is immediately suspending water main replacement projects that include lead services. Work will proceed on only main replacements that include copper services, while agencies work together to develop a plan to move forward. The 2016 main replacement program included approximately 10 miles of replacements impacting copper services and 5 miles impacting lead services. While additional projects impacting copper services will be assessed, it is highly unlikely that more projects can be designed and bid out in time for construction this year. Therefore, the target to replace 15 miles this year will not be reached. Frank P. Zeidler Municipal Building. 841 N. Broadway, Room 409, Miiwaukee, Wisconsin 53202 Phone (414) 286-2801 - Fax (414) 286?2672 - Member: American Water Works Association, Association of Metropolitan Water Agencies, Water Research Foundation utsuoostM go BOTAIBS ottqna Nd 981L818 Page Two As noted above, the results of the MWW pilot were reviewed with representatives of Milwaukee Health Department, Wisconsin Department of Health Services, Wisconsin Department of Natural Resources, and the US Environmental Protection Agency Region 5. It was the strong and unanimous recommendation of these national experts that removing the entire lead service line is the preferable approach over partial lead service line replacement. This is a matter of statewide public health concern for all utilities that have lead service lines. It also presents issues of how to address lead services lines on private property and financing options to assist homeowners for what can be very costly work. We trust that the Public Service Commission of Wisconsin shares these concerns about how water main replacements with lead services impact public health and supports this proactive suspension of related work while alternatives are explored. Very truly yours, Carrie M. Lewis, Superintendent Ghassan Korban, P.E., Commissioner Milwaukee Water Works Department of Public Works PSC REF#:280732 Ellen Nowak, Chairperson Phil Montgomery, Commissioner Mike Huebsch, Commissioner 610 North Whitney Way P.O. Box 7854 Madison, WI 53707-7854 January 22, 2016 Sent via ERF System Ms. Carrie Lewis, Superintendent Milwaukee Water Works 841 N. Broadway - Room 409 Milwaukee, WI 53202 Re: Application of Milwaukee Water Works, Milwaukee County, Wisconsin, for Authority to Increase Water Rates 3720-WR-108 Dear Ms. Lewis: Thank you for the status update on the main replacement efforts undertaken by Milwaukee Water Works (MWW) in 2015. In your letter you indicated that areas selected by MWW for water main replacement activities in 2016 included five miles of main containing lead services where MWW intended to replace only the main without coordinating replacement of the lead services. The Commission is committed to ensuring that all customers have access to clean, safe drinking water and I am concerned that MWW has apparently not proactively coordinated with its customers and the City of Milwaukee to ensure replacement of the lead services happens during the planned main replacements. As you are likely aware, the need to replace lead services that were primarily installed in the early 1900s is not a new issue in Wisconsin. In fact, over the last 20 years, many communities have implemented lead service replacement programs and coordinated these efforts with planned infrastructure repairs. I strongly encourage MWW to do the same as it continues to replace its aging mains. Considering that it is only January, I am also concerned about MWW’s statement that it will not comply with the Commission’s order requiring it replace 15 miles of main in 2016. MWW’s distribution system consists of more than 1,900 miles of water main, some of which dates back to the 1870s. In both 2013 and 2014, the most recent data that has been filed with the Commission, MWW had the second highest nonrevenue water per mile of main of all Class AB utilities in the state. It also reportedly had a significant number of main breaks which result in costly emergency repairs. Even if 15 miles of main are replaced each year, it still would take more than 125 years for a full system replacement. The need to ensure MWW has safe, reliable mains and other infrastructure to meet the water needs of both Wisconsin businesses and residential customers has long been communicated to MWW by both its wholesale customers and Commission staff. Telephone: (608) 266-5481 Fax: (608) 266-3957 TTY/TextNet: In Wisconsin (800) 251-8345, Elsewhere (608) 267-1479 Home Page: http://psc.wi.gov E-mail: PSCRecordsMail@wisconsin.gov Public Service Commission of Wisconsin RECEIVED: 01/25/16, 11:03:11 AM Public Service Commission of Wisconsin Ms. Carrie Lewis Docket 3720-WR-108 Page 2 Ultimately, the decision of which mains to replace to meet the 15 mile requirement in 2016 must be made by MWW in coordination with its customers and the City of Milwaukee. If MWW is unable to meet this requirement, it should submit a request to the Commission seeking a modification of its order. This request should include a detailed plan for ensuring a sustainable main replacement program consistent with the Commission’s order in its last rate case. Feel free to contact me if I can be of any further assistance in helping MWW address the multiple issues it faces in providing safe, reliable water service. Sincerely, Jeff Stone Administrator Division of Water, Telecommunications & Consumer Affairs JAS:pc DL:01284508