Lead water pipes

mr j garlits made this Environmental Information Regulations request to United Utilities Water PLC
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The request was successful.

Dear United Utilities Water PLC,

Regarding your lead and common supply pipe replacement scheme. You say "If your supply pipe is made of lead, we would advise you to consider replacing it. If you apply to replace your lead supply pipe under our scheme, we’ll replace the lead pipes that we own free of charge."

1. As it is a matter of human health, why have you not already replaced the lead pipes that you own?
2. Do you hold details of where there are lead pipes in your ownership that you haven't replaced?
3. How is the lead and common supply pipe replacement scheme funded?
4. How many common supply pipes (for clarity, I mean a single pipe from your main that goes on to serve more than one property) did you replace under this scheme in the year 2016, or the financial year 2015-2016 so far, please?

Yours faithfully,

mr j garlits

Jain, Rajat, United Utilities Water PLC

PLEASE QUOTE THE LEGAL SUBJECT HEADER
REFERENCE IN ALL COMMUNICATIONS
 
 
Dear Mr Garlits
 
Re: Your request for information
 
We refer to your request for information submitted via the whatdotheyknow
website.
 
We have considered this in accordance with our obligations under the
Environmental Information Regulations 2004 (EIR)
 
Please note our response each of your questions below:
 
 
1.As it is a matter of human health, why have you not already replaced the
lead pipes that you own?
 
Although technically we are not obliged to provide opinion under EIR, we
consider that it may be helpful to you to know the following:
 
Water companies are required to achieve compliance with the regulatory
standard for lead in water supplies of 10ug/l.
 
There is no lead in water as it leaves our water mains and almost all lead
occurs due to contact with lead pipes. Only the part of the lead supply
pipe between the water main and the property boundary is the
responsibility of the water company, the remainder including any internal
plumbing is the responsibility of the owner.
 
The contribution that this section of pipe in water company ownership
makes to overall lead concentrations is limited. United Utilities has
carried out both targeted and opportunistic lead pipe replacement in a
number of areas and has reviewed the efficacy of these strategies. Lead
pipe replacement is not only expensive but can be disruptive to residents.
 
The [1]DWI guidance states “Results from lead communication pipe
replacement trials completed in previous AMPs indicate that strategic
replacement of lead communication pipes by water companies does not
achieve significant benefits (in terms of both compliance with the 10ug/l
standard and reduced exposure to lead) unless the consumer replaces lead
pipes serving the property at the same time.”
 
Therefore in order to achieve compliance with the 10ug/l standard for
lead, and to reduce overall exposure to lead for consumers, the most
effective strategy is a multi-faceted approach.
 
We condition the water to reduce plumbosolvency, including optimising pH,
reducing colour and adding phosphate to water supplies which helps to
build up a protective laying inside lead pipes both on UU side and the
customers side within the property. This has significantly reduced lead
exposure. When we take a sample that fails the standard for lead we will
replace the lead pipe to that property. Where a customer replaces their
lead pipe we will replace our side and reconnect it without charge.
 
 
2. Do you hold details of where there are lead pipes in your ownership
that you haven't replaced?
 
Unfortunately, these is no legal obligation to record the type of material
the pipes are made of when they were laid, which, to the extent that any
exist, would have been when they were under local authority control prior
to 1974. The issue is further complicated by virtue of the fact that where
there are any historic lead pipes, this would very much depend upon the
types of records historically kept by the councils from whom we inherited
these. 
 
When pipes are serviced/maintained there may be the occasional record of
what they are made of eg polyethylene. However these records may be
sporadic in that we don’t always record the material the pipes are made of
when carrying out servicing/maintenance of them, and would not in any
event reflect ownership nor whether they have been replaced. We would
suggest that to attempt to provide you with this information would involve
having to search through all of our service records for our entire network
(which includes the whole of the North West region) would be manifestly
unreasonable under EIR regulation 12(5)(b). Furthermore, we consider it
would be contrary to the public interest to place us under this burden,
when those resources could be better applied towards providing a better
service to you. This is in particular when weighed against the benefit of
receiving this information.
 
However we may be prepared to consider searching form repair/maintenance
records if for example you are able to significantly narrow the scope of
your request to a small geographical area and for a narrow time frame.
However, as there is no legal obligation to hold a register of this
information, and what we hold very much depends on whether a record was
noted, it at all. So even if we were able to provide you with this
information, it is not likely to be accurate in any event. Furthermore,
for older pipes which may or may not have been historically serviced/
maintained, there is unlikely to be a centralised electronic database on
this (merely because they may have been stored in documents). Once again
this wouldn’t indicate when and if those pipes had been replaced.
 
 
3. How is the lead and common supply pipe replacement scheme funded?
 
The scheme is funded in the same way as other services we provide to our
customers are. This is through the revenue we collect from customers when
they pay their water bills, reinvested into improving the network
 
 
4. How many common supply pipes (for clarity, I mean a single pipe from
your main that goes on to serve more than one property) did you replace
under this scheme in the year 2016, or the financial year 2015-2016 so
far, please?
 
We don’t hold a specific record of the actual number of common supply
pipes replaced, only the number of properties benefitting from those works
orders. We can however advise that for the year 2016, 1507 properties
benefitted from common supply pipe replacements, and of those 197 are
known to be lead
 
We hope that this now meets with your request. However, should you
consider that that we have not adequately complied with our obligations
under EIR, you have the right to ask us to carry out an internal review,
by writing to David Hannon Head of Legal, United Utilities, Legal
Department, Grasmere House First Floor, Lingley Mere Business Park,
Lingley Green Avenue, Great Sankey, Warrington, WA5 3LP. Alternatively,
you may find it easier to e-mail us directly on [2][United Utilities request email]
and your review request will be forwarded on to Mr Hannon.
 
Your request for review should explain why you wish a review to be carried
out, and should be made within 40 working days of receipt of this letter,
and we will reply within 40 working days of receipt. If you are not
satisfied with the result of the review, you then have the right to make a
formal complaint to the Information Commissioner.
 
Finally, kindly acknowledge receipt by return of e-mail.
 
Yours sincerely
 
 
Rajat Jain
Data Protection & Fraud
Legal Department
United Utilities 
unitedutilities.com
 
 
 

show quoted sections

Jain, Rajat, United Utilities Water PLC

PLEASE QUOTE THE LEGAL SUBJECT HEADER
REFERENCE IN ALL COMMUNICATIONS
 
Dear Mr Garlits
 
Further to my earlier e-mail moments ago, by way of correction to my
typing error to Question 2, please note that we should have referred to
EIR Regulation 12(4)(b) and not 12(5)(b) as stated.
 
Yours sincerely
 
 
Rajat Jain
Data Protection & Fraud
Legal Department
United Utilities 
unitedutilities.com
 
 
_____________________________________________
From: Jain, Rajat
Sent: 14 February 2017 17:14
To: '[FOI #381971 email]'
<[FOI #381971 email]>
Subject: RE: Environmental Information Regulations request - Lead water
pipes Legal/EIR/2017/01/ID243- Mr J Garlits (WHO08.28)
 
 
PLEASE QUOTE THE LEGAL SUBJECT HEADER
REFERENCE IN ALL COMMUNICATIONS
 
 
Dear Mr Garlits
 
Re: Your request for information
 
We refer to your request for information submitted via the whatdotheyknow
website.
 
We have considered this in accordance with our obligations under the
Environmental Information Regulations 2004 (EIR)
 
Please note our response each of your questions below:
 
 
1.As it is a matter of human health, why have you not already replaced the
lead pipes that you own?
 
Although technically we are not obliged to provide opinion under EIR, we
consider that it may be helpful to you to know the following:
 
Water companies are required to achieve compliance with the regulatory
standard for lead in water supplies of 10ug/l.
 
There is no lead in water as it leaves our water mains and almost all lead
occurs due to contact with lead pipes. Only the part of the lead supply
pipe between the water main and the property boundary is the
responsibility of the water company, the remainder including any internal
plumbing is the responsibility of the owner.
 
The contribution that this section of pipe in water company ownership
makes to overall lead concentrations is limited. United Utilities has
carried out both targeted and opportunistic lead pipe replacement in a
number of areas and has reviewed the efficacy of these strategies. Lead
pipe replacement is not only expensive but can be disruptive to residents.
 
The [1]DWI guidance states “Results from lead communication pipe
replacement trials completed in previous AMPs indicate that strategic
replacement of lead communication pipes by water companies does not
achieve significant benefits (in terms of both compliance with the 10ug/l
standard and reduced exposure to lead) unless the consumer replaces lead
pipes serving the property at the same time.”
 
Therefore in order to achieve compliance with the 10ug/l standard for
lead, and to reduce overall exposure to lead for consumers, the most
effective strategy is a multi-faceted approach.
 
We condition the water to reduce plumbosolvency, including optimising pH,
reducing colour and adding phosphate to water supplies which helps to
build up a protective laying inside lead pipes both on UU side and the
customers side within the property. This has significantly reduced lead
exposure. When we take a sample that fails the standard for lead we will
replace the lead pipe to that property. Where a customer replaces their
lead pipe we will replace our side and reconnect it without charge.
 
 
2. Do you hold details of where there are lead pipes in your ownership
that you haven't replaced?
 
Unfortunately, these is no legal obligation to record the type of material
the pipes are made of when they were laid, which, to the extent that any
exist, would have been when they were under local authority control prior
to 1974. The issue is further complicated by virtue of the fact that where
there are any historic lead pipes, this would very much depend upon the
types of records historically kept by the councils from whom we inherited
these. 
 
When pipes are serviced/maintained there may be the occasional record of
what they are made of eg polyethylene. However these records may be
sporadic in that we don’t always record the material the pipes are made of
when carrying out servicing/maintenance of them, and would not in any
event reflect ownership nor whether they have been replaced. We would
suggest that to attempt to provide you with this information would involve
having to search through all of our service records for our entire network
(which includes the whole of the North West region) would be manifestly
unreasonable under EIR regulation 12(5)(b). Furthermore, we consider it
would be contrary to the public interest to place us under this burden,
when those resources could be better applied towards providing a better
service to you. This is in particular when weighed against the benefit of
receiving this information.
 
However we may be prepared to consider searching form repair/maintenance
records if for example you are able to significantly narrow the scope of
your request to a small geographical area and for a narrow time frame.
However, as there is no legal obligation to hold a register of this
information, and what we hold very much depends on whether a record was
noted, it at all. So even if we were able to provide you with this
information, it is not likely to be accurate in any event. Furthermore,
for older pipes which may or may not have been historically serviced/
maintained, there is unlikely to be a centralised electronic database on
this (merely because they may have been stored in documents). Once again
this wouldn’t indicate when and if those pipes had been replaced.
 
 
3. How is the lead and common supply pipe replacement scheme funded?
 
The scheme is funded in the same way as other services we provide to our
customers are. This is through the revenue we collect from customers when
they pay their water bills, reinvested into improving the network
 
 
4. How many common supply pipes (for clarity, I mean a single pipe from
your main that goes on to serve more than one property) did you replace
under this scheme in the year 2016, or the financial year 2015-2016 so
far, please?
 
We don’t hold a specific record of the actual number of common supply
pipes replaced, only the number of properties benefitting from those works
orders. We can however advise that for the year 2016, 1507 properties
benefitted from common supply pipe replacements, and of those 197 are
known to be lead
 
We hope that this now meets with your request. However, should you
consider that that we have not adequately complied with our obligations
under EIR, you have the right to ask us to carry out an internal review,
by writing to David Hannon Head of Legal, United Utilities, Legal
Department, Grasmere House First Floor, Lingley Mere Business Park,
Lingley Green Avenue, Great Sankey, Warrington, WA5 3LP. Alternatively,
you may find it easier to e-mail us directly on [2][United Utilities request email]
and your review request will be forwarded on to Mr Hannon.
 
Your request for review should explain why you wish a review to be carried
out, and should be made within 40 working days of receipt of this letter,
and we will reply within 40 working days of receipt. If you are not
satisfied with the result of the review, you then have the right to make a
formal complaint to the Information Commissioner.
 
Finally, kindly acknowledge receipt by return of e-mail.
 
Yours sincerely
 
 
Rajat Jain
Data Protection & Fraud
Legal Department
United Utilities 
unitedutilities.com
 
 
 

show quoted sections