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Greeley staff outline expanded lead service-line inventory and replacement program funded by state loan and forgiveness

Greeley Water and Sewer Board of Trustees · November 19, 2025
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Summary

Staff engineer David Cummings outlined a phased lead service-line inspection and replacement program to meet upcoming Lead and Copper Rule improvements. The city plans an accelerated, mostly grant- and loan-funded effort to inventory service lines, replace identified lead/GRR lines ahead of rule deadlines, and distribute precautionary filters where lines remain in service until replaced.

Greeley Water and Sewer staff presented an update on the city’s lead service-line inventory and replacement program on Nov. 19, describing a phased approach to identify and remove lead and galvanized-requiring-replacement (GRR) service lines in advance of forthcoming Lead and Copper Rule improvements.

David Cummings, staff engineer and project manager for the program, said the 2021 Lead and Copper Rule revision and subsequent rulemaking require public inventories and replacement plans. Greeley’s program uses a phased approach: an exploratory scoping phase (phase 1), larger inventories and potholing in subsequent phases, and broader geographic coverage in phase 5 tied to state funding. Cummings reported progress through phase 3 and into phase 4 inspections: roughly 220 service-line replacements completed, nearly 1,000 potholes or visual inspections in earlier phases and over 1,700 verifications underway in phase 4.

Funding and timeline: city staff secured a Drinking Water State Revolving Fund loan package that included low interest and a $10,000,000 forgivable principal component; the transcript references approximately $17.57M allocated to the inspection and replacement project and additional funds set aside for a reservoir project. Cummings said the program aims to use funds efficiently and does not anticipate needing the full loan amount for replacement work.

Operational notes and outreach: both public and private service lines must be addressed; private-property inspections require owner consent and staff rely on door-to-door outreach, mailers and emails to reach owners and tenants. Where a lead line is identified and replacement is pending, the city distributes precautionary filters to affected households, prioritizing tenant health. Cummings noted challenges gaining access to some properties and that, per city ordinance, fees or billing consequences could be applied if required replacements are not completed after deadlines.

The board discussed coordination with building-permits records to avoid redundant potholing where work has already been inspected and confirmed. Cummings confirmed access to building department records and said the project team will use those records and photographic evidence to reduce unnecessary inspections.

Next steps: staff will continue phased inspections and replacements, pursue efficient use of state funds, and return periodic reports to the board.