Lesson plan Grade 12 Social Studies & Civics

Governing Lead Pipe Replacement in Halloway: Who Pays and Who Decides

A grade 12 government lesson in which students use a Halloway stakeholder brief to map federal, state, and local roles and judge who pays to replace lead pipes.

Objectives

  1. Students will map how federal, state, and local governments share authority over lead pipe replacement.
  2. Students will evaluate a public policy in terms of its intended and unintended outcomes.
  3. Students will explain why lead service line costs raise questions of fairness.

Vocabulary

Service line
A service line is the small pipe that connects the water main under the street to the plumbing inside one home or building. It is the last leg of the trip water makes to your tap.
Action level
A trigger number in lead and copper testing. If too many homes test above this level, the utility must take steps like improving treatment and telling the public.

Also: primacy, unfunded mandate, revolving fund, principal forgiveness, environmental justice

Teacher overview

Federal rules can require an outcome without paying for it, which forces state and local governments to find the money and manage the politics. This lesson uses the fictional city of Halloway to examine how one federal requirement, the replacement of lead service lines, is carried out through three levels of government. Students map who sets the standard, who funds the work, and who does the digging, then use a stakeholder brief with Halloway's pipe inventory, neighborhood data, funding plan, and stakeholder statements to evaluate whether the policy's design matches its stated goal of protecting children from lead. The Flint water crisis is treated as background for why the rule exists. The only real-world figures students work with are the two federal facts printed in Part A of the handout; every Halloway figure is fictional.

Print the Student Handout (Parts A through E) for every student. Part B, the intergovernmental roles table, is filled in during direct instruction, and the completed version is in the Answer Key.

Procedure

Hook (5 min): Sketch a service line on the board. Draw the water main running under the street, a pipe branching from it toward a house, a valve labeled "curb stop" at the property line, and the pipe continuing across the yard to the meter inside the house. Label the section from the main to the curb stop "utility side" and the section from the curb stop to the house "customer side." Ask a single question: if half the pipe is under public land and half is under a family's yard, who should pay to replace it? Take two or three answers without comment. Students can check the sketch against Part A of the handout.

Direct instruction (15 min): Begin with brief background: in 2014 Flint, Michigan switched its water source to the Flint River without corrosion-control treatment, and testing by residents, Dr. Mona Hanna-Attisha, and Virginia Tech researchers exposed the lead contamination that followed, which helped prompt later revisions to the federal lead rule. Ask students why people outside government, rather than the agencies responsible, were the ones who brought the problem to light. Then explain the federal rule at the center of the lesson, using the two federal facts in Part A of the handout. Under the Lead and Copper Rule Improvements, the lead action level is 15 parts per billion and is set to drop to 10 parts per billion in 2027, and utilities must replace nearly all lead service lines within about a decade. Point out that the action level is a trigger for utility action, not a safe level, since EPA's health-based goal for lead is zero. Then walk students through Part B, the intergovernmental roles table, one row at a time: the federal EPA writes the standard and sends grants to the states; states hold primacy, enforce the rule, and lend money through revolving funds; local utilities like Halloway's inventory their pipes, plan and carry out the replacements, and set water rates. Students fill in the two blank columns as you go. Define primacy, unfunded mandate, and revolving fund as each term comes up.

Group analysis (20 min): In groups of four, students work through the stakeholder brief for the fictional city of Halloway (Parts C and D of the handout). To save time, each member reads one portion closely and reports to the group: the inventory and neighborhood table, the cost and funding table with the state ranking, the three customer-side options, and the stakeholder statements. Each group then completes the T-chart in Part E, listing the policy's intended outcomes and its unintended outcomes in Halloway, with at least one specific piece of evidence from the brief for each entry. Groups then answer the guiding question in Part E: does the rule's reliance on local funding advance or undercut its own goal of protecting children? Their answer must cite at least two figures from the brief and respond to one stakeholder who would disagree with them. Circulate and check that each T-chart has at least two entries on each side before a group moves on to the guiding question.

Share and discuss (10 min): Two groups report their T-charts and their answers to the guiding question. Lead a discussion connecting the unintended outcomes to environmental justice. Nationally, EPA estimates that about 4 million lead service lines remain and notes that lead in drinking water disproportionately affects lower-income communities. In Halloway, Riverside Flats and Mill Hill hold most of the lines that must be replaced, and they have the lowest incomes and the most renters. Ask: if most of the cost is repaid through citywide water rates, who carries the heaviest burden relative to income, and who benefits most from the replacements?

Closure / exit ticket (5 min): Students write one sentence naming an intended and an unintended outcome of the replacement rule in Halloway, and one or two sentences recommending which of the three customer-side options in Part D the city council should adopt, with one reason drawn from the brief. Collect the tickets. A ticket that names both outcomes and supports its option with evidence from the brief shows that the student met the lesson's objectives.

Answer Key

Part B, completed roles table:

Level Who acts What it decides or enforces What it pays for, or how it raises money
Federal EPA, under laws passed by Congress Writes the national standard: the action level, the inventory requirement, and the 10-year replacement deadline Sends grants to the states to build their revolving funds; does not pay for individual replacements directly
State State drinking water agency with primacy; state revolving fund Enforces the federal rule within the state, reviews utility inventories and replacement plans, and ranks loan applications Lends money at below-market interest, forgives part of some loans, and adds state matching money
Local Halloway Water Department and City Council Completes the inventory, plans and carries out replacements, decides who pays for the customer side, and sets water rates Raises money through water rates and revenue bonds, and repays the state loan

T-chart, sample responses: Intended outcomes include lower lead levels in tap water as lead pipes are removed (3,700 lines scheduled, about 370 a year), fewer children exposed to lead (seven schools and child care centers are on lines that must be replaced), and the city's compliance with the tightening action level. Unintended outcomes include higher water bills for every customer (from $48 to $55 a month); a funding plan in which local ratepayers repay $29.3 million of the $33.3 million cost ($8.0 million in loan repayment plus $21.3 million in bonds, with only the $4.0 million in forgiveness paid for by anyone outside Halloway); disputes over the customer side of the line (the $3,800 cost and the need for an owner's permission); and the possibility that renters in Riverside Flats and Mill Hill wait longer if their landlords delay the work or pass the cost into rent. A strong response also notices that the burden falls hardest on the neighborhoods with the most lead lines and the lowest incomes, since the same $7 monthly increase is a larger share of a $36,000 income than of a $94,000 income.

Guiding question: A defensible answer can argue either way, provided it connects local funding to the rule's protective goal and uses the brief. A student arguing that local funding undercuts the goal might note that only $4.0 million of the $33.3 million is not repaid by Halloway ratepayers, that the state could not offer forgiveness to every system that applied (Pierce), and that cost-sharing on the customer side can stall replacements in rental housing (Arroyo, Vu, Okafor). A student arguing that it advances the goal might note that the deadline forces action whatever the funding, that the state ranking rewards systems with many lines to replace and with schools and child care centers on those lines, which helped Halloway rank third of 19, and that local control lets the council choose Option 1 to protect low-income residents. The response to an opposing stakeholder should engage that person's actual argument, for example Sorensen's point that Northfield pays for work done elsewhere, or Bell's point that Riverside Flats families cannot pay the customer-side cost.

Exit ticket: Answers vary. A complete response names one intended outcome (reduced lead exposure, especially at the seven schools and child care centers) and one unintended outcome (higher bills for every customer, or delays where owners refuse or cannot afford the customer side), and recommends one option with a reason from the brief. Option 1 is supported by Arroyo's point about owner permission and by Riverside Flats' $36,000 median income. Option 2 is supported by Sorensen's point about lower bills for neighborhoods with few lead lines. Option 3 is supported by the argument that landlords, not tenants, own the pipe, though Okafor's statement is the main counterargument to it.

Differentiation

Support

Provide the completed roles table from the Answer Key in place of the blank Part B, so students can focus their effort on the intended-versus-unintended analysis rather than on recording which body does what. For the group analysis, point students to the three places in the brief on the fictional city of Halloway that they will use most: the Riverside Flats row of the neighborhood table, the funding table, and the $3,800 customer-side cost.

Extension

Using only Part C of the brief, students evaluate the state's 100-point ranking system. They identify which categories most likely raised Halloway's score of 78, then write a short argument on whether the state should give more of its 100 points to disadvantaged-community status, even if that means fewer points for the number of lead lines, and whether it was wise to spread forgiveness across six systems rather than concentrate it. As a second step, they explain how the funding table would change under Option 2, in which owners rather than ratepayers pay the customer side of each line.

ELL supports

Pre-teach "service line," "curb stop," "action level," "mandate," "revolving fund," and "forgiveness" (of a loan) with the board sketch from the hook and short definitions. Allow students to complete the T-chart with phrases rather than full sentences, and provide sentence frames for the exit ticket: "One intended outcome is ___ because the brief shows ___. The council should choose Option ___ because ___."