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
- Students will map how federal, state, and local governments share authority over lead pipe replacement.
- Students will evaluate a public policy in terms of its intended and unintended outcomes.
- 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.
Student Handout
Part A: The two federal facts and how a service line is divided
Federal fact 1. Under the federal Lead and Copper Rule Improvements (final October 2024), the lead action level is 15 parts per billion (ppb), and it drops to 10 ppb in 2027. Water systems must replace nearly all lead service lines within 10 years. The action level is the point at which a utility must take further steps; it is not a safe level. EPA's health-based goal for lead in drinking water is zero.
Federal fact 2. EPA estimates that about 4 million lead service lines remain in US water systems (November 2025). EPA notes that lead in drinking water disproportionately affects lower-income communities.
How a service line is divided in Halloway. A service line is the pipe that carries water from the water main under the street into a building. In Halloway, the utility owns the section from the main to the curb stop, a shutoff valve near the property line. The property owner owns the section from the curb stop to the house. The federal rule requires the whole line to be replaced, because replacing only one section leaves lead pipe in place and can loosen lead particles into the water for a time afterward. The rule does not say who has to pay for the section on private property, and the utility needs the owner's permission to work there.
Part B: Intergovernmental roles
Fill in the two blank columns as your teacher explains each level of government.
| Level | Who acts | What it decides or enforces | What it pays for, or how it raises money |
|---|---|---|---|
| Federal | US Environmental Protection Agency (EPA), under laws passed by Congress | ||
| State | The state drinking water agency, which holds primacy, and the state revolving fund | ||
| Local | Halloway Water Department and the Halloway City Council |
Part C: Stakeholder brief for the fictional city of Halloway
Halloway is a fictional city of about 62,000 people. Its water system is owned by the city and run by the Halloway Water Department. The city council approves the department's budget and sets water rates; no state agency has to approve those rates. In 2025 the department completed the service line inventory the federal rule requires.
Inventory results. Halloway has 21,400 service connections. Of these, 3,200 are lead and 500 are galvanized steel lines that must be replaced under the rule, for a total of 3,700 lines that must be replaced. Another 1,200 lines are of unknown material and must be dug up or tested to find out whether they are lead. Spread over the 10-year deadline, replacing the 3,700 known lines means about 370 replacements a year.
Where the lines are.
| Neighborhood | Service connections | Lines that must be replaced (lead or galvanized) | Lines of unknown material | Median household income | Homes that are rented | Schools and child care centers on a line that must be replaced |
|---|---|---|---|---|---|---|
| Riverside Flats (built mostly before 1930) | 3,800 | 1,500 | 500 | $36,000 | 64% | 4 |
| Mill Hill (built mostly 1920-1950) | 3,400 | 1,150 | 400 | $45,000 | 48% | 2 |
| Eastgate (built mostly 1950-1975) | 5,200 | 850 | 250 | $68,000 | 35% | 1 |
| Northfield and newer areas (built after 1975) | 9,000 | 200 | 50 | $94,000 | 22% | 0 |
| Citywide | 21,400 | 3,700 | 1,200 | $58,000 | 37% | 7 |
What it will cost. The department estimates that a full replacement averages $9,000 per line: about $5,200 for the utility side and $3,800 for the customer side. Replacing all 3,700 known lines would cost about $33.3 million. This estimate assumes the utility pays for both sides of every line (Option 1 in Part D). It does not include the 1,200 lines of unknown material, some of which will turn out to be lead.
How the department plans to pay.
| Source | Amount | Who repays it |
|---|---|---|
| State revolving fund loan, forgiven portion (principal forgiveness) | $4.0 million | No one; Halloway does not repay this part |
| State revolving fund loan, repaid portion (20 years, below-market interest) | $8.0 million | Halloway water customers, through rates |
| City revenue bonds | $21.3 million | Halloway water customers, through rates |
| Total | $33.3 million |
The state revolving fund is built from federal grants and state matching money, and loan repayments flow back into the fund so it can lend again. The state decides which systems receive loans and how much of each loan is forgiven. It ranks applications on a 100-point scale: up to 40 points for the number of lead and galvanized lines a system must replace, up to 30 points if the community meets the state's definition of a disadvantaged community (based on citywide median household income), up to 20 points for schools and child care centers served by those lines, and up to 10 points for a project that is ready to begin. Halloway scored 78 points and ranked third of 19 applicants this year. The state had enough forgiveness money to offer some to its top six applicants, and it chose to spread that money across all six rather than give most of it to one system.
To repay the loan and the bonds, the department has proposed raising the average residential water bill from $48 a month to $55 a month over three years. The rate is the same in every neighborhood.
Part D: The council's decision on the customer side
The council must choose how to handle the $3,800 customer-side cost of each line.
Option 1: The utility pays for the whole line. Owners pay nothing directly. The full $33.3 million is covered as shown in the funding table, so every customer in the city shares the cost through rates.
Option 2: Owners pay for the customer side. The utility pays for its side. Owners pay about $3,800, which they may spread over 10 years as a charge on their water bill. Owner-occupants below a set income can apply to a city grant fund for help. Bills for all customers rise less than under Option 1.
Option 3: The utility pays for owner-occupied homes only. Owners who live in their homes pay nothing directly. Landlords pay the customer-side cost for rental properties, with the same 10-year payment plan as Option 2.
Statements from stakeholders
Denise Arroyo, director, Halloway Water Department: "We can meet the 10-year deadline, but we have to start now and keep a steady pace. If owners refuse to let us onto their property, we cannot finish the job, and the most reliable way to get their permission is to make the work free to the owner."
Marcus Bell, city council member, Ward 1 (Riverside Flats): "About 40 percent of the lines that must be replaced are in my ward, and so are four of the seven schools and child care centers. My residents did not choose these pipes. A family earning $36,000 cannot write a $3,800 check."
Linda Sorensen, city council member, Ward 4 (Northfield): "Northfield has very few lead lines, but under Option 1 my residents pay the same rate increase as everyone else for work that happens almost entirely in other neighborhoods. Washington set this deadline, so Washington should pay for more of it."
Ray Okafor, Halloway Property Owners Association: "Most of the older rental buildings in Riverside Flats are owned by small landlords with one or two properties. Under Option 3, many will raise rents to cover the cost, and the tenants will end up paying anyway."
Teresa Vu, parent and tenant, Mill Hill: "I rent, so I cannot approve the work on my building's line. My landlord has to. I have a two-year-old, and I want to know which option gets the lead pipe out of my building fastest."
Alan Pierce, manager, state drinking water revolving fund: "We had far more requests this year than we had money. Halloway scored well, but forgiveness money is limited, and every dollar we forgive is a dollar that does not come back to the fund to lend next year."
Part E: Analysis
T-chart. List at least two intended outcomes and at least two unintended outcomes of the federal replacement rule in Halloway. Next to each entry, cite one piece of evidence from Parts A through D.
| Intended outcomes (with evidence) | Unintended outcomes (with evidence) |
|---|---|
Guiding question. Does the rule's reliance on local funding advance or undercut its own goal of protecting children from lead? Answer in a paragraph that cites at least two figures from the brief and responds to one stakeholder who would disagree with you.
From Water for Schools (waterforschools.org). This material is in the public domain (CC0) and may be copied, edited, and shared freely.
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 ___."