Could There Be Irony in Lead in Drinking Water?

For many years, scientists have warned of the danger that lead in drinking water poses to young children, as even low level exposure can raise the likelihood of behavior and learning problems, slowed growth, and other serious health ailments. Infants may face highest levels of exposure, as formula mixed with tap water can account for up to 60% of their total lead-related risk. With an estimated 400,000 children attending day care in New Jersey, the state’s 4,000 licensed child care facilities (CCFs) pose a particular concern. So, when the State of New Jersey appropriated funding in 2021 to help CCFs recover from the pandemic, it seemed to be a golden opportunity to finally address the problem of lead exposure in children. Ironically, that logic may prove to be wrong.

Supported by a total of $59 million in federal American Rescue Plan (ARP) funds ($54.5 million) and a Fiscal Year 2022 State Budget appropriation ($4.5 million), the NJ Economic Development Authority (EDA) organized a Child Care Facilities Improvement Program (CCFIP) in July 2021 to pilot full cost grants for facility improvements that will help ensure the future viability of this critical industry. Phase 1, which may absorb nearly half (i.e., $25 million) of the funds, launched on November 15, 2022, when EDA began accepting applications from licensed CCFs. (Registered family child care providers are not eligible for Phase 1 but will be in the future.)

 Key program features include:

• Grants ranging from $50,000 to $200,000 per applicant (of which up to 20% may be used for “soft costs,” such as environmental assessments).
• Funding set aside for providers operating in overburdened communities (e.g., state-established Opportunity Zones) and currently serving at least one low-income child receiving Child Care Assistance subsidies.
• The applicant may be a nonprofit organization, may operate in owned or leased space, must be in good standing with federal and state regulatory agencies, and must enroll in Grow NJ Kids (NJ’s Quality Rating and Improvement System) within one year of executing a grant agreement.
• The list of eligible interior and exterior facility improvements is extensive, including classroom space, windows, plumbing/electrical, windows, roofing, and playground equipment. While the cost of remediating environmental issues (e.g., lead in drinking water, lead paint, and asbestos) is also eligible, those needs are fairly unique within this construction-oriented list.

Since physical improvements sharpen competitiveness, they are likely to be very attractive to CCFs, many of which operate on a small profit margin and could not otherwise pursue such work.  However, when combined with EDA’s plan to issue grants on a “first come, first served” basis, the CCFIP program is unlikely to have sufficient funds to significantly reduce the backlog of known environmental problems. 

For the first time in state history, a full view of the extent of lead in drinking water exposure in CCFs will be available in 2024, when the Department of Children and Families (DCF) expects to unveil a statewide database reflecting comprehensive testing results. If the experience of other states is instructive, lead exceedances will be particularly significant in CCFs within disadvantaged communities, where older housing stock heavily laden with lead plumbing and paint predominantly serve communities of color. With a significant portion of state-regulated CCFs serving urban communities (e.g., Jersey City: 174 facilities or 4% of the statewide total), the potential risk is not evenly distributed across the state.

Though EDA wisely provides CCFs with considerable flexibility in defining their most important needs, environmental/health concerns should not be left to chance.  Ironically, state assistance may succeed in providing children with modernized facilities without addressing the long-standing health issues that imperil their future.  

Several potential solutions could be applied:

• All grants should include funding to remediate existing environmental issues.
• As part of Phase 2 of the program, either of the proposals below would accelerate the removal of lead sources in CCFs:
  • Set aside a portion of the $59 million to address environmental/health issues. (As a point of reference, if DCF testing confirms significant lead in one-third (1,335) of state-regulated CCFs, approximately $6 million would be required just to replace lead service lines (average cost of $4,000) and/or indoor lead plumbing ($300)).
  • Legislatively dedicate an additional amount from the federal funds that New Jersey has yet to allocate from the American Rescue Plan program (approximately $1 billion in the fall of 2022) to address environmental/health problems in state-regulated CCFs, with special priority on overburdened communities.

We have a rare opportunity to improve early childhood learning while permanently removing a threat to the health of young children. With a few tweaks, we can avoid the irony of coming up short.

For more information, see the online report issued in November 2021 by Jersey Water Works, “Lead in Drinking Water in Child Care Facilities: Ensuring the Future for New Jersey’s Children.”