Lead Water Crisis: Comparative Essay Bloomfield VS Newark East Ward

by Tamalie Ranatunga

Site Description:

The levels of lead in Newark New Jersey’s drinking water are some of the highest recently recorded by a water system in the United States- placing affected residents in unknown health risk and additional financial demand. This crisis stems from the 2012 municipal action to change the water treatment of Pequannock Water Treatment Plant, which is one of two water distribution plants for Newark. I am following the daily lives of Newark Residents in South Ward and Branch Brook because I want to know how affluence effects resident’s management of contaminated drinking water in order to help my reader understand the injustice done to residents of lower economical means.  

Author Biography:

Hi my name is Tamalie Ranatunga and I am a student at NJIT studying architecture. Newark has been my place of residence during my five years in college – its history, culture and resilience brought continuous inspiration to my practice in architecture. The Lead Water Crisis has created hardship for affected residents and added strain to the already strained relationship between the community and its municipality. I am interested in articulating how this crisis has affected residents in different locations in Newark. 

Final Report:

Imagine not being able to trust your water. Safe water is a basic right to residents in America. We drink it, cook with it, clean with it, bath in it, ect.

After his contaminated water service line was changed, Leonard Thomas tested his water and found that it still contained lead particles, 130 parts per billion. His water wasn’t safe. Leonard Thomas is a Newark East Ward Resident and a long time water advocate in Newark. He is a part of the Newark Water Group and the Newark Water Coalition both fighting to keep Newark’s water safe and in the publics hands. To get his water to a safe level, measuring 0 particles per billion, Leonard has to go through the process of running his faucet for 5 minutes and then using a lead specific filter. Because of his work with the Newark Water Group and Newark Water Coalition, Leonard Thomas is thoroughly knowledgeable about water safety and is able to ensure that his drinking water is safe. However, he worries about his fellow residents, who haven’t had the experiences and information to ensure that their drinking water is safe. “People think changing your pipes is enough. We can’t make that assumption”, Leonard Thomas.[1]

Interview with Newark Resident and volunteer at Newark Water Coalition & Newark Water Group- Leonard Thomas. He speaks about his experience being effected by lead water and his experience as a volunteer.


The Newark, New Jersey Water Crisis officially began in 2017, after a water study by the United States Environmental Protection Agency, The Lead and Copper Rule Compliance Study, confirmed that Newark’s water lead levels exceeded the limit set by the Safe Drinking Water Act:15 parts per billion. Lead is a toxicant that affects multiple body systems and is particularly harmful to young children. There is no known ‘safe’ blood lead concentration. Blood lead concentrations as low as .05 parts per million, are associated with decreased intelligence in children, behavioral difficulties and learning problems- severity of symptoms increase as exposure increases.[2]

The 2017 Lead and Copper Rule Compliance Study tested water samples from Newark, which is serviced by two water treatment plants: Pequannock Water Treatment Plant and Wanaque Water Treatment Plant. Both Pequannock and Wanaque Water Treatment Plant samples contain lead contaminants; however, lead concentrations were higher in the samples from the Pequannock Water Treatment Plant.[3] These water treatment plants do not only serve Newark. Bloomfield, a separate township in New Jersey, also receives its water from the Pequannock Water Treatment Plant. Although Bloomfield and Newark were both affected by the Lead Water Crisis, the information and aid residents received from their local governments was different. This paper will investigate what differs between the two municipalities and how these differences contributed to varied aid and information received by residents. Through this analysis this paper argues: demographics and affluence of Newark and Bloomfield contributed to -Bloomfield’s municipality reacting more transparently and inclusively than Newark’s Municipality to the Lead Water Crisis.

This paper will briefly cover the timeline that led to the Lead Water Crisis in order for the reader to understand who is responsible for maintaining the public’s water and the public’s awareness of their water quality. Compared to Bloomfield, Newark has a much larger population and its local government received much more pressure from the media and residents. So the paper will specifically focus on Newark’s East Ward in comparison to Bloomfield. The two locations will be compared by population, affluence, demographics and water history. The two municipalities’ aid and dialogue with its residents will then be analyzed. Throughout the study, Leonard Thomas’ testimony as an activist and Newark East Ward resident provides a broadened perspective about how the crisis has affected residents day to day.    

The Newark Water Crisis

“Corrosion control” is the source of the Lead Water Crisis and main reason for the lead level spikes in 2017.[4] Lead from old pipes that connect water mains to homes starting leaking into the water. Water treatment plants are responsible for preventing these types of leaks; but the Pequannock Water Treatment Plant’s water treatment, which was approved by the state in 1997, had failed.[4] Since 1997, decision-makers at every level, from the water treatment plant operator to state oversight officials, have failed to heed obvious warning signs. Additionally, from 2008-2013, the agency that managed Newark’s water treatment was part of a multimillion-dollar kickback scheme.[5]  Andrew Papachen, who was not a part of the kickback scheme, was the controlling plant operator, working with Newark’s water since 1974. He was not a capable controlling plant operator: “left cringe-worthy conditions. Drain valves constantly leaked. Thick crusts coated water filters that were clogged with mud-balls”.[5] Andrew Papachen went as far as dropping benchmarks for how many pathogens the plant needed to kill without asking the state; and not even meeting those self-imposed benchmarks. The Pequannock water treatment plant did rack up violations for not following rules. However the city officials say “they still don’t know what happened”.[5] Officials in Newark and at the state made decisions that didn’t prioritize people’s health because of their lack of oversight at the Pequannock water treatment plant.[5] “All those results are going to everybody, they’re reviewing it, but nobody sees an issue,” said Kareem Adeem, acting director of Newark’s water and sewer department, which oversees the plant”.[5] After years of neglect and mismanagement by all levels of decision-makers, in 2017 the New Jersey Department of Environmental Protection mandated cities and towns to test the water supply twice a year. The City of Newark then states that it was in violation of the Environmental Protection Agency’s limit of lead levels in the drinking water.

It has been identified that the Pequannock Water Treatment Plant’s failed corrosion control treatment is the reason for lead from old pipes leaking and contaminating the water. The Pequannock Water Treatment Plant serves Pequannock Township, Bloomfield, Belleville, Nutley and parts of every ward in Newark except the East Ward. Newark’s other water treatment plant, the Wanaque Water Treatment Plant, services the East Ward and parts of the North, Central and South wards. While there has been no problem with the corrosion control treatment at the Wanaque Water Treatment Plant, the gates separating the two treatment plants in Newark had been left open in the past. By having the gates open, corrosion from the Pequannock Water Treatment Plant could easily blend with water from the Wanaque Water Treatment Plant causing lead pipes that service the Wanaque Water Treatment Plant to also corrode. Newark homes served by the Wanaque Water Treatment Plant have tested to have high lead levels. Leonard Thomas, resident of Newark’s East Ward, measured 150 parts per billion in his water.[5] Also, the 2017 Lead and Copper Rule Compliance Study found samples sourced from the Wanaque Water Treatment Plant contain lead contaminants.

Bloomfield, a township in New Jersey is 5.30 square miles with a population of 49,973 people.[6] Newark, a city in New Jersey, is 24.19 square miles with a population of 282,011 people.[7] Newark’s East Ward specifically is .113 square miles with a population of 2,406   people.[7] Newark is around 5 times larger than Bloomfield in size and population. Newark’s East Ward makes up 2% of Newark’s size and .8% of its population.

In terms of demographics, in Bloomfield’s population: 41.1% are White alone (not Hispanic or Latino),  20.1% are Black/African American alone, 8.8% are Asain only and 29.4% are Hispanic/Latino.[6] Additionally, in the town only 3.2% identified as “Two or More Races”.[6]  In Newark’s population: 11.0% are White alone (not Hispanic or Latino),  50.1% are Black/African American alone, 1.9% are Asain only and 36.3% are Hispanic/Latino.[7] Bloomfield is predominantly white town but could be seen as somewhat distributed in its diversity. Newark is less distributed in its diversity; its population is made up predominantly of Black/African American and Hispanic/Latino people. In Newark, the East Ward’s population: 63.01% is White only,  1.91% is Black/African America,  and 61.39% is Hispanic/Latino. So the majority of Newark’s white and Hispanic/Latino population reside in the East Ward. 

In terms of income, Bloomfield’s median household income is $78,034.[6] Newark’s median household income is $35,199 and specifically Newark’s East Ward median household income is $54,722.[7] While Newark’s East Ward is a wealthier part of Newark, it still is at a significantly lower economic standing than Bloomfield.

In October 2018, Newark went door-to-door and handed out free filters to households the city identified as being affected by lead water contaminations. This action took place after The Lead and Copper Rule Compliance Study confirmed lead water contaminations much higher than the Environmental Protection Agency’s limit, 15 parts per billion. Before the confirmation from the study, despite being warned by the Environmental Protection Agency, city officials insisted that the water was “absolutely safe to drink”, assuring residents that the lead water issue was confined to a small number of homes.[8] The city wasn’t straightforward with the public, denying that there even is a lead problem in many households. The city misled and endangered the public by telling them that the water was perfectly safe.

After The Lead and Copper Rule Compliance Study confirmed high lead water contaminations, Newark identified 15,000 homes that had lead service lines. The city only identified households with service lines that directly source water from the  Pequannock Water Treatment Plant as qualified for a filter; these households are located in parts of the North Ward, parts of the South Ward, the West Ward and the Central Ward. The city did not provide filters to any residents in the East Ward, which sources water from the  Wanaque Water Treatment Plant.  The Federal Environmental Protection Agency that has been “consulting” with Newark’s district workers since the early 200s disagreed with Newark’s approach. They pushed for “emergency door-to-door water deliveries or water filters for families with children under the age of 6, pregnant or nursing women, homes with lead services lines or homes that tested above a certain threshold for lead in the water”.[8] The Federal Environmental Protection Agency argued that the city should provide filters to homes that tested positive for lead contamination; instead of only providing filters to homes serviced by the Pequannock Water Treatment Plant. Newark’s approach was a blanket approach vs the necessary case by case approach the Federal Environmental Protection Agency was pushing for. Newark ultimately did not follow their recommendation and the National Resources Defense Council asked the court to intervene in the lead contamination debate. A federal judge denied the National Resources Defense Council’s request, leaving residents from Newark’s East Ward unaware and unprotected.[9]

Months after distributing water filters, the city began receiving reports that these filters were failing to decontaminate the water. In August 2019, the U.S. Environmental Protection Agency urged the city to provide bottled water to affected residents and told officials it was “essential” to warn people not to rely on filters until more sampling was done.[10] In response the city began to provide qualified households two cases of water (with about 24 bottles per case). Residents could pick up their water from one of four locations provided by the city; they must bring a proof of address. Again residents who live in the East Ward which are served by the Wanaque Water Treatment Plant were not eligible for bottled water (with the expectation of pregnant or nursing women). The city insisted that the East Ward was safe, dismissing claims from the Newark Water Coalition that East Ward households also have lead water contamination. The National Resources Defense Council felt the city was “cherry-picking” incidents to address that were not representative of residents’ experiences 

In September 2019, after a month of testing samples, Mayor Ras Baraka addressed the public saying “Our message is simple: the filters work, use the filters,”.[11] Preliminary testing shows that 97% of filters were working as expected and “those numbers make us comfortable to move forward without bottled water.”.[11] So the city stopped giving out bottles of water, with the exception of pregnant women and families with children 6 years of or younger.[11] However to ensure that their water is safe, residents needed to do much more than simply “use the filter”. Despite the fact that the city was not being forthright about the full scope of people affected by lead water contamination, the city also overly simplified the actions that needed to be taken by residents to ensure that their water is safe. Leonard Thomas, a long time Newark water activist, regularly goes through a process of running his faucet for five minutes, filtering the water, and then testing it to ensure that it does not contain lead contaminants. The city’s minimal dialogue with residents resulted in many residents not taking the proper precautions and still being exposed to contaminated lead water.

In August 2019, New Jersey State transferred about $100 million from their federal clean water fund to help replace Newark’s lead pipes. It is expected that this project will cost about $132 million dollars.[12] Currently (2020) the city is in the process of replacing all lead service lines for free. Residents from the East Ward, who the city previously said does not need water filters, will also have their lead service lines replaced. In fact, 60 properties in the East Ward were included in the first phase of lead service line replacement. Unfortunately, the city is still downplaying the danger that residents in the East Ward face. They justify the lead service line replacement in all areas of Newark as an infrastructure upgrade, not an essential action taking place because all areas of Newark are in danger of lead water contamination. Tapinto Newark,  an online newspaper serving Newark, confirmed that East Ward households are in “ongoing health risk” after observing low orthophosphate levels and high lead level readings in the sampled East Ward.[12] 

The Water Crisis in Bloomfield, NJ

Shortly after Newark began distributing water filters, Bloomfield, which is fully sourced by the Pequannock Water Treatment Plant, began distributing water filters to all its residents. Bloomfield spokesman Dan Knitzer spoke to residents: “The township is definitely concerned with anything that affects public health and this is something that we’re becoming more aware of. We’re trying to be proactive with it”.[13] Bloomfield encouraged all residents to pick up a filter and agree to have their water tested for lead. Differently to Newark, Bloomfield encouraged residents to have their water tested. Newark chose to identify which households were affected rather than encourage residents to find out for themselves.

In August 2019, after the U.S. The Environmental Protection Agency warned that filters might not be working and Newark began distributing water bottles, Bloomfield announced that they will begin to test those filters.[14] Bloomfield’s approach was to first test filters at homes with high lead levels and then offer filter testing to any of the 3,000 residents who received filters. Bloomfield Mayor Michael Venezia announced that five tested homes had come back clear. At a town hall meeting, she spoke to the public saying: “These water filters have been given to residents whose homes contain older plumbing faucets and fixtures of pipes, which may allow lead to build up in the home, We tested our source water, and tests showed it had no detectable lead. Water enters our system entirely lead-free”.[14] Bloomfield municipality’s dialogue with its residents was transparent, thorough and regular. Newark’s Mayor Ras Baraka simply told his residents: “Our message is simple: the filters work, use the filters,”.[14] Bloomfield thoroughly explained their testing method and results in a town hall meeting. And most importantly, Bloomfield encourages their residents to find out for themselves by testing their water.

In August 2019, Bloomfield had already replaced 46 lead service lines, free to residents. It borrowed $1.1 million from the state infrastructure bank to continue their line replacement work and planned to source their water from somewhere else.[15] Bloomfield had begun replacing their service lines before Newark and had gotten aid from the state sooner than Newark. The town spent $10 million of its money on general water infrastructure improvements and connecting to the North Jersey District Water Supply Commission.[16] Bloomfield was more proactive and efficient than Newark’s. They were able to start replacing service lines quickers and used this as an opportunity to upgrade their infrastructure, replacing lead service lines and water meters.


Imagine not knowing your household water isn’t safe. Safe water is a basic right to residents in America. We drink it, cook with it, clean with it, bath in it, etc.

This paper argues: demographics and affluence of Newark and Bloomfield contributed to -Bloomfield’s municipality reacting more transparently and inclusively than Newark’s Municipality to the Lead Water Crisis. Decision-makers at all levels of oversight failing to notice the violations and poor management of the Pequannock Water Treatment Plant. Newark’s and Bloomfield’s aid and dialogue with their public differed. Bloomfield provided aid to all its residents and encouraged them to test their water for contamination. By encouraging the public to test their water for contamination, Bloomfield addressed the crisis in a case-by-case approach. Newark “identified” the location in its city that were in harm and provided aid to those residents. These locations source water from the Pequannock Water Treatment Plant. However, Newark sources its water from two water treatment plants: Pequannock and Wanaque and it’s been confirmed various times that households in Newark serviced by the Wanaque Water Treatment Plant have lead contaminated water. Newark did not encourage the public to test their water for contamination, instead they set the boundaries. East Ward residents, that are sourced by the Wanaque Water Treatment Plant, were not given the same aid as residents served by the Pequannock Water Treatment Plant: filter and bottled water. Even more damaging Newark still hasn’t addressed this fact. Newark has placed their residents in irreparable harm.

[1] Leonard Thomas (Newark Resident) in discussion with the author, November 2020. https://ejhistory.com/oral-interview-video-essay-image-analysis-tr/

[2] “Lead poisoning and health,” World Health Organization, 23 August 2019, https://www.who.int/news-room/fact-sheets/detail/lead-poisoning-and-health#:~:text=There%20is%20no%20known%20’safe,symptoms%20and%20effects%20also%20increases.

[3] City of Newark Department of Water and Sewer Utilities, “City of Newark Lead and Copper Rule Compliance Study.” Newark NJ, 2018

[4] Warren and Karen Yi For The Star-Ledger, Michael Sol. “Records show water treatment had state OK.” Star-Ledger, The (Newark, NJ), August 26, 2019: 008. NewsBank: Access World News. https://infoweb-newsbank-com.proxy.libraries.rutgers.edu/apps/news/document-view?p=AWNB&docref=news/1758EADF05A6E640.

[5] For The Star-Ledger, Karen Yi. “Was city’s water crisis preventable? Lead Records reveal lead problems festered for years.” Star-Ledger, The (Newark, NJ), December 22, 2019: 001. NewsBank: Access World News. https://infoweb-newsbank-com.proxy.libraries.rutgers.edu/apps/news/document-view?p=AWNB&docref=news/177FD0A45B408830.

[6]  U.S. Census Bureau (2010). Bloomfield township, Essex County, New Jersey. https://www.census.gov/quickfacts/fact/table/bloomfieldtownshipessexcountynewjersey/HCN010212

[7] U.S. Census Bureau (2010). Newark city, New Jersey. https://www.census.gov/quickfacts/newarkcitynewjersey

[8] For The Star-Ledger, Karen Yi. “Feb. 22 email told city of water treatment woes Water.” Star-Ledger, The (Newark, NJ), December 14, 2018: 001. NewsBank: Access World News. https://infoweb-newsbank-com.proxy.libraries.rutgers.edu/apps/news/document-view?p=AWNB&docref=news/1704E0721168B5F8.

[9]  For The Star-Ledger, Karen Yi. “Judge: City need not give out more water filters.” Star-Ledger, The (Newark, NJ), December 20, 2018: 001. NewsBank: Access World News. https://infoweb-newsbank-com.proxy.libraries.rutgers.edu/apps/news/document-view?p=AWNB&docref=news/1704E0721168B5F8.

[10] For The Star-Ledger, Karen Yi. “Nearby towns take steps amid lead crisis Towns.” Star-Ledger, The (Newark, NJ), August 20, 2019: 001. NewsBank: Access World News. https://infoweb-newsbank-com.proxy.libraries.rutgers.edu/apps/news/document-view?p=AWNB&docref=news/1756EC84ED2EBDF0.

[11] For The Star-Ledger, Karen Yi. “City to stop giving out bottled water to most; urges filters be used.” Star-Ledger, The (Newark, NJ), October 5, 2019: 008. NewsBank: Access World News. https://infoweb-newsbank-com.proxy.libraries.rutgers.edu/apps/news/document-view?p=AWNB&docref=news/176616413506DC10.

[12] Salant For The Star-Ledger, Jonathan D.. “Officials plan to ‘do what is necessary’ to get clean water.” Star-Ledger, The (Newark, NJ), September 12, 2019: 012. NewsBank: Access World News. https://infoweb-newsbank-com.proxy.libraries.rutgers.edu/apps/news/document-view?p=AWNB&docref=news/175E834491221FA8.

[13] For The Star-Ledger, Karen Yi. “Free filters on hand after lead concerns Water Township purchases its water from Newark plant.” Star-Ledger, The (Newark, NJ), November 22, 2018: 021. NewsBank: Access World News. https://infoweb-newsbank-com.proxy.libraries.rutgers.edu/apps/news/document-view?p=AWNB&docref=news/16FD9D142CBDCBE0.

[14] For The Star-Ledger, Karen Yi. “Lead-wary residents line up for bottled water Water Amid large-scale distribution effort, city investigating why some filters are apparently failing to decontaminate.” Star-Ledger, The (Newark, NJ), August 13, 2019: 001. NewsBank: Access World News. https://infoweb-newsbank-com.proxy.libraries.rutgers.edu/apps/news/document-view?p=AWNB&docref=news/1754A09A204AB170.

[15] Warren For The Star-Ledger, Michael Sol. “Suburb looks to leave Newark water system.” Star-Ledger, The (Newark, NJ), August 21, 2019: 004. NewsBank: Access World News. https://infoweb-newsbank-com.proxy.libraries.rutgers.edu/apps/news/document-view?p=AWNB&docref=news/1757413F10D612E8.

[16] Warren For The Star-Ledger, Michael Sol. “Two Newark suburbs struggle to remove lead water lines Lead Bloomfield has done some work; Belleville yet to begin.” Star-Ledger, The (Newark, NJ), January 19, 2020: 017. NewsBank: Access World News. https://infoweb-newsbank-com.proxy.libraries.rutgers.edu/apps/news/document-view?p=AWNB&docref=news/17890B6FF157E1B8.

Primary Sources:

  1. Two Newark suburbs struggle to remove lead water lines Lead Bloomfield has done some work; Belleville yet to begin

Star-Ledger, The (Newark, NJ)

This primary source includes information on the amount of money loaned to Newark and Bloomfield to aid in replacing lead service lines and how many service lines they have replaced as of January 2019. Both Bloomfield and Newark have also handed out water filters to residents. As of January 2019, Bloomfield has met the federal lead standard and Newark’s lead levels are still high. 

  1. City scales back bottled water distribution

Star-Ledger, The (Newark, NJ)

This primary source includes information about Newark’s plan moving forward after preliminary testing verify that water filters are working. September 2019- Newark started to scale down their bottled water distribution after preliminary testing of more than 300 filters showed 97% of them worked to remove lead from the tap water. DEP is setting up a program to edicate Newark residents on proper filter installation and maintenance. 

  1. Was the city’s water crisis preventable? Lead Records reveal lead problems festered for years

Star-Ledger, The (Newark, NJ)

This primary source creates a timeline about the actions that lead to the Newark lead water spike in 2017. City and state decision-makers failed to heed warning signs. Pequannock Plant Operator failed to run the plant effectively and follow state mandates. What broke the camel’s back- 2012 the federal government issues a new rule that clamped down on how water systems measure amounts of cancer-linked contaminants. Newark’s response was to make the water more acidic- which caused a lead issue. Currently, Newark has gotten funds from Essex County to replace lead pipes and provided filters and water bottles as mandates. This article is suggesting that decision-makers at every step of the ladder are responsible for the Newark Lead Water Crisis.

The 2012 federal government issued rule focuses on preventing cancer-linked contaminants, which are created when too much chemicals are used to disinfect the water containing too much unfiltered debris. Newark dropped it’s water pH level- making the water more acidic. Two years later- 2014, state regulators warned city officials about Newark’s disinfection practices, and warned city officials that residents should boil their water. However, the Pequannock Plant Operator, Pappachen, denied their claims. Pappachen argued the state’s tests had incorrect calculations and their new approach hasn’t been given enough time to work. The Pequannock Plant had also illegally dropped its benchmark for how many pathogens it needed to kill without asking the state. Records from four months of testing from 2013-2016 show the Pequannock Plant did not meet daily disinfection requirements 40%- every after self imposed standards. Throughout 2016 and 2018 the federal government marked Newark’s water system for accumulating the serious violations that jeopardized public health. This marking was missing by the state that didn’t force permanent fixes to Newark’s recurring problems. A state audit was initially by the EPA concerning New Jersey’s enforcement of federal lead rules. The DEP couldn’t find any evidence the state had ever set up a system in Newark that would have acted as an early alarm for failing lead prevention treatment.

Secondary Sources:

  1. CDM Smith. “Lead and Copper Compliance Study,” Published October 10, 2018. https://www.politico.com/states/f/?id=00000166-e5f2-dd0d-afe7-eff264510000  

This report analyzes data collected from the Pequannock and Wanaque Water System.

This report helps provide background history on Newark’s water supply system and specific evidence about where/to what extend lead water contaminations effecting residents. The City of Newark Copper Rule Compliance Study addresses the history of Newark’s water supply system. It provides information about water sampling results and water quality trends from the Pequannock and Wanaque Water System- identifying Pequannock as exceeding Lead Action Level from 2017. The report identified Bloomfield as receiving a large percentage of its supply from Newark’s Pequannock WTP. The results from sampling from South and North Ward confirm lead contaminations.

  1. New Jersey Department of Health Office of Local Public Health Childhood Lead Program, “Childhood Lead Exposure in New Jersey Annual Report 2018,” Published 2018.https://www.state.nj.us/health/childhoodlead/documents/reports/childhoodlead2018.pdf 

This report analyzes New Jersey children’s exposure to lead as of 2018. 

This report helps provide background information about New Jersey children in its various municipalities affected by lead. It identifies Newark as in the top five largest municipalities with the highest percent children with an Elevated Blood Lead Levels at or above 5 ug/dL (4.4%). It includes information about Bloomfield. This information will articulated what percentage/to what extend Newark’s children are effected by lead compare to children of other municipalities.

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