Over a year has passed since the Lead and Copper Rule Revisions (LCRR) compliance deadline, bringing us closer to the Lead and Copper Rule Improvements (LCRI) compliance deadline of November 1, 2027. While some utilities may have shifted their focus away from service line inventories over the past year, attention is turning to compliance as the LCRI deadline approaches—now one year earlier than the rule was finalized. Utilities across the country once again face the pressure of meeting the requirements aimed at eliminating lead exposure risks. There is a lot to be done over the next two years.
To support this, the Environmental Protection Agency (EPA) has released the next round of State Revolving Fund (SRF) appropriations to help utilities achieve compliance. Utilities can leverage these programs through the Drinking Water State Revolving Fund (DWSRF), which provides low- or no-interest financing for lead service line replacement. DWSRF financing is available through the Infrastructure Investment and Jobs Act (IIJA) and the Bipartisan Infrastructure Law (BIL). Utilities may access financing to support Lead Service Line Replacement (LSLR), including replacement projects, service line inventories, and compliance-related activities. This article provides a comprehensive roadmap for utilities to achieve compliance, including inventory, planning, financing, and strategic execution.
The LCRI compliance deadline is fast approaching, making it critical for utilities to evaluate their current progress. Think back to 2024, when utilities scrambled to complete and submit their initial inventories to state regulatory agencies. Funding quickly ran out, especially in the states where it was operating on a first-come-first-serve basis. Some consultants declined projects due to their workload. The lessons from LCRR in 2024 are clear. Waiting until 2027 to start working on LCRI compliance is not an option; the time to act is now.
The cornerstone of LCRI compliance is having a complete and accurate inventory of service lines. Many communities still face uncertainty regarding the composition of their service lines, whether on the public side, private side, or both. Unknowns may pose a significant challenge to compliance, including the need for continued annual customer notifications and an elevated replacement rate. For communities still dealing with unknowns, the most cost-effective solution for reducing them lies in implementing a field inspection program combined with predictive modeling. The number of physical inspections required for your field inspection program depends on the number of unknowns that remain in your system.
| Number of "Unknown" Service Lines | Number to Physically Verify |
|---|---|
| Fewer than 1,500 | 20% of "unknown" lines |
| 1,500 | 306 |
| 1,600 | 310 |
| 1,700 | 314 |
| 1,800 | 317 |
| 1,900 | 320 |
| 2,000 | 322 |
| 2,200 | 327 |
| 2,400 | 331 |
| 2,600 | 335 |
| 2,800 | 338 |
| 3,000 | 341 |
| 3,500 | 346 |
| 4,000 | 351 |
| 4,500 | 354 |
| 5,000 | 357 |
| 6,000 | 361 |
| 7,000 | 364 |
| 8,000 | 367 |
| 9,000 | 368 |
| 10,000 | 370 |
| 15,000 | 375 |
| 20,000 | 377 |
| 30,000 | 379 |
| 40,000 | 381 |
| 60,000 | 382 |
| 90,000 | 383 |
| 225,000 or more | 384 |
If you believe that you have no lead in your system, statistical analysis can be used to allow you to mathematically claim your system as Lead-Free, pending your state’s acceptance of modeling, as our team has done for clients such as Blacksburg and Radford, VA. At least 34 states have released specific guidance documents that accept statistical or predictive modeling methods for minimizing unknown service lines. Before commencing your field program, it is always recommended that utilities meet with their state regulatory agency to lay out their plan and understand any specific nuances that may be more stringent than the EPA’s LCRI requirements, especially regarding field investigations, the number of representative investigations required, and the criteria for accepting predictive models or statistical analysis to minimize unknowns.
In addition to the baseline inventory, there are many other compliance components that are due on November 1, 2027.
Read the full version from Water Finance & Management here.