When Illinois first asked the City of Evanston to inventory its lead service lines, the state's form was pretty basic: how much lead, how much non-lead galvanized. Today, that same annual submission is "a serious comprehensive spreadsheet," says Darrel A. King, Evanston's Water Production Bureau Chief. Filed as a PDF every April, it runs 203 pages.

That jump from a simple form to a 203-page filing previews what many U.S. water systems are about to go through. The federal Lead and Copper Rule Improvements (LCRI) set a compliance deadline of November 1, 2027. Illinois moved earlier, with a 2022 state law, the Lead Service Line Replacement and Notification Act, and the state's 2024 adoption of the Lead and Copper Rule Revisions (LCRR). Evanston has been working through many of the LCRI's requirements ever since.

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The Inventory Got Bigger, and So Did the Questions

Evanston's current inventory covers more than 14,000 service lines: roughly 5,400 confirmed non-lead, just over 9,200 lead, and 270 galvanized lines that require replacement. Since the 2022 law took effect, the city has replaced just over 1,300 lead service lines.

To verify what is actually coming into each building, Evanston is using a citywide water meter and meter-interface-unit (MIU) replacement program, now in its first or second year and covering more than 13,000 homes. When installers run new wiring inside a property, the city gets a chance to see the service line material for itself.

The first year Evanston mailed its service line material notices, the notice was comprehensive and required no action, and the city still got hammered with resident requests. Staff spent about a month keeping up. Now the city runs pre-outreach education before each notice goes out, telling residents what the letter is and that it needs nothing from them. The flood hasn't repeated.

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Then Came School and Childcare Testing

In 2025, Evanston launched a lead testing and notification program for schools and childcare facilities. "There's just a lot of extra work, a lot of areas that we were not used to being in," said Eleanore Meade, the city's chemist, who is responsible for water quality and compliance.

Step one was building a list. School boards, state licensing boards, and the public health department each had a version, and the versions didn't match. Some sites had closed. Others showed up on one list and not another. The state also gave little guidance on how to carry out the program in year one, so Evanston worked on a tight timeline.

The first-year requirement was to sample 20% of the inventory. Facilities that declined, didn't want sampling, or already had results could still count toward that total, and so could facilities that never responded, as long as the city documented its outreach. Evanston is now working through the sites it didn't reach the first time, aiming to finish them in a single year.

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A Replacement Plan Built Around Several Numbers

Evanston isn't sure yet how many lead lines it will have to replace each year. Under the Illinois act, it expects about 500 a year. Under the LCRI, that could rise to about 1,000 a year, or around 642 a year if a deferral stretches the timeline to 16 or 17 years. The city's plan lays out how to reach each of those numbers, and the city has elected to cover the cost of replacements all the way into the house.

Evanston runs three replacement programs today. The annual water main replacement program doubled this year, from 1.5 miles to 3.2 miles. A leaks-and-breaks program covers replacement on both the public and private side when a lead or galvanized line fails. A homeowner-initiated pilot, open at up to 50 locations this year, offers a $2,500 reimbursement and waives permit fees for residents who don't want to wait for the city's schedule.

Funding comes from ARPA dollars, cash, water rates, state revolving fund loans, about $5.4 million in principal forgiveness tied to state-designated disadvantaged census tracts, a Department of Commerce and Economic Opportunity grant for low- and moderate-income areas, and TIF dollars where available. Outreach runs through mailings, community and ward meetings, FAQs, door-to-door visits, and yard signs. The city is also working with a consultant who specializes in messaging, because some households need ten contact attempts before they respond.

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Sampling Rules Changed Too

In May 2024, Illinois asked Evanston for a new lead and copper sampling site plan. The old version needed little more than an address. The new one asked for the public-side and private-side materials, the year the home was built, and what was on the private plumbing.

"That's a whole paradigm shift for utilities. We weren't used to paying attention to anything past our own infrastructure, and now we're expected to know a lot more about it." — Eleanore Meade, City of Evanston

A new tiering system followed. Evanston went from 30 sampling sites to 60 and from once-a-year sampling to twice a year, which Meade pointed out meant 120 samples in a year.

Meade had been running the newer "first-and-fifth-liter" protocol since 2022, because it was on her radar and she wanted to see the results before anyone was surprised. Evanston uses a blended polyphosphate for corrosion control, and its fifth-liter samples tend to run higher than its first-liter samples, roughly a 3 parts-per-billion increase at the 90th percentile. The city's 90th percentile still came in under the 10 ppb action level, which moved Evanston back to standard monitoring: 60 sites, once a year.

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Where 120Water Fits In

Most of what's above is Evanston's own program, built to meet Illinois law. One piece runs through a direct partnership with 120Water: sampling after a replacement. Once a replacement is done, the address goes into 120Water's database. About a month later, 120Water sends the customer an offer to have their water sampled. Customers who opt in get a kit roughly three months after the replacement, and results go to both the customer and the city. Per 120Water's review of the data, about 35% of customers who receive the offer take it.

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The Advice They'd Give Everyone Else

Asked what they'd tell other systems, Meade said to start early and not to be shy about borrowing templates, FAQs, and sampling instructions from utilities that have already built them. King did the same with his public-facing inventory map. After attending a seminar where large cities described their lead work, he used Cincinnati's map as a template for Evanston's. He also urged utilities to ask regulators their questions and to lean on their AWWA state section, which Evanston does with the Illinois section.

"Don't feel like you're alone, and that you have to create it all by yourself. There are other utilities out there that have already been through this." — Darrel A. King, City of Evanston

Evanston has been working under Illinois' lead service line rules since 2022, so its team can already say what the work looks like: a bigger inventory, new lists to build, more sampling sites, and a replacement plan that has to hold up under several possible numbers. Their advice to the systems next in line is to borrow what already exists and ask for help early.