In our recent webinar with WaterOnline, 120Water’s Director of Water Quality Compliance Jonathan Cuppett shared that the LCRR is subject to change under LCRI except for the submission of your Lead Service Line Inventory by October 16th, 2024. 

With under a year until preliminary inventories are due, Jonathan Cuppett helped define the LCRR priorities that utilities should focus on over the next 10 months in order to meet the October 2024 deadline.

LCRR Requirements and Priorities

Here are some priorities to consider when preparing your service line inventory for submission:
(Skip to the 5 minute mark in the recording to review).

• Review your records. Understand the type of records you have or can gain access to that might have information related to the material of your service lines. Develop a plan to systematically evaluate the required historical records in an order that will provide the most useful and accurate information
• Classify your service lines. Refer to the EPA’s table at the bottom to determine how each portion of a service line makes up the classification of the entire service line.
• Make your inventory publicly available. You’ll need to make your inventory available online if your system serves more than 50,000 customers.
• Have a plan to notify customer with an LSL, GRR, or unknown service line within 30 days of submitting your inventory.

After covering the required aspects of your service line inventory for submission, Jonathan shared how your service line inventory can help other major areas of LCRR compliance including:

• Developing your LSLR plan if your inventory contains any LSL, GRR, or service lines of an unknown material type
• Identifying your new sampling sites
• Creating a list of all the school and childcare facilities your system serves
• Knowing which residents need to receive certain communications

(Learn more about how you can leverage your service line inventory to help with the other areas of LCRR at the 12 minute mark in the recording).

Through much of the records review for your inventory development, you will come across information that isn’t required for your inventory but is information that you’ll need for other areas of LCRR compliance. For example, documenting the building type for each of your locations is not required in the EPA’s template for a compliant inventory. 

At the same time, the new tiering methodology for your sample sites will be based in part on a location’s building type and you’ll need to know which locations in your system are connected to schools or childcare facilities. 

It is very likely that in your inventory development, you will come across information about each of your location’s building types. Our suggestion is to make a concerted effort with inventory development to gather the data you’ll need to coordinate LCRR compliance beyond the initial inventory deadline in October 2024. 

Communication Strategy Considerations

In addition to proactive data gathering, 120Water’s Senior Manager of Water Utilities Marketing, Arianne Shipley drove home the importance of extending the proactive mindset to the piece you hear mentioned in each component of LCRR compliance: Communications. 

Inventory is the foundation of LCRR compliance, but communications encompasses the actions you’ll need to take based on your inventory. 

The inventory will impact who, how, and when utilities will need to communicate with their customer after October 2024. It’s important that systems start putting together their communications strategy now alongside inventory development so that they are prepared to quickly and efficiently communicate when necessary. 

Minimally, the communications strategy needs to consider and plan for how the utility will support the execution of the LCRR communication requirements, which include:

• Notifying ALL customers within 24 hours of an action level exceedance. 
• Sending certified communication to residents with a service line of unknown material within 30 days of submitting the inventory.
• Annually notifying customers that have a service line of unknown material type.

Your communications strategy needs to encompass not only how the communications will be delivered, but also how your communication assets will be developed and approved internally. Here are some things to consider when developing your communications strategy:

• Who are the LCRR stakeholders we need to communicate with?
  • Are they internal (i.e. directors) or external (i.e. customers)?
• What materials do we need to develop to bring the message to each stakeholder?
• How long does it typically take to write, design, and get approval for your communications material?
• Who and from what other departments need to be involved in the process?
• What are the best channels to deliver the communication to each group? Do we need to create a new channel?
• How are we going to distribute each type of communication, especially the communication required for compliance?

(Watch from the 30th-minute mark in the recording to hear Arianne’s recommendations to consider for your communications strategy).

The countdown to October 2024 is on, but the LCRR journey is just beginning. Your inventory will be the foundation from which you can build a variety of program strategies you’ll need to execute in the near future to achieve long-term LCRR compliance.

Check out data management systems that organize your inventory data in a way that enables you to use the data you’re collecting to effectively run all the other LCRR programs. LCRR compliance is the sum of many parts, so pick a tool that helps you think about and manage LCRR compliance holistically.  

If you’re interested in learning more about how 120Water can help you set up and manage a successful LCRR program, contact us here.

*EPA’s Classification Table

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