City Managers play a pivotal role in pursuing safe and clean drinking water for communities. The Environmental Protection Agency (EPA) Lead and Copper Rule (LCR) stands at the forefront of this mission. At 120Water, we understand the vital responsibilities of city managers and provide support throughout their LCR journey. 

We packed this article with detailed information. However, we also understand how valuable your time is, so here are the highlights:

• Understanding the different acronyms and how they affect your entity
• As the City Manager, how can I help my water system?
  • Understanding the rules and requirements and staying up to date with the LCRI
    • What elements are required in 2024?
    • What major LCRI changes should we anticipate?
  • Empowering your staff to build the right internal team to manage the projects
  • Adopting a customer-centric perspective to communicate transparently
  • Partnering with experts to accelerate progress and manage the data
• How 120Water is here to help your water system achieve compliance

Pro Tip: If your role is the city manager, we encourage you to read through this article and use  it as a guide to strike up a conversation with your water system operators. If you are the water operator you can take elements from here to educate your city manager on the changes and what’s to come in the future.  

Understanding the Lead and Copper Rule: A Timeline of Regulatory Developments

First and foremost, it is essential to understand the nuances associated with the Lead and Copper Rule and the timeline for which they occurred. 

• The EPA first issued the LCR in 1991, intending to limit concentrations of lead and copper in drinking water and setting a standard for pipe corrosion control, a proven method of controlling contaminants in drinking water. 
• Thirty years later, in 2021, the EPA released the Lead and Copper Rule Revisions (LCRR), which included major changes to the LCR geared toward eliminating lead in drinking water by removing the sources of lead. 
  • One major component the EPA finalized is that water systems submit a service line inventory by October 16, 2024. This date is not subject to change. 
  • The EPA clarified that upon further evaluation of the other LCRR components, there were significant opportunities to improve them in 2023. 
• In November 2023, the EPA released the third version of the Lead and Copper Rule, calling it the Lead and Copper Improvements (LCRI), which proposes changes related to replacing lead service lines, sampling requirements, lowering the “allowable” amount of lead, and public communication. 

Important Note: As of January 2024, all LCRI requirements are proposed and subject to change. However, the EPA intends to finalize the LCRI proposal before the compliance deadline of the LCRR, which is October 16, 2024.

As the City Manager, how can I help my water system?

City Managers at the Center of the LCRI

Improving water infrastructure and water quality is a must-solve problem for the country. However, when 93% of water utilities in the US serve populations of 10,000 people or less, changes to regulations can feel overwhelming. The LCRI represents more than a new EPA regulation; it constitutes a comprehensive effort requiring teams, time, and technology to align seamlessly. City Managers hold a central role in orchestrating this harmonious synergy to get the job done.

With over 4,000 utilities partnering with 120Water, we’ve gained insight into the challenges and opportunities inherent in this undertaking, drawing upon nationwide collaborations with cities. As the city manager, you can help by:

• Understanding the rules and requirements and staying up to date with the LCRI
• Empowering your staff to build the right internal team to manage the projects
• Adopting a customer-centric perspective to communicate transparently
• Partnering with experts to accelerate progress and manage the data

Get Educated and Stay Up-to-Date

The LCRR and newly proposed LCRI are overwhelming for even the most seasoned water professionals. However, being up-to-date on the regulations and understanding how they affect your staff and the community is critical. Why? Given the short timeline to submit inventory and prepare your community for the upcoming communications, your understanding will help bridge the gap between your city council, stakeholders, and the community while your utility staff is boots on the ground, building the inventory.

What Elements are Required in 2024?

Between now and October 2024, entities should still comply with the Lead and Copper Rule (LCR). The EPA is incorporating certain aspects from the LCRR and setting a deadline of October 16, 2024, for specific tasks:

• Service Line Inventory (SLI) is due.

• Public notification associated with the inventory to all customers with a lead service line, galvanized requirement replacement, or unknown within 30 days after inventory.

• Notification of all customers within 24 hours once it is discovered that there is a lead action level exceedance of 15 ppb.

What Major LCRI Changes Do You Anticipate?

The LCRI proposes changes related to replacing lead service lines, sampling requirements, lowering the “allowable” amount of lead, and public communication. 120Water reviewed the 600+ pages of the proposed LCRI and listed below what changes we expect to see finalized in 2024. 

NOTE: If your eyes glaze over or these proposed changes go over your head, don’t stress! Use this list to start a conversation with us at 120Water or your water system operators to understand better how they will affect your community. 

LCRI major changes: 

• Remove all lead service lines (LSL) and galvanized requirement replacement (GRR) “under your control” within ten years (Oct. 2037) 
  • Remove regardless of the 90th percentile lead (Pb) levels
• Lower the action level to 10 ppb (from 15 ppb) and remove the existing Trigger Level
• Sampling at LSL sites (Tier 1 and 2): Sample for Pb in 1st- and 5th-liter and use higher results for the 90th percentile
• Document control and access issues for service line replacement
• Provide results to customers for ALL samples within three (3) calendar days, including supplemental monitoring
• Connectors will be added to the Baseline Inventory
• Additional Requirements for chronic Pb ALE’s (Filters to Everyone)

Building the Right Team 

The primary and most critical step in the LCRI journey is assembling the right team. City Managers are often the key to identifying and bringing together the appropriate departments and partners.

Creating the perfect team may seem daunting, especially when 85% of utilities operate with three or fewer employees. But one of our valued customers aptly said, “There’s not enough time to consider every option at length – so utilities should just start somewhere and then continually reflect and revise.” In other words, take that first step, and the path will become clearer as things progress.

Thinking Like a Customer to Build Trust

Engaging residents in the private-side service line verification process requires City Managers to adopt a customer-centric perspective. While this may seem obvious, it constitutes a crucial step that requires intentionality. Many City Managers reside within the communities they serve, often having friends, family, and neighbors among their constituents.

In order to support the utility department’s projects effectively, the city manager should recognize and appreciate the differences between the “community perspective” and the “professional/technical” perspective. It is important not to rush to conclusions based solely on feedback from citizens or customers, as many complex factors are at play, including differing philosophies, personalities, and roles within the department. Mutual understanding, appreciation, and respect for these various perspectives make it easier to address complex issues and ensure the successful implementation of utility projects. External pressures from sources like the media, community groups, and employee organizations further emphasize the need for a collaborative environment that balances these different dynamics.

This unique viewpoint enables active participation in a transformative initiative directly impacting the local community. Building trust hinges on transparency. Commence with consistent, transparent education regarding the LCRI initiatives and proceed with actionable measures to assist residents in eliminating potential lead contaminants from their water supply.

Partner for Success

As city manager, you can support your water system by encouraging them to partner and outsource elements of the LCRI. The 120Water team has extensive experience assisting cities of every size in building and verifying inventory and constructing effective communication campaigns for their residents. 

120Water Helps You with Inventory and Verification Efforts

If your entity is at the beginning, building and verifying your inventory, check out how we supported the City of Smyrna, Georgia’s inventory development efforts and how we helped Del-Co Water Company, Ohio reduce their unknowns by 75%.

120Water Helps You with Communication Efforts

120Water is deeply invested in the success of our customers, going beyond building your LCRR  inventory. We offer a variety of communication-related services, from best practices to services, many of which are showcased in this public engagement lookbook.

Our communication-related services encompass:

1. Disseminating information to residents about the city’s LCRR initiatives via postcards, websites, and letters.
2. Facilitating the distribution of sampling kits to residents, along with clear instructions on collecting samples and the importance of doing so.
3. Managing the collection of service line data from residents through surveys and lead swab kits.
4. Organizing and securely managing the inventory data on our platform, enabling utilities to submit the required inventory directly to state agencies.
5. Develop a public transparency dashboard to communicate project progress and success with residents.

We’re Here to Help

City leadership faces a challenging yet vital project, and 120Water is ready to provide the necessary assistance. We offer the technology, resources, and expertise required to establish a compliant service line inventory and meet the October 16, 2024 deadline.

Furthermore, our solutions empower you to create a public transparency dashboard that showcases your proactive approach to safeguarding your community’s water supply. Your leadership and ability to build trust within your community will be instrumental in the success of your inventory development.

Standing at the forefront of the LCRI initiatives and being dedicated to ensuring clean, safe water is commendable. City managers or municipality leaders interested in partnering with 120Water to address LCRI requirements successfully should be quick to reach out. Together, we can ensure the well-being of your community and the integrity of its water supply.

Next Steps

1. Check in with your water utility leader. Understand how they plan to manage this massive project and where you can provide help or outsource some of their workload.
2. Review and share these 120Water resources with your team. While the inventory is due this year, other big requirements such as communications, sampling, and data management are just around the corner.
3. Book a Planning Assistance Session with our team to better understand how 120Water can partner with your city to tackle your compliance programs. These free 30-minute meetings are an opportunity for you to speak with a specialist in your state to better understand how 120Water can partner with your city to tackle your compliance programs.