Private Side Inventorying: Tackling The New Challenge of LCRR
Posted on July 7, 2021 Kelly Smith
With the revised Lead and Copper Rule calling for a full Lead Service Line Inventory by October of 2024, water professionals must begin a massive-scale project. No part of the challenge is more daunting than collecting information on private-side service lines–and systems across the nation have a long road ahead of them to get the data needed to succeed in this project. Gathering all the necessary data will require thorough records audits in addition to proactive communication and education for residents.
New Private-Side Requirements
In the past, water systems have only been responsible for public service lines, with any side of the line on consumer property falling outside of their compliance requirements. Aiming to better understand the true lead scope in our communities, the new Rule requires systems to conduct a complete location-based inventory of both public and private side lines.
Where LSLs are present, systems will be required to update the inventory annually and develop a Lead Service Line Replacement plan to meet annual goals. The Rule contains the additional caveat that systems must replace the publicly owned side of an LSL within 45 days of a customer replacing the private side, if the customer notifies the utility.
The inventory itself is perhaps the largest challenge of the revised Rule–and the private side nuance is the trickiest aspect.
Private-Side Materials Data
According to polls conducted across the industry in 2020, only 25% of systems claim to have any private side material records at all, let alone the near-complete data required for an official inventory. Even if systems have kept great records on the public side, it’s unlikely this extended to private side lines, as it has never been required before.
Thus, many systems will need to start from scratch. Reviewing records such as existing policy and plumbing codes, home age, and tax parcel data can help utilities make assumptions about the likelihood of lead on a property.
Additionally, predictive modeling can be a powerful tool to generate information about the private side of service lines. With a high number of unknowns, systems can input existing data into a model to generate probabilities for every home with an unknown service line, helping them to prioritize and quantify the efforts needed to validate materials.
Communications & Education
The new responsibility of inventorying the private side includes the need for more communication and education between utilities and their customers. This requirement must be met through a collaborative effort between systems and residents, with the completion of an inventory relying heavily on resident responsiveness and private-side access.
According to recent polls, only 32% of systems have email address data for customers. In today’s world, where so much communication is digital, customers expect information from their utilities to be sent via the channels they use the most. In a recent survey, 86% of customers expected businesses to communicate with them through a mix of digital and physical channels, with email topping the list of preferred methods.
This project is going to require customer buy-in, so it’s important to get the communication strategy right. Proactive education about the new requirements of the Rule will go a long way in ensuring customers are informed about the changes and understand why you’re testing their private-side pipes.
Validating material information will be perhaps the most communication-heavy aspect of the project, and having a strong digital communications strategy will help systems communicate the necessary validation method and get customer buy-in to help where needed.
Utilities should evaluate what combination of validation methods (and communication strategy alongside them) is most realistic for them in terms of budget, resident engagement, etc.
- Inspection by Utility Staff: Utilities can perform on-site inspections during opportunities when they’re already visiting residences, such as meter or main replacement projects or fixing leaky services. Combining these efforts can save time and money for the system.
- Profile Sampling: In profile sampling, consecutive samples are collected from a customer’s faucet and analyzed for lead. The resulting concentrations may then be used to identify lead sources along the line. Shipping sample bottles directly to the customer with clear communication and pre-packaged return labels can save your system time and increase efficiency.
- Lead Swabs: Lead Swabs are typically used to identify leaded paint but can be useful in identifying lead pipes, leaded solder and leaded brass. Systems can enlist residents to perform these tests on their own pipes.
- Customer Survey Campaigns: Customers can help utilities fill in significant data gaps through well designed and orchestrated communication campaigns. By leaning on marketing and education efforts (sending physical or digital materials directly to customers), utilities can communicate the importance of this project and request direct assistance via photographs or surveys.
Steps To Take Today
If you’re struggling with the private side of inventorying, you’re not alone. The good news is, there are ways to tackle this challenge that won’t stretch your staff or budget.
A great first step is to begin the records review process, gathering existing data from sources such as work order systems, billing systems, GIS, and tax parcel data. From there, build a picture of where private side lead lines may be located so you can begin the validation process. A similar audit on the customer data side can help identify gaps in information so your system can collect the necessary data to fill out your communications strategy.
120Water is designed to help systems overcome the challenges of inventorying. For more information on how our solution can help you predict, validate, and communicate the location of private-side lead lines, schedule a consultation with our team.