Now that the Lead and Copper Rule Improvements (LCRI) has been finalized, many water systems may be unsure of what to do next or how to start preparing for the LCRI compliance deadline of November 1st, 2027. Each water system’s journey will be unique, but all systems can start by continuing to build on their initial service line inventory that was required to be submitted as part of the Lead and Copper Rule Revisions (LCRR) in 2024.

LCRR Requirements to Keep in Mind

While the October 16th, 2024 LCRR compliance deadline has come and gone there are still some LCRR elements that water systems need to consider. In addition to submitting the initial service line inventory in 2024, water systems were also required to notify customers with lead service lines (LSL), galvanized requiring replacement (GRR), and unknown service lines. The service line notification is an annual requirement and notifications need to be sent in 2025, 2026, etc. until the service line can be classified as non-lead. Moreover, moving forward, water systems are required to notify all of their customers within 24-hours following a systemwide lead action level exceedance at 15 µg/l.  Starting in November 2027, the 24-hour notification will remain in effect but the lead action level will be 10 µg/l.  

LCRI Deadlines

The LCRI has its own set of requirements and deadlines. Three LCRI elements must be submitted to state regulators on the LCRI compliance deadline of November 1, 2027 including: 

• Updated “Baseline” inventory that includes connector material
• List of all school and childcare facilities served by the system
• Service line replacement plan (if any LSL, GRR, or Unknowns are in baseline inventory)

Water systems also need to be prepared to comply with a variety of other LCRI changes that will go into effect starting on November 1st, 2027. However, system specific characteristics will determine the exact timing of if and when an individual water system is impacted. LCRI elements that water systems need to prepare for include:

• Validate non-lead service lines and verify all unknown service lines
• Initiate a school and childcare sampling program
• Comply with a lower lead action level of 10 µg/l 
• Update sampling programs to align with new the tiering structure
• Implement a new sampling protocol for LSL sites (sample 1st and 5th liter)
• Enhance customer transparency following lead action level exceedances
• Implement risk mitigation procedures following service line replacements or disturbances
• Offer to sample at properties served by a LSL, GRR, or Unknown service line
• Perform a follow up assessment at individual compliance sample sites with >10 µg/l Pb
• Assess corrosion control treatment following a Pb or Cu ALE 

Where to Start

As numerous November 2027 deadlines approach, putting together a comprehensive LCRI compliance plan may challenge water utilities juggling many other responsibilities and new regulations. There are three steps that utilities can take today to help them start their journey.

1. Begin Identifying Connector Materials: The LCRI “Baseline” inventory is due on November 1st, 2027. Connectors (commonly referred to as goosenecks) are required to be added to the Baseline inventory and categorized as lead, non-lead, unknown, or no connector present. While the connector material does not impact the classification for the entire service line (some states have different interpretations) water systems should review their records to classify as many connectors as possible prior to the submission deadline. 
2. Start/Continue an Unknown Verification Program: Whether you have 100 or 1 million unknowns, identifying service line materials is the foundation of LCRI compliance. Unknown materials will be assumed to be lead and included in the service line replacement rate that determines how many LSLs/GRRs need to be replaced each year. Water systems should develop a verification plan that assesses state-approved verification methods, evaluates opportunities to verify materials during normal field operations, and considers a data management strategy to ensure all of the data is organized and accessible to various team members. 
3. Identify Funding: The costs to complete and manage unknown verification and service line replacement programs can be substantial, fortunately funding is available. The Bipartisan Infrastructure Law (BIL) has allocated $15 billion in federal funding, disbursed through Drinking Water State Revolving Funds (DWSRF), specifically designed to support programs to identify unknowns and replace service lines. Water systems should research funding pathways in their state and understand application submission requirements. 

The Path Forward 

All of the LCRI and LCRR required elements may overwhelm water providers, especially smaller systems with limited staff who are already at capacity. Regardless of how utilities plan to comply, continuing the inventory process will only benefit them. Compliance obligations can be minimized for those who are able to confirm there are no LSLs or GRRs in their system. Systems with unknown service lines in their Baseline Inventory submission on November 1st, 2027 will be forced into more requirements including offering to sample at customer homes, submitting a service line replacement plan, and including unknowns in their service line replacement rate calculation. 

The LCRI represents a new generation of data-intense regulations, with data management playing a critical role in overall compliance success. As your system works to meet LCRI’s many requirements and multiple deadlines, consider digital solutions that can help organize and manage the variety of data throughout your compliance journey. 

Learn more about how 120Water can support your system through these regulatory mandates by connecting with our state specialists here.