With the October 16 deadline for the Lead and Copper rule revisions (LCRR) quickly approaching, it's crucial now more than ever for water systems to be well prepared for compliance. In the recent webinar ‘Get Ahead, Stay Ahead’ by Water Online, CDM Smith, and Trinnex, the speakers discuss what utilities need to do before and after the LCRR deadline and share a few insights around the proposed Lead and Copper Rule Improvement (LCRI).
Sandy Kutzing (Senior Vice President, lead and copper strategy leader, CDM Smith), Mark Zito (Vice President of Product Management, Trinnex), Rose Hanson (Strategic Communications Lead, CDM Smith) and Katie Deeher (Product Leader, Trinnex), together covered the LCRR compliance requirements, and highlighted the importance of performing public education and outreach and using technological solutions (including predictive modeling) to streamline utilities’ processes — now and into the future.
While utilities may be on track for the LCRR deadline, there’s still uncertainty about what's next and what do they need to prepare for after the deadline. Let’s get into the details!
LCRR and LCRI
As communities across the United States work to safeguard the quality of their drinking water, the Lead and Copper Rule Revisions (LCRR) and Lead and Copper Rule Improvements (LCRI) are setting the stage for a monumental shift in how water utilities manage lead service lines (LSLs). By October 16, 2024, all water utilities are required to submit a service line inventory, identifying the material of both public and private service lines.
Under the LCRR, water systems are also required to follow science-based testing protocols to identify the presence of lead service lines and make this information publicly available. However, not all service lines need to be known by the October 2024 deadline. Utilities are allowed to have unknowns in their inventory at this stage, with the expectation that a complete inventory will be developed by 2037 per the proposed LCRI.
The regulations, however, are not without their complexities. There's often confusion regarding certain types of pipes, such as lead connectors (goosenecks) and galvanized pipes. Goosenecks, which are short segments of pipe used to connect service lines to the water main, do not qualify as lead service lines unless lead is detected upstream. Similarly, galvanized pipes only need replacement if lead is found in the upstream line, or the upstream line was previously lead. Clarifying these distinctions will help utilities focus on replacing the most dangerous sections of pipe.
To further ensure the elimination of lead from the nation’s drinking water, the Environmental Protection Agency (EPA) has proposed the LCRI, which builds on the foundations laid by the LCRR. This proposal calls for most water utilities to replace lead service lines within the next 10 years, starting in 2027. The aim is clear: provide safe drinking water to communities across the country.
Here are the top three points utilities and communities need to know about the LCRR and LCRI:
- Lead Service Line Inventory: The first critical step is the submission of the initial inventory of lead service lines by October 2024. Starting in 2027, utilities will be required to replace 10% of lead service lines each year.
- Lead Service Line Replacement: By 2027, utilities must submit a detailed lead service line replacement plan, and partial replacements will no longer be allowed. To help detect and mitigate lead risks, free lead testing will be offered for all lead, galvanized requiring replacement and unknown lead status service lines, and stricter sampling requirements will take effect by 2028. These measures are designed to ensure that the transition to a lead-free infrastructure is both thorough and transparent.
- Unknown Service Line Elimination: By 2037, utilities must eliminate all unknown service lines from their inventories. This includes identifying and replacing lead service lines that were previously undetected. At the same time, the EPA plans to lower the acceptable lead action level in drinking water from fifteen parts per billion to ten parts per billion in 2027, further tightening safety standards.
Funding Opportunities for LSL Replacement
To support the massive task of replacing lead service lines, funding is available from 2022 through 2027, including bill funding opportunities with up to 50% principal forgiveness. This financial assistance is crucial for utilities working to replace both public and private-side service lines. Utilities are encouraged to collaborate with local townships and state legislators to secure these funds. In cases where cost-sharing with homeowners is necessary, legal tools such as special tax assessments may be required. Click here for more information.
Getting Ahead: Immediate Actions for LCRR Compliance
To meet LCRR compliance, utilities must complete a thorough records review (e.g., tap cards, GIS files, permits) by October 16, ensuring private service lines are tracked up to building inlets, even if some remain unknown.
Additionally, utilities need to document the source and date of all information for future reference and use modern software tools to track progress and communications, further streamlining the replacement process.
Building Trust through Inventory and Customer Communications
LCRR-compliant inventory is due by October 16, 2024, and water systems must post their inventory online (for systems serving over 50,000 customers) by this deadline. Utilities must also notify residents about any lead, galvanized requiring replacement or unknown lead status service lines that need replacement by November 15, 2024.
These notifications must be mailed physically, and not sent electronically. The state regulatory agencies will provide templates, but utilities should also consider proactive, visual communication methods to ensure that residents understand the implications.
Communicating with the public on lead-related issues is crucial for building trust. Utilities can start with consumer confidence reports (CCRs) to ensure transparency and compliance with the EPA’s expectations.
Replacement Communication
The LCRI requires a utility to make at least four attempts to offer to replace a service line. Utilities need to track these communication attempts.
Utilities should also prepare flyers and door hangers explaining the replacement process and offer clear instructions for residents before and after the service line replacement. Community outreach programs, such as door-to-door campaigns and community meetings, are the most effective ways to gather replacement signups and build trust.
By focusing on these key areas—inventory accuracy, securing funding, proactive communication, and effective tracking—you can meet regulatory requirements and build trust within your community.
Staying ahead: What to do Beyond the Deadline
To ensure the success of lead service line replacements and compliance with the LCRI, utilities must shift from partial to complete service line replacements, all while establishing post-replacement safeguards such as filters and sampling. These critical measures should be routine by 2027, helping protect public health while ensuring regulatory compliance.
Service Line Replacements and Inventory Updates
One of the biggest challenges in meeting replacement targets is having an incomplete inventory of service lines. For example, if a utility aims to replace four hundred service lines per year but only knows the location of two hundred, it will face difficulty meeting the target. Therefore, reducing the number of unknown service lines by October 2027 is essential to avoid delays or setbacks in future replacement efforts.
Machine learning (a type of predictive modeling) can assist in identifying unknown service lines, improving the inventory process, and supporting utilities in meeting their replacement goals. Predictive modeling can also streamline efforts, enabling utilities to focus on high-priority areas while reducing uncertainty in service line materials. More on that later
Sampling and Treatment Adjustments
In addition to replacements, proper sampling and treatment protocols are essential to reduce lead levels in the water system. Utilities should evaluate fifth-liter samples from lead service lines and make necessary adjustments to their treatment processes. If utilities exceed the lead action level (currently 15 ppb), a Tier 1 notification must be sent to all customers within 24 hours. This applies only to the 90th percentile, not individual samples.
Proactively practicing and refining these compliance efforts will help utilities meet the required 3-day turnaround for notifying customers of elevated lead levels by 2027–2028. Early action in sampling and treatment will minimize disruptions and ensure that lead levels remain within safe limits.
School Sampling Initiatives
Another crucial aspect of lead reduction is initiating sampling programs in schools. Through collaboration with local schools, utilities can take advantage of grant programs such as the Water Infrastructure Improvements for the Nation (WIIN) Grant, which provides funding for lead testing. Sampling conducted from 2021 to the present will help reduce the number of schools the utility is responsible for sampling by 2027, easing the burden of compliance while ensuring safer environments for children.
By taking these steps—moving toward complete service line replacements, refining sampling and treatment processes, and leveraging school sampling programs—utilities can meet their long-term compliance goals while protecting public health.
Predictive Modeling: Why it Matters in LCRR and LCRI, and How it can be Helpful
Predictive modeling serves as a game-changer for utilities, streamlining field verifications by pinpointing high-priority areas. This focused approach significantly reduces time and costs for utilities while ensuring compliance with key submission deadlines, such as those in October 2024 and 2027.
Predictive modeling is an iterative process in which the model is re-run alongside continuing field investigation. Here’s how it works:
If lead is not detected, statistical methods can be employed to quantify uncertainty and estimate with the upper limit of lead that could exist in the system, given that none was found in a representative sample of field verifications.
Starting predictive modeling (or using statistical methods) early is essential for reducing unknowns by 2027. While statistical methods can be useful for even small amounts of unknowns, machine learning models are the most useful for utilities that have more than a few thousand unknowns. This is because a portion of the unknowns need to be field-verified to support the model. Utilities with lead but only a small number of unknowns may fare better by field verifying all of their unknowns, rather than employing predictive modeling.
The following table contains some general guidance that Trinnex uses to help utilities understand is predictive modeling is right for their system.
Machine learning models predict the probability that an unknown service line is lead, and predictions are more useful when they are closer to 0% (low probability of lead) or 100% (high probability of lead). Over time, the iterative process of predictive modeling alongside targeted field investigations reduces the number of unknowns in the middle range of probabilities (for example, between 30% and 60%). When applying predictions to materials in the inventory, the thresholds for determining “non-lead” and “lead” can be tailored to the water system based on risk tolerance and/or regulatory guidelines, which vary by state.
Predictive modeling, especially when integrated into an all-in-one solution, saves both time and money by directing efforts where they are needed the most.
The next decade marks a critical period in the fight against lead contamination. By embracing the LCRR and proposed LCRI, utilities can work toward building healthier communities and ensuring that all Americans have access to clean, safe drinking water. While challenges remain—especially in managing unknown service lines and navigating complex pipe classifications—the comprehensive and phased approach outlined by the LCRR and LCRI provides a clear roadmap to a lead-free future.
