In the U.S., an estimated 9 million service lines still contain lead that can end up in our drinking water. The EPA-proposed The Lead and Copper Rule Improvements (LCRI) aims to build a public inventory of lead service lines (LSLs), and replace 100% of LSLs by 2037, all while enhancing lead sampling and corrosion control, expanding public education, improving lead sampling in schools and childcare facilities, and improving communications.
Why Reducing Unknowns in LSL Inventories Matters
One of the first steps toward safer drinking water is creating a complete and accurate inventory of LSLs, a requirement under the LCRI. These inventories could include unknowns under LCRR, but with LCRI regulations now in effect, minimizing them is essential. Here’s what it helps with:
- Building Public Trust and Addressing Health Risks
Submitting inventories with a high number of unknowns can raise alarms about water safety, undermine public confidence, and tarnish a utility’s reputation. More importantly, unknown service lines may still contain lead, posing unmitigated health risks to the community.
- Meeting Compliance Standards
The upcoming LCRI, expected to take effect in 2027, requires utilities to replace unknown service lines at the same rate as known lead lines. A large number of unknowns could lead to unmanageable replacement obligations, placing utilities in a challenging position.
- Optimizing Replacement Plans
Accurate inventories allow utilities to focus on the lines that need attention first, allocate resources wisely, and create more effective and efficient maintenance schedules.
Even utilities that are confident they don’t have lead service lines must still submit inventories and clearly document service line materials. For larger utilities serving more than 50,000 residents, these inventories must also be made publicly available online.
Benefits of Reducing Unknowns
Minimizing unknowns in LSL inventories offers a host of benefits that ripple through public health, regulatory compliance, and public perception:
- Health Improvements: Reducing unknowns helps identify and eliminate potential sources of lead, protecting the most vulnerable populations, including children and pregnant women.
- Regulatory Confidence: Accurate inventories ensure utilities meet LCRR deadlines and set the stage for full LCRI compliance, avoiding costly or reactive measures.
- Stronger Public Confidence: Clear and detailed inventories demonstrate a commitment to transparency, boosting community trust in the safety of their drinking water.
Read more about reducing unknowns here: Securing Solutions to Unknowns Lead Service Lines (LSLs)
Effective Communication: A Key to Successful Compliance
Once utilities have submitted their lead service line (LSL) inventories, they are required to notify customers with lead or unknown service lines within 30 days of the October 16 deadline. Communication is essential for ensuring the success of LCRR compliance, and here’s how it plays a critical role:
- Meeting Regulatory Requirements
Utilities are required to inform customers about lead risks through physical mail, and they often supplement this with proactive communication methods such as flyers, webinars, and community meetings.
- Building Transparency and Trust
Honest and transparent communication helps build public trust. Customers should be informed about any unknowns in the inventory, and utilities should explain the steps they’re taking to address these gaps.
- Proactive Engagement
In addition to required notifications, utilities can share updates on water quality, replacement plans, and lead exposure prevention tips through Consumer Confidence Reports (CCRs) and other platforms.
- Collaborating with Stakeholders
Partnering with schools, health agencies, and community organizations strengthens the communication process, raises public awareness, and increases operational efficiency.
Tailored Communication Strategies
To effectively reach communities, utilities should adapt their communication strategies to reflect local demographics, needs, and concerns. Underserved neighborhoods, which often have higher numbers of lead service lines, may require targeted outreach. Additionally, materials should be translated for English-as-a-Second-Language (ESL) populations. Digital tools like leadCAST can help track communication touchpoints, manage outreach efforts, and create public portals for easy access to information.
Focusing on the Source of Lead
Clear communication should emphasize that lead typically enters drinking water through pipes and fixtures, not at the treatment plant. Utilities should provide guidance on how to identify lead service lines and reduce exposure. Larger utilities can make LSL inventories available as interactive maps, enhancing transparency and encouraging collaboration with property owners.
Challenges and Solutions
Managing communication and data tracking manually can be overwhelming, especially for larger utilities. Tools like leadCAST simplify these tasks with features such as communication tracking, public portals, and mapping systems. These tools help ensure compliance, streamline outreach efforts, and enhance public engagement, making it easier for utilities to keep their communities informed and involved.
Read more about building public trust through communications here: Embracing Safety, Alerting the Community
Updates to Tap Sampling Requirements: What You Need to Know
The Lead and Copper Rule Improvements (LCRI) bring updates to the way tap sample sites are selected, aiming to prioritize locations most likely to have higher lead levels. These changes will take effect starting in 2028, marking the first compliance period under LCRI. Here’s a quick overview:
- 90th Percentile Calculation: The calculation now puts more weight on samples from the highest-tier sites. For properties with lead service lines (LSLs), first- and fifth-liter samples are required, with the higher concentration counted towards the 90th percentile.
- Enhanced Sampling Requirements: New rules for sampling at schools and childcare facilities include the option for waivers. Utilities can apply sampling done since 2021 (with state approval) toward compliance if it follows EPA methods.
School and Childcare Facility Testing
Testing in schools and childcare centers is critical to protecting vulnerable populations, such as children. Here’s what’s changing:
- Timeline and Waivers: Sampling begins in 2028, with the ability to use pre-compliance sampling for exemptions.
- Collaboration and Outreach: Utilities are encouraged to collaborate with schools, PTAs, childcare centers, and community groups to ensure thorough sampling and clear communication.
Post-Replacement Sampling to Build Trust
Under LCRI, utilities must replace all lead and galvanized service lines by 2037. After each replacement, utilities are required to offer residents sampling within 3 to 6 months to ensure that lead is no longer present. This step helps build trust and proves that the replacements were effective.
Building Community Trust
To build and maintain public trust, utilities are encouraged to take the following actions:
- Update Sampling Instructions: Ensure they meet LCRI standards.
- Provide FAQs and a Point of Contact: Address questions clearly and promptly.
- Simplify Kit Distribution: Make it easy for residents to access sampling kits.
- Share Results Quickly: Communicate results as soon as they are available.
- Handle Exceedances Carefully: Be ready with customized templates for exceedance notifications.
- Partner with Community Groups: Work with local organizations and adjust communication to meet the cultural and linguistic needs of the community.
These updates will help utilities maintain transparency, protect public health, and ensure compliance with the LCRI.
Read more about sampling here: Mapping Paths for Sampling
Proactive LSL Replacement: A Step Toward Safer Drinking Water
The Lead and Copper Rule Improvements (LCRI) set a clear goal: replace all lead service lines (LSLs) by 2037. This shift from relying on lead level exceedances to proactively removing all lead and galvanized pipes aims to better protect vulnerable populations, such as children and pregnant women.
Challenges in LSL Replacement
While LCRI offers a strong roadmap to reduce lead exposure, a few challenges could impact its full implementation:
- Identifying Unknown Service Lines: Many utilities lack complete records of the materials used in customer-side and company-side pipes. Thorough inventories and inspections are key to identifying these unknowns.
- Funding Constraints: Although $15 billion has been allocated for LSL replacements, the total cost could exceed $90 billion, leading to potential funding gaps.
- Supply Chain and Workforce Shortages: The scale of replacements may place pressure on resources, causing delays.
Why Full Replacements Matter
The LCRI prohibits partial LSL replacements, except in emergencies or during planned infrastructure work. Partial replacements can temporarily raise lead levels, so the focus must be on ensuring complete replacements for the best health protection.
How Digital Tools Can Help
Digital tools like leadCAST are essential in overcoming the logistical challenges of LSL replacements. These tools help utilities by:
- Assigning and managing contracts
- Visualizing replacement progress
- Streamlining right-of-entry (RoE) form collection
- Ensuring quality assurance for inspections
Building Public Awareness and Trust
Public education and clear communication are vital to the success of LCRI. Utilities need to:
- Create tailored FAQs and communication materials
- Work with schools, childcare centers, and community organizations
- Respect cultural needs by offering multilingual support
By proactively replacing lead pipes and keeping communities informed, utilities can ensure safer water for everyone.
Read more about LSL replacements here: Overcoming Challenges in Lead Service Line Replacement
leadCAST: Streamlining LSL Replacement Programs
Digital tools such as leadCAST provide a comprehensive digital solution to support water utilities in reducing uncertainties, enhancing communication, managing sampling, and replacing LSLs. Let’s dive into the details.
Eliminating Unknowns with Precision
leadCAST enables utilities to identify and address unknown service line materials through predictive modeling and systematic tracking. By integrating state-approved inventory development tools, leadCAST ensures no service line is overlooked, paving the way for comprehensive Lead and Copper Rule (LCRR) and Lead and Copper Rule Improvements (LCRI) compliance.
Enhancing Communications and Engagement
Effective communication is critical for LSL replacement success, and leadCAST simplifies this process with its touchpoint tracking feature. Utilities can log and manage communication details, including program types, resident interactions, and responses, to ensure consistent and transparent engagement. Additionally, leadCAST’s public portal empowers residents to access service line information, order water tests, and submit inspection results. The platform's public map meets LCRR requirements for utilities serving over 50,000 residents, promoting transparency and fostering community trust.
Simplifying Sampling Efforts
Through a partnership with SimpleLab, leadCAST offers end-to-end tap sampling logistics, making it easier for utilities to comply with LCRR and LCRI requirements. This seamless integration ensures accurate sampling while reducing administrative burdens on utilities and residents.
Accelerating LSL Replacement
leadCAST streamlines every aspect of LSL replacement, from moving properties into the replacement pool to tracking progress visually. Right-of-entry (RoE) form management is simplified through a public portal, while in-app inspection capabilities, accessible on mobile devices, ensure efficient and high-quality replacements with built-in QA/QC functionality.
The journey toward LCRR and LCRI compliance is challenging but essential for safeguarding public health and building community trust. By prioritizing inventory accuracy, proactive communication, and effective tracking, utilities can meet regulatory requirements while ensuring clean and safe drinking water for all.
