Lead service lines: 3 key actions to take for lead and copper rule compliance
June 26, 2025
June 26, 2025
What happens after you¡¯ve submitted your initial lead service line inventory? Keep these tips in mind as we approach the next compliance deadline.
So, you¡¯ve created an initial lead service line inventory and submitted it to your state regulatory agency last October. (Hopefully.) Now what??
Many public water system owners in the US worked hard from 2021 to 2024 to comply with the Lead & Copper Rule Revisions (LCRR). As of October 2024, in its current form, the rule is now known as the Lead & Copper Rule Improvements (LCRI).?
You may know that the next compliance deadline is November 1, 2027. But what exactly is due at that time? How can you be sure you¡¯re complying with the requirements??
We¡¯ve worked closely with many water utilities in the US of all sizes, across several states and geographic regions. We¡¯re deeply familiar with the ins and outs of all things related to lead service lines and regulatory compliance. We want to help our water utilities make it to the finish line in 2027 and beyond for replacing lead service lines.
For a baseline lead service line inventory, it¡¯s important for water utilities to reduce as many ¡°unknowns¡± as possible prior to November 1, 2027.
Before joining Âé¶¹´«Ã½, I worked at the Boston Water and Sewer Commission. I started as a field engineer and progressed to deputy director of engineering. I oversaw the design division and managed projects involving the replacement of water mains, sanitary sewers, storm drains, and lead service lines. I helped develop plans for the initial lead program in Boston. It¡¯s been great to bring that public sector experience to my job here, because I feel like I understand the nuances and challenges that our clients face. I know that clients have concerns other than lead. These include aging infrastructure, capital programming, and maintaining the reliability and operations of their systems.
When it comes to compliance, here¡¯s the tricky part. The regulatory landscape remains uncertain and varied among state agencies. Even though we have the 2027 compliance deadline, we could see some pullback on certain LCRI elements and inconsistent requirements by state. It¡¯s possible that Congress could repeal parts of the LCRI, which would alter requirements and compliance dates. The industry did just experience changes to a similarly ¡°hot topic¡± regulation related to PFAS.?
Recently the U.S. EPA announced its intention to scale back the PFAS regulation. We also saw that the government plans to extend PFAS compliance deadlines from 2029 to 2031. A draft of this rule revision will be published this fall, with a final version published in spring 2026. So, there is a precedent for the LCRI to change as well.?
But we, along with industry experts and organizations such as the American Water Works Association, agree that it¡¯s best to move forward assuming that the LCRI will remain in place. Even if it¡¯s scaled back to the LCRR, there would still be compliance elements that will remain for public water systems and require a lot of effort.?
There may be uncertainty, but that doesn¡¯t mean we stop working toward compliance. Here are three ways to keep preparing for LCRI compliance:?
1.?Keep communicating with state regulators
Maintain communication with your state regulators (different states have different requirements). We see that state governments are communicating with utility owners in a variety of ways. We recommend you do your due diligence and reach out to your state regulator and know or learn about what questions to ask.?
We help our clients schedule meetings with those regulators. For the City of Tarpon Springs and the Toho Water Authority, we held meetings with the Florida Department of Environmental Protection. In Massachusetts, we¡¯ve worked with multiple clients to schedule funding meetings with MassDEP. And in Jackson, Mississippi, we¡¯ve met with the Mississippi State Department of Health on many times.?
The goal of these meetings is to confirm or discuss any state requirement alterations to the rule, discuss and identify funding sources and application processes, and gain approval from state regulators for the public water system¡¯s approach. These approaches outline:?
Specific categorizations of service line materials not explicitly covered in the LCRR/LCRI.
Having a robust lead service line inventory with as many reduced unknowns as possible will allow you to be prepared for compliance with both the LCRR and LCRI.
2.?Continue to reduce unknowns and plan for replacement?
Water utilities were already asked to submit an initial lead service line inventory. Next will be a baseline inventory; with that, there will be a lead service line replacement plan.?
For the baseline inventory, your main objective should be reducing as many ¡°unknowns¡± as possible prior to November 1, 2027. This will have an impact across many compliance components, such as reducing the number of yearly customer notifications. Many utilities have already started a field inspection program that checks service line materials at unbiased and representative addresses within your service area. If you haven¡¯t, we recommend not delaying that any further. We have found that using a field inspection program with statistical analysis/predictive modeling can help utilities greatly reduce their total number of unknowns.
For the replacement plan, there are a lot of components (nine to be exact). Each of these components can be found on page 3 of the EPA¡¯s .
Some of the details could shift with regulatory changes, but big-picture planning will still be essential.
We¡¯ve worked with the Town of Norwood, Massachusetts, through several phases of LCRR and LCRI compliance since 2020. Our current activities include the resolution of unknown service lines in the working inventory through an inspection and meter-replacement program. We¡¯ve also worked with the Town to conduct several hundred service line replacements per year through a robust water conveyance system improvements program. This effort allows our team and the Town of Norwood to remove lead service lines once they¡¯re identified. We also focus on old, typically failing iron service lines that have a lead gooseneck connector at the main.
Documenting the service line material during this program allows us to see the material both inside the home and near the water main (also known as multipoint verification) for all service lines that are discovered. We can then capture materials and advise that lead service pipes be replaced as quickly as possible.
Don¡¯t scramble! Break up the compliance pieces into well-planned phases. Give plenty of time for each phase so that work is done thoroughly and thoughtfully.
3.?Use a phased approach for regulatory compliance
This process will take time. It will include multiple steps. Our advice? Create a phased approach, which will map out your utility-specific timelines to accomplish all components of the LCRI.
The bottom line: Don¡¯t scramble! Break up the compliance pieces into well-planned phases. Give plenty of time for each phase so that work is done thoroughly and thoughtfully.?
So, what exactly do water utilities need to focus on? Well, first and foremost, focus on the elements that are due or begin on November 1, 2027. Also look at those that begin shortly thereafter on January 1, 2028. Here is a list to help guide you on your compliance journey:
November 1, 2027:
January 1, 2028
Author Brendan O¡¯Brien oversees a lead service line replacement in Jackson, Mississippi.
It¡¯s been rewarding to help clients prepare for compliance. I think back to when I worked with the City of North Port, Florida, where we achieved full compliance by October 2024. The project involved field inspections and statistical analysis; through mathematical analysis, we advised the city that they could claim their system was lead-free. I¡¯ve kept in touch with our client there since we achieved compliance, and I¡¯ll always remember their appreciation for our team¡¯s work.
Right now, the regulatory landscape remains uncertain. What we do know is that having a robust lead service line inventory with as many reduced unknowns as possible will allow you to be prepared for compliance with both the LCRR and LCRI. Whether elements are redacted or regulatory timelines are changed, we recommend regular communication with your customers and state regulators. Develop a planned approach for all compliance pieces. I wish you the best of luck on your compliance journey.