JEO Helping Communities Get the Lead Out

The Environmental Protection Agency (EPA) rolled out new regulations for its existing Lead and Copper Rule (LCR) policy. These updates require public water systems to complete an inventory of all water service lines within their jurisdiction to help identify lead or lead-contaminated water service and supply lines. This information will be useful to public water systems as they plan for long-term replacements of those lines. It is important for public water systems to understand all the requirements that fall under this policy, which include public outreach, engagement, and education, as well as developing and maintaining a service line inventory.

Community Responsibilities as Part of Lead and Copper Rule

The water system must:

• Identify and maintain detailed records of the material of every water service line in the system. This includes both the public (PWS-owned) and privately owned pipes, as well as their connectors.
• Keep inventories current with annual updates through 2037, incorporating new data from maintenance, inspections, or construction. This inventory data must be submitted to state regulatory agencies and be available to the public either online or by request.
• Notify property owners/customers if their service lines have been identified as lead or potentially lead contaminated galvanized. Additional annual notifications are required for unknown materials on service lines.

Lead and Copper Regulations

Initial Inventory Requirement (Deadline 10/16/24)

Under the EPA’s Lead and Copper Rule Revisions (LCRR) which went into effect in 2021, public water systems were required to submit their initial lead service line inventory to state primacy agencies by October 16, 2024. This inventory identified the material of service lines throughout each system on both the public water supply side and the private water service line side.

Upcoming RequirementS And Deadlines

Baseline Service Line Inventory Update – Due November 1, 2027

Public water systems must update their service line inventories to continue removing unknown service or supply line materials and must include connector materials. Connectors must be classified as Lead, Non-lead, Unknown, or None. Inventories should also include an address/location ID (if available) and report totals for service line types, lead and unknown connectors, and lead or galvanized requiring replacement (GRR) service line replacements.

Public water systems should also be working to verify and remove as many unknown service lines and connectors in their inventories prior to the November 2027 deadline as possible. Unknown service line materials and connector materials must be verified and proven not to be lead or galvanized requiring replacement materials before they can be removed from the inventory. The threshold to identify unknown service lines will increase following the submission of baseline inventory in November 2027.

Unknown service lines in a PWS inventory will also trigger specific sampling, notification, and replacement mandates according to the EPA regulation. Under the current regulation, ‘unknown’ lines are presumed lead until proven otherwise.

Service Line Replacement Plan – Due November 1, 2027 (if applicable)
If unknown, lead, or galvanized lines requiring replacement are identified, the Public Water System must also create a service line replacement plan documenting how they plan to remove 100% of the identified lines with a clear timeline, funding plan, and prioritized replacement strategy.

Long-Term Compliance Timeline

• Nov 1, 2027 – Submit Baseline Service Line Inventory and Replacement Plan (if applicable).
• Within 30 days – Provide initial public notification of service line material and annually thereafter.
• At service initiation – Notify new customers of service line material.
• Jan 30, 2029 – First annual inventory update due; then annually thereafter.
• Dec 31, 2034 – Complete inventory validation of non-lead service lines.
• Jan 30, 2035 – Final validation report due.
• Dec 31, 2037 – Complete full lead service line replacements.
• Jan 30, 2038 – Final replacement report due.

*Dates reflect EPA timelines. Deadlines may vary by state. Individual states may have additional and varying deadlines of their own.

Leading the Way

Understanding the Lead and Copper Rule: What Communities Need to Know and Do

The updated Lead and Copper Rule requires communities to identify, track, and replace lead or potentially lead-contaminated water service lines, especially in properties built before 1987.

Strict deadlines are in place: initial inventories (2024), baseline inventories and replacement plans (2027), and full replacement of lead lines by 2037, with ongoing annual inventory updates starting in 2029.

The process can be complex and costly, but federal funding (including $15B from the Bipartisan Infrastructure Law) is available to support compliance.

Successful implementation depends on strong community engagement, accurate data collection, and coordinated planning, often requiring expert support to manage inventories and large-scale replacements.

Learn more HERE.

Experience in both Inventorying and Replacements

Since 2022, JEO has been working with communities of all sizes to help identify the lead-contaminated pipes that connect water mains to homes and businesses. We’re already helping communities replace them with safer materials.

Learn more about our work in LSLI and LSLR HERE.

LSLI and LSLRDownload

Helping Communities Get the Lead Out

JEO is equipped to help with all aspects of Lead Service Line Inventory (LSLI) and Lead Service Line Replacements (LSLR). Turnkey or custom, we got you covered:

All things lead:

• LSL Program Administrator
• Public Education

Additional Resources

• Lead and Copper Rule & Revisions Overview: A comprehensive review of the most recent action taken to improve and expand upon existing LCR policy.
• EPA Lead and Copper Rule Implementation Tools: The EPA has curated a list of resources to help states and water utility departments to implement the LCR.
• EPA 3T’s for Reducing Lead in Drinking Water Toolkit: EPA’s 3Ts – Training, Testing, and Taking Action – Information and recommendations to prepare schools, child care facilities, and states to build a voluntary implementation program to reduce lead levels in drinking water.

EPA’s Final Lead and Copper Rule Improvements
Technical Fact Sheet: Service Line Inventory and Replacement Requirements

final_lcri_fact-sheet_service-line-inventoryDownload

EPA’s Final Lead and Copper Rule Improvements
Technical Fact Sheet: Inventory Validation

final_lcri_fact-sheet_validationDownload

For more information about the LCRR or this JEO service, please reach out to our “JEO Helping Communities Get the Lead Out” project team members: hsalmi@jeo.com, shaehn@jeo.com, bseachord@jeo.com