The Time To Start LCRI Compliance Is Now

By Christian Bonawandt

Water utilities are currently in a dual-focus phase under the U.S. EPA’s Lead and Copper Rule Improvements (LCRI) regulation. Utilities must balance compliance with the older rules and rule revisions while working toward active replacement in 2027. In a recent Water Online Live event titled "From Inventory to Action: Navigating the Next Phase of LCRI Compliance," Chief Editor Kevin Westerling sat down with Lauren Wasserstrom, national practice lead for Lead and Copper Rule (LCR) compliance at Jacobs, and Kristin Epstein, Northeast U.S. LCR compliance coordinator at CDM Smith.

Together, they discussed the regulatory transition surrounding the LCRI, the burden imposed by unknown service lines, strategies for transitioning from compliance paperwork to active replacement programs, and critical funding mechanisms utilities must leverage before federal allocations expire.

Compliance Meets LCRI Readiness

Over the past several years, water utilities across the nation have poured significant resources into compiling service line inventories. However, as the deadline to start replacement approaches, they face a complex dual challenge: maintaining compliance with current LCR and Lead and Copper Rule Revisions (LCRR) requirements while preparing for the LCRI’s mandatory compliance date on November 1, 2027.

Wasserstrom emphasized that despite ongoing federal litigation surrounding the LCRI, the EPA is actively defending the rule, and public water systems cannot afford to adopt a wait-and-see approach. Furthermore, state agencies are establishing their own guidelines, often implementing standards more stringent than federal baselines.

“There certainly is nothing simple about this rule and every water system is at a different place, but for all systems, the LCRI is a significant multi-year undertaking, and it’s just too big of a lift to wait to prepare,” Wasserstrom stated.

She outlined the near-term compliance obligations utilities must execute while preparing for 2027:

• Annual consumer notifications. Water utilities that have lead, galvanized requiring replacement (GRR), or unknown service lines are required to deliver annual notifications to affected customers by December 31, 2026.
• State compliance reporting. Documentation of consumer notifications must be submitted to state primacy agencies by July 1, 2027 (or earlier if required by state regulators).
• New customer notifications. Service initiation notices need to be provided immediately to any new customer served by a lead, GRR, or unknown service line.

Epstein reinforced that readiness varies widely across both utilities and regulatory bodies, noting that state guidance documents continue to evolve. “Just because a state regulator says one thing in a meeting doesn’t mean that that’s what’s going to end up in the guidance document that comes out two months later,” she cautioned, urging utilities to maintain close contact with state regulators while initiating replacement conversations immediately.

The Math Of Unknown Service Lines

An audience poll conducted during the live broadcast showed nearly half (49%) of utility participants saw reducing unknown service lines as their single greatest LCRI challenge, followed closely by funding future service line replacements. Epstein explained that the anxiety surrounding unknown service lines stems directly from the LCRI’s regulatory formula. Under the rule, unknown service lines are legally presumed to be lead until proven otherwise. Beginning November 1, 2027, a utility’s mandatory annual replacement target is calculated using a strict mathematical equation:

Annual Replacement Goal = (Lead Lines + GRR Lines + Unknown Lines) / Years Remaining in Program.

This formula creates a significant compounding challenge for utilities that enter the compliance period with large volumes of unknowns. “If let's say you have 10,000 unknowns in your inventory, that is going to say that you need to do 1,000 additional replacements that year to meet the LCRI,” Epstein warned. “You may have 10,000 unknowns and only 100 lead service lines. So, you can't possibly replace a thousand in a year.”

To systematically reduce unknowns before the baseline inventory deadline, the panelists recommended five strategies:

1. Standardize operational field tracking. Field crews must write down pipe materials during every routine maintenance event, curb stop repair, main break, or meter replacement. Work order systems should feature dedicated dropdown fields rather than unstructured notes.
2. Deploy customer self-identification with visual proof. Customers should be encouraged to submit photo verification of their water service line where it enters the building, with utilities using targeted outreach for properties with accessible basements, daylighted pipes, or crawl spaces.
3. Utilize statistical analysis for uniform non-lead areas. For areas strongly presumed to be entirely non-lead, utilities can perform statistically valid random sampling (with a maximum of 384 physical inspections for systems with over 1,500 unknowns) to verify non-lead status across the area with 99% accuracy and 95% confidence.
4. Apply predictive modeling and machine learning. For mixed-material systems, machine learning algorithms can analyze property age, building characteristics, spatial density, and historical records to assign a probability of lead to individual addresses, optimizing inspection and replacement targeting.
5. Conduct targeted physical inspection (potholing). While hydro-excavation or potholing remains the gold standard for visual confirmation, it is invasive and costly; utilities should reserve it to validate predictive models or resolve high-risk locations.

Wasserstrom added that the key is to start early and take things one step at a time. “The water utilities making that real progress aren’t waiting for every piece to be figured out before they start,” she said. “And they’re moving forward with where they can while at the same time working through that broader strategy for resolving unknowns.”

From Paperwork To Operational Programs

A central theme of the discussion was the difference between completing a compliance submission and building an operational capital program capable of executing full service-line replacements at scale.

By November 1, 2027, water systems must complete several key requirements, including:

• A comprehensive baseline service line inventory, incorporating connector materials.
• A detailed service line replacement plan detailing technical, financial, and operational execution strategies.
• Publicly accessible inventory and replacement data (required to be hosted online for systems serving over 50,000 people).
• A verified list of all schools and licensed childcare facilities within the service area.
• Applications for non-lead validation waivers, where applicable.

However, as Epstein explained, filling out a state compliance form by checking a box is vastly different from having an actionable implementation program in place. “It can be a year between conceptualizing a project and actually getting a contractor notice to proceed,” she said. “We cannot just on November 1st go, ‘Oh shoot, what do we do now to start these replacements?’ You have to be ready to start on November 2nd.”

Taking Advantage Of Unclaimed Capital

Looking more broadly at LCRI execution, both experts warned that utilities often underestimate the sheer administrative, cross-departmental, and financial overhead required. Wasserstrom noted that compliance spans nearly every internal department, including geographic information systems (GIS), engineering, field operations, legal, customer service, and water quality. It also requires external coordination with laboratories, health departments, contractors, and state regulators. Beyond physical pipe replacement, utilities face expanded compliance tap monitoring, revised sampling tiers, mandatory disturbance protocols, and complex data management obligations.

However, the panel was quick to highlight a major missed opportunity: unallocated federal infrastructure funding. Under the Bipartisan Infrastructure Law (BIL/IIJA) administered through State Revolving Fund (SRF) programs, federal grant allocations include 49% principal forgiveness, effectively providing grant funding for lead inventory and replacement projects.

Epstein urged all water utilities: “Get the free money. Don’t let that sit there.” She advised utilities that SRF applications do not require a completed inventory; predictive modeling or statistical estimates can be used to define project scopes and secure multi-year funding before state rollover windows close.

As Kevin Westerling noted at the close of the broadcast, “Inventories are no longer the finish line. They're the foundation for everything that comes next. The utilities that are best positioned for success will be the ones using this time to reduce uncertainty, build implementation programs, and prepare for long-term requirements ahead.”

Christian Bonawandt is an industrial content writer for Water Online. He has been writing about B2B technology and industrial processes for more than 25 years.