Lead and Copper Rule Revisions and Improvements

In November 2023, EPA announced updated changes to its Lead and Copper Rule Revisions (LCRR), called the Lead and Copper Rule Improvements (LCRI), which the Agency finalized in October 2024. Key elements of EPA’s new LCRI proposal include a new mandate to replace 100% of all lead pipes in ten years, a lowered lead action level, and new inventory and reporting requirements. Although the LCRI replaced the LCRR and modified specific requirements, there are provisions under the previous LCRR that remained unchanged and which systems should be prepared to meet by the initial October 16, 2024 deadline. A breakdown of the major timeline and requirements are shown below. Please note this is not an exhaustive list.

Starting October 16, 2024:

  • Initial service line inventories must be submitted to State’s primacy agency by this date. The inventory must also be made publicly available. Please note that even if your system has identified NO lead service lines, the inventory must still be submitted.
  • Begin customer notification outreach (within 30 days of inventory submission) for identification of lead, galvanized needing replacement, or unknown service lines.
  • Tier 1 public notifications for samples showing lead action levels above federal standards. Public must be notified within 24 hours of the system learning about the exceedance.
  • Associated reporting requirements.

Starting October 2027 (or three years after the finalization date of the LCRI):

  • Ten year lead service line replacement timeline to remove 100% of all lead pipes begins. Systems must complete replacements at 10% per year based on a 3-year running average. Very limited exceptions for additional flexibility are allowed.
  • Baseline lead service line replacement plan due.
  • In addition to annual notifications for customers with lead, galvanized needing replacement, and unknown service lines. PWSs will also now be required to conduct a validation process to ensure the inventory is accurate.
  • New lead action level lowered from 15 parts per billion to 10 parts per billion. Water systems with multiple exceedances within a specific timeframe will be required to provide water filters for customers as well as conduct additional pubic outreach

Resource Library for Local Governments

The EPA has published a set of suggested customer notification templates that includes required text as well as sample language that you may use. By law, every notification must contain a verbatim lead health exposure warning. Conference staff has consulted with mayors, city water practitioners, and subject-matter experts who advise that mayors should be proactive and consider adopting their own tailored notifications to assure the public that the utility is operating in compliance with all requirements. The resources available on this page are available to aid you in your customer notifications and public outreach efforts. Please note that some States may require prior approval for modified customer notification outreach and systems are encouraged to plan accordingly.

EPA’s lead and copper rule (LCRR) requires all public water systems (PWS) to submit an initial inventory of their water service line materials to state primacy agencies by October 16, 2024. PWS will then have 30 days, or until November 15, 2024, to notify every customer that has a known lead service line, galvanized requiring replacement (GRR), or a service line of unknown material. EPA reports there are 5.1 million service lines with known lead content, 1.7 million service lines with GRR, and 20.7 million lines with unknown material. PWS will be responsible for sending notifications to more than 30 million customers. More information regarding customer notification requirements includes:

  • All community water systems (CWS) and non-transient non-community water systems (NTNCWS) must comply with these requirements.
  • The initial water service line material inventory must include pipe material identification for both the utility and customer side of the service line.
  • The inventories must be accessible to the public, and for systems serving more than 50,000 customers, the inventory must be available online.
  • Notification content requirements differ depending on if the customer is serviced by a lead, GRR, or lead status unknown service line.
  • Systems must provide repeat notification on an annual basis and can only discontinue notification when the entire service line is no longer lead, galvanized needing replacement, or lead status unknown.

Several States and local governments have developed their own lead service line communications and customer notification templates for public water systems to utilize. Communities may want to reach out to their primacy agencies to see if a guide is available in their State. We have collected a few municipal and State examples for you to refer to. You can view them here.

Please note that some States may require prior approval for modified customer notification outreach and systems are encouraged to plan accordingly.

Federal law mandates the customer notifications include specific language and information, such as a statement outlining the health effects of lead exposure, steps to reduce lead exposure through drinking water, and information about opportunities to replace lead service lines as well as programs that provide financing solutions to replace the service line. Leading water industry practitioners have advised the Conference that in addition to the required elements of notifications, public water systems should consider adding in additional relevant information to better manage public risk communication. When applicable, local leaders should consider the following actions and incorporating the following information to their customer notifications:

  • Engage with Media and Community Organizations: Before sending out customer notifications, local leaders should consider reaching out to these key partners to ensure information reaching the public is accurate and timely. Conveying information such as why the notifications are being sent out, what types of efforts the utility is undertaking to meet ensure safe drinking water, and providing progress updates on inventory and lead pipe replacement goals can help better manage the discourse.
  • EPA Mandate to Remove all Lead Pipes: The customer notifications should include a statement alerting customers that this notification does not represent a public health threat, rather it is an informatory notice as part of the federal government’s effort to remove all lead service lines across the country. Identifying and locating the these pipes is a necessary first step in that process.
  • Corrosion Control Protocols: If applicable, the customer notifications should include a statement that the city’s municipal water supply is being by treated with proper corrosion control and that all sample lead levels meet federal standards. The existence of a lead or galvanized requiring replacement service line does not necessarily mean that lead is present in your drinking water.
  • Lead Pipe Replacement Plans and Costs: The customer notifications must include information regarding municipal efforts to remove lead service lines as well as financing opportunities to support these initiatives. Adding in the other relevant information surrounding costs, such as if the utility will be replacing pipes at no cost or what the average cost to replace LSLs on the customer side might be, provides customers with increased transparency to better assess their options and make informed decisions.
  • Municipal Health Department Information: Residents receiving these notifications may have additional questions regarding heath risks, local lead levels, and blood testing resources, concerns which may not be able to best addressed by the local water system. Including your municipal health’s department contact information in the customer notification letters can help best direct customers to appropriate resources and guidance.