Regulatory Alert: Lead and Copper Rule Revisions

October 2024 Deadline

The Lead and Copper Rule Revisions (LCRR) were issued in December 2021 to better protect communities from exposure to lead in drinking water by improving sampling and initiating more lead service line replacement. In August 2022, the Environmental Protection Agency (EPA) released guidance for municipalities regarding compliance with the LCRR. The guidance provides information for preparing and maintaining an inventory of service line assets by October 2024 to identify those service lines where lead levels exceed safe parameters for replacement. Municipalities covered under this rule should immediately begin planning, budgeting and securing available funding to support this effort. Essentially, the LCRR requires communities with a certain level of lead service lines to actively plan for their replacement in the coming years.

What is the Lead and Copper Rule and What is the Revision?

In 1991, the EPA established the Lead and Copper Rule (LCR) to mitigate exposure to lead in drinking water through monitoring at the tap. Most lead exposure occurs due to water coming into contact with lead pipes, faucets, and other plumbing fixtures. Lead service lines (LSLs), or pipes that connect homes to water mains, are more common in older cities and homes, specifically those built before 1986. The latest LCRR revisions specifically cover developing and maintaining a service line inventory and economically removing and replacing LSLs from our water systems.

Inventory of Service Line Assets

The EPA’s Lead Service Line Inventory guidance covers the development of an inventory as well as outreach and communication to the public. To assist municipalities, the guidance also contains an inventory template and case studies, and stresses priorities for schools, childcare facilities and disadvantaged communities. 

Preparing to meet the EPA Deadline

The Safe Drinking Water Act Lead Ban in 1986 resulted in a shift to copper, galvanized steel or PVC pipe, but unfortunately, millions of LSLs still exist today. The inventory required by the LCCR will identify those LSLs and help utilities in prioritization to replace them. Fortunately, funding is available to assist communities in this effort, including funds from the American Rescue Plan and Infrastructure and Investment Jobs Act (IIJA) and individual state funding. The key to complying with the LCRR is to get started without delay.

CHA has been helping clients develop funding applications and secure funds for LCRR-related work. CHA also has experience developing an LSL Inventory which could help utilities develop their inventory on time and in a cost-effective way. The inventory database can then be used smartly and effectively for LSL replacement-related prioritization work.