91����app

With the U.S. Environmental Protection Agency’s (EPA) Lead and Copper Rule Improvements (LCRI) now in effect, water systems across the country must prepare to meet the requirements by the November 1, 2027 compliance date. 91����app recently hosted an In the kNOW webinar featuring regulatory experts and utility leaders to help water systems prepare for these significant changes and tackle lead in drinking water. The session provided an overview of key compliance deadlines, funding pathways and a look at Wilmington, Delaware’s proactive approach—offering a roadmap for other utilities ready to get ahead.

Understanding LCRI requirements and timeline

Tugba Akgun, 91����app’ Northeast Practice Leader for Lead and Copper Rule Compliance, outlined the current regulatory landscape. The LCRI builds on the 2021 Lead and Copper Rule Revisions (LCRR), adding several new provisions designed to better protect communities from lead in drinking water, including:

• Baseline service line inventory, including connector materials and replacement plans due by November 1, 2027
• Lead testing at schools and licensed childcare facilities by October 31, 2032
• Validation of non-lead service lines by December 31, 2034
• Replacement of all lead and galvanized requiring replacement (GRR) service lines and identification of all unknown service lines by December 31, 2037
• Lowering of the lead action level from 15 micrograms per liter (µg/L) to 10 µg/L, along with revised sampling protocols, including fifth-liter sampling for systems with lead service lines
• Expanded public education and consumer notification

While aspects of the LCRI may continue to evolve at the federal level, any potential changes will take time. In the meantime, it is crucial for water systems to begin preparing now—while staying informed and ready to adapt to federal updates or state-specific requirements.

Spotlight: Wilmington’s early and holistic approach

Wilmington’s water system, serving over 100,000 residents, has taken significant steps toward early compliance. Kelly Slabicki, the city’s water division contractor, detailed a multi-pronged strategy:

• Proactive inventory: Wilmington launched an online self-reporting tool for residents to identify service line materials. City crews verify submissions and inspect lines during routine maintenance and capital projects.
• Coordinated replacements: Lead and GRR service lines are being replaced as part of broader infrastructure upgrades, minimizing neighborhood disruptions.
• Financial incentives: The city also offers subsidies and no-interest financing to homeowners for private-side replacements. A long-standing program provides a $1,000 reimbursement toward eligible replacements.
• Filter distribution: After replacements, residents receive free water filters and replacement cartridges, plus educational materials including flushing instructions.
• Tap sampling: Wilmington collected first-and fifth-liter samples at lead service line sites to evaluate the impact of the new sampling protocol and lower lead action level.
• Corrosion control evaluation: The city also performed a desktop corrosion control treatment evaluation study to assess water quality and confirm alignment with the LCRI requirements.  

Funding the transition: Advocacy and flexibility are key

Mike Matichich, who leads 91����app’ financial services team, emphasized that successful LCRI implementation and replacement of lead and GRR service lines hinges on solid financial planning and creative funding strategies.

Wilmington secured more than $70 million in principal forgiveness under the Bipartisan Infrastructure Law (BIL), including nearly $23 million for lead service line work. Advocacy played a critical role: Wilmington successfully pushed the state of Delaware to revise its definition of “disadvantaged communities,” enabling broader access to grant funding.

Other utilities may also benefit from programmatic approaches that allow multi-year funding applications. Salt Lake City, for example, secured a $40 million funding package from Utah, combining low-interest loans and principal forgiveness for the first five years of its lead service line replacement program. Early cost assessments and neighborhood-level demographic studies documenting the financial need of households in many parts of the City helped support its application.

What utilities should do now

Lauren Wasserstrom, 91����app’ national practice leader for lead and copper rule compliance, closed the session with practical takeaways:

• Continue to meet current LCRR requirements, including annual service line material notices and Tier 1 public notification requirements, while otherwise following existing Lead and Copper Rule provisions until the LCRI compliance date.
• Prepare for LCRI compliance submissions and requirements ahead of the November 1, 2027 compliance date:
  • Develop a baseline inventory and add connector materials.
  • Reduce unknowns in your service line inventory and begin validating non-lead classifications.
  • Develop a replacement plan, secure funding and establish risk mitigation procedures.
  • Identify school and childcare facility contacts and leverage existing state testing programs where available.
  • Develop and test compliance tap sampling protocols and assess results against the 10 µg/L lead action level.  
• Monitor evolving federal and state-specific requirements and coordinate with your primacy agency on compliance expectations and funding opportunities. 

The LCRI requirements are a significant undertaking, but systems that take action now will be better positioned to meet compliance deadlines, access available funding and protect public health – regardless of how future federal updates or state-specific requirements may evolve.