The Finer (and Funding) Details of Lead & Copper Rule Revisions Compliance

The clock is ticking for drinking water utilities to comply with the Lead & Copper Rule Revisions (LCRR). While it is a significant undertaking for communities to inventory lead service lines (LSLs) and develop a replacement plan by October 16, 2024, these are key steps to mitigate lead exposure and its associated health risks for the public. Luckily, agencies don’t have to do it alone. Woodard & Curran’s drinking water experts have been working with clients across the country to catalogue LSLs and create a plan for replacement, as well as secure funding for this work.

The Environmental Protection Agency (EPA) recently released $30 million in grant funding under the Water Infrastructure Improvements for the Nation (WIIN) Act specifically for disadvantaged communities and schools. This aligns with the Biden-Harris Administration’s Justice40 Initiative, which seeks to deliver 40 percent of benefits from certain federal investments to historically marginalized communities. Our client, the city of Fall River, Massachusetts, received $10 million under this program for LSL replacement.

With funding available at both the state and federal level, our funding team is constantly monitoring available programs to help our clients undertake this critical work. Of the $5 billion we have secured for clients to date, we have helped secure $1.2 million in grants and 100 percent principal forgiveness loans specifically for LSL inventory and replacement planning projects. We expect more monies will be funneled into state revolving fund (SRF) and other programs across the country. Our funding specialists are collaborating with our technical experts to ensure our clients are best positioned to secure funding and defray passing the cost to their communities and ratepayers.


Rob Little Practice Leader Drinking Water

View All Posts

Funding Secured for Clients to Date

$5 Billion


$1.2 Million

LCRR-Related Work

A treasure hunt without the map

The LCRR sets out to address a major public health concern. However, utilities face an uphill battle. It was commonplace to use lead pipes in construction between the 1950s and 1980s, and yet thorough records of distribution systems, and particularly service line assets, are often nonexistent. Even for small water distribution systems, identifying LSLs, tracking the assets, planning for replacement, and executing the plan can be a large undertaking. While there is no one-size-fits-all approach for this work, we have the expertise to customize solutions for our clients across the country. Whether the approach is boots-on-the-ground physical asset inspection, utilizing the latest artificial intelligence and machine learning tools, or a combination of the two, we are here to help.

In Lawrence, another historically disadvantaged Massachusetts community, Woodard & Curran has been working with officials for the past 15 years to replace LSLs and associated water mains. This partnership helped the city capture data on private-side service line materials during a meter replacement program, giving the water department a head start on its LSL inventory.

A thorough investigation of historical records in Andover, Massachusetts, left approximately 1,300 water services for which the material was “unknown.” Under the LCRR, these unknown assets must be considered lead until proven otherwise, especially given the fact these premises were built within the aforementioned timeframe. In partnership with the town’s water division, we are working to conduct site visits to visually inspect each unknown service line, identify its material, and document the size, condition, and point of entry. This requires water customers to schedule an appointment by phone or online so our staff can meet with them at their convenience and conduct the inspection quickly, easily and in a cost-effective manner.

Previous state-specific regulations (e.g. California) required drinking water systems to compile an inventory of known partial or total “user service lines,” defined as the portion between the water main and the meter. Utilities that have this data are at an advantage, but the LCRR requires documentation of the pipeline between the individual meter and building inlet, as well, and digitization of data for ease of customer access. Many water suppliers will have to revisit their plans to determine the best approach to collect and report this new information. Systems with more than 50,000 service population will also have to provide online public access to this inventory data.

Public outreach and engagement is key

Many ratepayers probably don’t think twice where their water comes from or how it reaches their tap when they turn on the faucet or flush the toilet. Likewise, water suppliers often do their critical work to provide safe, clean drinking water while maintaining a low profile. However, this federal regulation and others, as well as modern times, require effective communication with consumers. In fact, the American Water Works Association has long recognized how important and beneficial it is to provide clear and timely communication to customers.

Beyond educating consumers about the LCRR, effective communication is critical to ensure water utilities can obtain permission to inspect and document assets on private properties. With an experienced communications team at our disposal here at Woodard & Curran, we are working with clients to plan, design, and execute public outreach and engagement strategies to boost relationships between the water agencies and their consumers. Time and time again, public utility transparency with clear communication has proven beneficial in garnering public support for infrastructure projects.

Still facing uncertainty

The proposed Lead and Copper Rule Improvements (LCRI) looms with many unknowns for water utilities. However, as we track federal legislation, we do not expect many of the LCRR requirements to change. The LSL inventory will likely still serve as the backbone of the overall initiative, so water suppliers should waste no time in documenting their assets. The EPA is still holding public meetings, accepting written comments, and engaging with stakeholders. The EPA intends to take final action on the proposed LCRI by October 16, 2024, the same date the LSL inventories and replacement plans are due. It may seem like plenty of time to do this work, but we are urging our clients to start now so that their careful planning will prove helpful in this major step to protect the health of the communities and populations we serve.

Scroll back to top of the page