Dear Aqua Answers,
I submitted the Lead Service Line Inventory (LSLI) for my water system in October 2024, as required. We were unsure of the construction materials used in some service lines. So, there are some unknowns. Why do I still need to refine my inventory? I heard that unknown line materials are bad. Why?
Please help.
Thanks,
Lea D. Line
Dear Lea,
Thank you so much for submitting your initial Lead Service Line Inventory (LSLI) last year. We understand that many systems do not know all the construction materials used in all their service lines. The Lead and Copper Rule Improvements (LCRI) finalized by EPA in 2024 requires ongoing effort to identify service line construction materials and submitting a baseline service line inventory, including connectors, by November 1, 2027. This inventory is different than the initial inventory submitted in 2024. The baseline inventory submittal will establish your system’s baseline for identifying, prioritizing, and replacing lines that contain or may contain lead.
Under the LCRI, each system must track its progress by calculating a service line replacement rate, which is based on the number of lead, galvanized requiring replacement (GRR), and lead status unknown service lines identified in the baseline inventory. The required Lead Service Line Removal (LSLR) calculation method and required percent removals of lead lines may jeopardize future compliance if you have a high number of unknown service lines that are later confirmed to be non-lead. This lowers the total number of lines in the replacement pool without crediting overall progress in identifying service line materials. This structural flaw risks forcing systems to meet unrealistic replacement rates and/or face non-compliance, even when they have effectively removed all known lead or GRR service lines or ultimately determine all unknown service lines to be non-lead. Customer refusals to allow service line material identification or line removal will also heavily influence system compliance into the 2030s.
This means that unknown service lines are bad for future compliance with LCRI. CDPHE will be communicating with EPA about these concerns and seeking additional flexibility.
What can you do in the meantime? Make as much progress as possible on your system’s service line (and connector) inventory before the baseline inventory is due on November 1, 2027. Try to reduce the number of unknowns, especially by 2030.
The division continues to support water systems serving up to 15,000 persons by offering technical assistance provided by WSP. The program is currently operating on a wait list, and suppliers can sign up here to be contacted by WSP in the event that the division is able to provide additional funding for the program. Enrolled suppliers can request remote support or hands-on assistance, offered at no cost. The division has selected only one contractor to provide technical assistance to eligible water systems, and it will not reimburse systems for the costs of hiring outside contractors. Waitlisted suppliers should continue to work on their inventories while they await potential additional funding for the program.
In addition, the division has a team of drinking water coaches available to help you with LSLI project management. Our team can coach your system as you:
Identify and navigate grant and loan funding for service line identification and replacement
Navigate regulatory requirements, including inventory templates, communications tools, public notice and drinking water portal
Draft and update your LSLI
If you are interested in working with one of our coaches on your LSLI please fill out a coaching request form, and one of our coaches will reach out to assist you and your team.
Thank you for your efforts to identify service line materials in your water system.
Sincerely,
➽ Aqua Answers
