Summary of Applicable Schedule Requirements For The Final Lead and Copper Rule Improvements

On October 16, 2024, the U.S. Environmental Protection Agency (EPA) promulgated the final Lead and Copper Rule Improvements (LCRI). The LCRI changes the lead and copper tap sampling process, lowers allowable lead limits, and sets a replacement timeline for all lead service lines.

The LCRI applies to all community water systems (CWS) and non-transient non-community water systems (NTNCWS). CWS are public water systems that serve at least 15 service connections used by year-round residents or regularly serve at least 25 year-round residents. NTNCWS are public water systems that are not CWSs and that regularly serve at least 25 of the same persons over six months per year.

The final LCRI builds on the original Lead and Copper Rule (LCR) from 1991 and the Lead and Copper Rule Revisions (LCRR), finalized in 2021, by strengthening five main focus areas:

  • Locating legacy lead pipes;
  • Achieving full lead pipe replacement within 10 years;
  • Improving tap sampling;
  • Lowering the lead action level; and
  • Strengthening protections to reduce lead exposure

Under 40 CFR § 141.80(4)(i), public water systems must continue to comply with certain provisions of the LCR and LCRR until the new LCRI compliance date, which is November 1, 2027.

Below is a list of deliverables for water systems, as they relate to the LCRR

System RequirementsCompliance Date
Submission of Initial Lead Service Line Inventory.October 16, 2024
Notification to customers of known or potential service lines containing lead.Within 30 days of completion of the Initial Lead Service Line Inventory.
Submit annual certification to the Department that the system provided notification and delivered lead service line information materials to affected customers with lead, galvanized requiring replacement, or unknown service lines for the previous calendar year with a copy of the notification and information materials.July 1, 2025, and then annually by July 1 until no lead, galvanized requiring replacement, or unknown service lines remain on the system's inventory.
Annual repeat notification to customers of known or potential service lines containing lead, unless the entire service connection is no longer lead, galvanized requiring replacement, or unknown.December 31, 2025, and then annually by December 31 until no lead, galvanized requiring replacement, or unknown service lines remain on the system's inventory.

Below is a list of deliverables for water systems, as they relate to the LCRI

System RequirementsCompliance Date
Submission of Baseline Inventory, to include all service lines and connectors.November 1, 2027
Notification of known or potential service lines containing lead and repeat notification on an annual basis until the entire service connection is no longer lead, galvanized requiring replacement, or unknown. For new customers, water systems must also provide notice at the time of service initiation.Within 30 days of completion of the Baseline Inventory, and then annually by November 1, until no lead, galvanized requiring replacement, or unknown service lines remain on the system's inventory.
Submission of Service Line Replacement Plan for lead or galvanized requiring replacement service lines.November 1, 2027
Submission of list of schools and childcare facilities within the system's service area (for CWS only).November 1, 2027
Submit a revised site sampling plan, a list of tap sampling sites for water quality parameters, and the tap sampling protocol that is to be provided to individuals who are collecting lead and copper tap samples.January 1, 2028
Submit annual certification to the Department that the system provided notification and delivered lead service line information materials to affected consumers with lead, galvanized requiring replacement, or unknown service lines for the previous calendar year with a copy of the notification and information materials.July 1, 2028, and then annually by July 1 until no lead, galvanized requiring replacement, or unknown service lines remain on the system's inventory.
Submit a revised inventory, to include all service lines and connectors, until such time as there are no lead, galvanized requiring replacement, or unknown service lines.January 30, 2029, and then annually by January 30 until no lead, galvanized requiring replacement, or unknown service lines remain on the system's inventory.
Submit a certification that there have been no updates to the Service Line Replacement Plan, or, if there have been updates, submit an updated Service Line Replacement Plan.January 30, 2029, and then annually by January 30 until no lead, galvanized requiring replacement, or unknown service lines remain on the system's inventory.
Submit documentation to the Department explaining why each service line requiring replacement was not replaced.January 30, 2029, and then annually by January 30 until no lead, galvanized requiring replacement, or unknown service lines remain on the system's inventory.
Submit a certification to the Department that the system offered to inspect service lines of customers who, within 30 days of receiving the customer notification, suspected the inventory incorrectly categorized their service line material.January 30, 2029, and then annually by January 30 each year.
Full replacement of all lead and galvanized requiring replacement service lines.By November 1, 2037.
Last Modified: Monday, Oct 20, 2025 - 03:38pm