Nearly 140,000 small public water utilities across the country are gearing up for the fast-approaching Lead and Copper Revisions (LCRR) deadline. While small utilities have traditionally faced several unique operational challenges, a few opportunities exist to quickly get on the right path towards LCRR compliance.
What we know about LCRR compliance requirements for small utilities
The Environmental Protection Agency (EPA) considers small utilities as systems serving less than 10,000 people. The LCRR, forthcoming in October 2024, applies to all utilities, but small utilities have some flexibility in meeting compliance. According to the EPA, small utilities must:
- Operate and maintain optimal corrosion control treatment (if currently in place) and meet any other requirements determined by the State, until deemed unnecessary
- Develop a service line inventory that’s accessible to ratepayers upon request
- Collect water quality parameters and make compliance option recommendation to the State following an exceedance of lead trigger levels
- Implement a full lead service line replacement program to start within one year of the State’s approval
- Install, maintain, and monitor point-of-use devices in each household
LCRR Input from small utilities
In 2021, the EPA reached out to the public to better understand the concerns with LCRR. Based on the feedback, the EPA established a Small Business Advocacy Review (SBAR) panel process. The EPA has a specific interest in “engaging with small entities in disadvantaged communities... to ensure that they do not disproportionately bear the burden of risks.” The SBAR recently had an open call for small utility representatives to join the panel. While the panel continues discussions, small utilities can leverage quick wins to get them closer to achieving LCRR compliance.
Three LCRR quick wins for small utilities
1. Expand inventory collection efforts to homeowners by leveraging self-reporting tools.
Self-reporting helps minimize the burden of inventory development by collecting enough data to indicate where lead material might exist and where to prioritize verifications. Self-reporting uses a web-based form with questions to help guide the homeowner in reporting their pipe material, similar to the screenshot here. As a bonus, a unified platform can house and maintain updated data from activities such as self-reporting and field inspections and can serve as a public-accessible inventory database.
2. Start with known at-risk areas to help prioritize field verifications.
Focus data collection efforts on your most vulnerable areas. You might also qualify for certain funding through the Bipartisan Infrastructure Bill. Collect data from self-reporting as well as paper records, property information, work orders, and so on. Find more information regarding top information sources for inventory development here.
3. Consider investing in software with built-in machine learning capabilities. It will pay off in the long run.
Investing in machine learning provides several cost-saving advantages. By connecting crucial data from various sources to help predict where potential lead material might exist. Machine learning can help improve the success rate of inspections by pinpointing the likelihood of lead density in a particular area based on several factors such as property age, diameter, etc.
Start your LCRR compliance program today
Don’t let the LCRR compliance deadline creep up on you. Small utilities don’t have to choose between risking maintaining daily operations to prepare for meeting LCRR requirements. Leverage technology built by engineers who worked on the unprecedented Newark, New Jersey Lead Service Line Replacement program. Schedule a 30-minute consultation to learn more.