U.S. EPA releases guidance for compliance with lead pipe removal requirements

Key Takeaways

On August 21, the U.S. Environmental Protection Agency (EPA) released additional guidance for water systems to comply with the 2024 Lead and Copper Rule Improvements (LRCI). The guidance comes as water systems face a November 1, 2027, deadline to complete a baseline inventory of water service line materials and begin replacing service lines. The guidance provides further directions on how to assess, identify and access service lines to comply with the rule.

View access guidance       View inventory guidance

Background

Originally finalized in 1991, the Lead and Copper Rule regulates the presence of lead and copper in drinking water systems. Both substances are considered contaminants under the National Primary Drinking Water Regulations, and for lead, there is no safe level of exposure. In 2021 and 2024, EPA published major revisions to the rule – known as the Lead and Copper Rule Improvements – which required water systems to first inventory and then fully replace lead service lines within 10 years. NACo engaged EPA throughout the rule’s development and provided input on how EPA could make implementation feasible and effective for county-owned water systems.  

County role

Water systems were required to complete initial inventories of service line materials by October 16, 2024, with a full baseline to be completed by November 1, 2027, when the rule comes into effect.  The rule provides very few exceptions to the replacement requirements, but water systems are only required to replace service lines when they are under the control of the water system. The rule provides some flexibility for water systems with fewer than 3,300 customers but the final rule removed a deferred deadline for water systems that must replace more than 10,000 service lines per year.

Counties work to uphold drinking water quality standards for residents as owners, users and regulators of drinking water infrastructure. They are core partners with states, other local governments and EPA to achieve the goals of the LCRI and protect public health. The guidance provides more insight into how EPA defines access, including by acknowledging that water agencies’ access could be limited by:

• State and local laws or regulations that constrain how and when water agencies can replace service lines,
• Lack of permission from private property owners who have non-compliant lines or  
• Physical access challenges that make replacement infeasible or unsafe.

The guidance expands clarity for counties as they scope and plan replacement of lead service lines. It also details classification and inventory strategies for counties and water agencies.  

Funding for counties

Counties rely on funding from the Drinking Water State Revolving Fund (DWSRF) to finance service line replacement projects. The 2021 Infrastructure Investment and Jobs Act (IIJA; P.L. 117-58) provided $15 billion for lead service line replacement projects and supported critical infrastructure projects nationwide. After IIJA expires on September 30, 2026, public water systems could face a funding cliff just as the LCRI replacement provisions come into effect. NACo has continuously engaged with congressional stakeholders and urged reauthorization of the DWSRF to reflect the level investment made by IIJA.  

In July 2026, the Senate began the program’s reauthorization process as part of the Water Resources Development Act of 2026 (WRDA 2026; S. 4949). The bill would authorize $16.5 billion for the DWSRF over 5 years. NACo supports the Senate’s WRDA 26 and urges Congress to swiftly pass state revolving fund reauthorization legislation. Continuing robust funding levels for the DWSRF is critical to ensuring water systems can meet water quality standards for lead.

Next steps

NACo will continue to monitor the impacts of LCRI implementation on county-owned water systems and advocate for increased federal financial resources to support assessment and replacement operations. More information about the LCRI can be found here.