How to manage customer-owned service lines for LCRR compliance

Editor’s note: BlueConduit recently hosted a webinar around state-specific LSLI compliance and the upcoming inventory submission deadline of Oct. 16. In this series, we detail some of the questions we received. 

What can utilities do to convince customers to check the materials on their side of the line? What is EPA’s expectation or requirement in this regard?

When it comes to LCRR compliance, the inventory submission must include the materials on both the public and private side of the line. That can be easier said than done when it comes to classifying materials on the private side.

First, the good news: From the EPA’s perspective, they aren’t expecting all service lines to be known or have a material classification by October 2024. So, if you’re having difficulty classifying the material on the private side of the line, you can leave it as “unknown” and still be compliant in time for October. That said, the LCRI that is expected to come out later this year will have expectations around material classification and reduction of unknowns over the first seven years of the new guidance. So, the fewer unknowns you have by October, the better. 

If access to the private side is required to verify the material of the service line, there is guidance from the EPA for water systems to work with customers in identifying and reporting lead service lines, including examples of programs from other water systems 

In the meantime, we recommend using predictive modeling or statistical methods to first identify the likely materials of each service line (eg lead, non-lead, GRR, etc.). These predictions can help you then classify your service line materials, based on your state’s specific guidance. 

We’ve also talked to utilities that are struggling to get feedback from customers about their side of the line, making it difficult to classify materials for inventory purposes and reduce the number of unknowns. If you’re in the same boat and use Esri, you can use the LSLI app integration with 123 Survey to streamline feedback from the customer side. You can format your survey however you like, making it easy to gather feedback. 

In the end, it all comes down to having a robust customer communications plan. However you decide you want to receive feedback from your community, we recommend making sure it’s publicly available and in a variety of formats.

If you’re looking for help getting your inventory ready for October, BlueConduit can help. Our predictive modeling solutions for lead service lines create locally tailored, AI-driven models that reduce the number of unknown service lines in your system. Contact us to learn more or get started.

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