Connecting Waterpeople

Lead & Copper Rule Revisions: catalyst for standardizing data management & simplifying SRF funding

About the blog

Megan Glover
CoFounder & CEO at 120Water.

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  • Lead & Copper Rule Revisions: catalyst for standardizing data management & simplifying SRF funding

The Lead and Copper Rule Revisions (LCRR), coupled with the enactment of the Infrastructure Investment and Jobs Act (IIJA)/ Bipartisan Infrastructure Law (BIL), creates an unprecedented opportunity for State Agencies to accelerate investment in drinking water infrastructure.

The vast majority of the IIJA/ BIL funds targeting drinking water infrastructure are being funneled through each State's SRF, particularly through one-time-only special category funding ​​for the replacement of lead service lines.

For Regulators and SRF Administrators, these investments provide a unique opportunity to drive impact in their communities, educate utilities on the availability, accessibility and deployment of funds, and streamline the application process to improve accessibility for the most disadvantaged community water systems (CWS).

Many utilities struggle to dedicate resources to even apply for funding available to solve problems. With many water systems being under-resourced and understaffed, kicking off multi-year projects to comply with LCRR will be a big lift.

Focus on the development and maintenance of inventories

Based on 120Water’s experience supporting over 200 CWS’ service line inventory development, achieving a verified inventory is a multi-year effort that requires deep analysis of a CWS’ relevant and acceptable data sources, strategy for resource prioritization, and deployment of different verification tactics. With inventories due to State primacy agencies by October 16th, 2024, inventory development for every CWS in a state is critical to determine the appropriate deployment of funds for applicable service line replacement and/or remediation projects.

Many utilities struggle to dedicate resources to even apply for available funding for investment in drinking water infrastructure

Clearly articulate acceptable service line material verification tactics

Since few CWS will be able to achieve the service line inventory requirement through the records-informed inventory outlined in LCRR, states must clearly articulate different service line verification tactics that are accessible and relevant for CWS of all sizes and capacities. As noted in the revisions: “Any resource, information, or identification method provided or required by the State to assess service line materials…”.

Using predictive modeling will help in prioritizing where to confirm pipe materials but will not be a substitute for an inventory acceptable for compliance. So capturing the additional data points and verification method will be important.

Target the most in-need community water systems

With the vast majority of community water systems (CWS) serving populations of <10,000 people, many systems will struggle to develop competitive applications to fund their projects. Some struggles include: data quality and currency, personnel capacities, time constraints, and adequate education on available funding, among others. Ensuring that funded work will impact the most in-need populations – children under the age of 5 years old, low-income and historically disadvantaged populations – is critical to maximizing the impact of investment dollars.

Main takeaway

While individual assistance agreements have proven to be both efficient and effective for funding water infrastructure/capital improvement projects, other delivery mechanisms may be more appropriate to realize impact at scale on meeting various LCRR requirements, such as service line inventories.

States should consider the following to support all utilities: (1) primacy agencies and SRF agencies should openly collaborate on data needs to create inventories that become fundable replacement projects; (2) understand how many utilities in a state serve populations of <10,000 people, and what systems and processes can be streamlined and centralized to increase their access to SRF funding; (3) inventory and data standardization needs to start ASAP to have the data needed to distribute funding for replacement after initial inventories are due in October 2024.

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