The U.S. Environmental Protection Agency (EPA) has released two guidance documents aimed at helping public water systems comply with the lead pipe replacement requirements of the Lead and Copper Rule. The documents, an Access Tips guide and a Service Line Inventory Tips guide, translate existing federal requirements into plain language, with worked examples meant to reduce confusion among utilities and state regulators as they carry out the 2024 Lead and Copper Rule Improvements (LCRI).
EPA opened both documents for public comment in April 2026 before finalising them this August, presenting the release as part of a broader effort to combine plain language guidance with federal funding and technical assistance for water systems working to remove lead pipes.
Identifying unknown service lines
Under the LCRI, water systems completed an initial inventory of service line materials in October 2024 and must submit a baseline inventory update by November 1, 2027, with annual updates after that. Most systems have until December 31, 2037 to resolve any lines still classified as “unknown.”
The inventory tips document lays out acceptable evidence sources beyond visual inspection, including construction and plumbing code records, documented statements from experienced water system personnel, and statistical or predictive modeling, including AI based models, when approved by a state primacy agency.
It also clarifies how systems can determine that a galvanized line is not “galvanized requiring replacement” by showing it was never downstream of a lead line, using neighborhood level records such as local ordinances that banned lead pipe installation during a given construction period.
Access barriers to replacement
The access tips document addresses a separate but related challenge: what happens when a water system cannot physically reach a service line to replace it. The LCRI requires replacement of lead and galvanized requiring replacement lines “under the control of the water system,” and leaves it to each system to determine, and document, when it lacks that control.
Common barriers include a property owner refusing consent after a documented “reasonable effort,” defined as four contact attempts using at least two communication methods, a local ordinance restricting excavation to periods of water main work, or a state law requiring the use of state contracted crews on a fixed schedule.
Worked examples in the document show how systems in these situations can remain in compliance while continuing to report the barrier and reassess access as circumstances change, such as new funding becoming available or an ordinance expiring.
Both documents sit alongside EPA’s wider push on lead in drinking water this year, including a redesigned lead.gov hub, a new children’s health StoryMap, and continued funding through the Real Water Technical Assistance program, part of nearly three billion dollars EPA announced in 2026 for lead pipe identification and removal.
