Challenges to the LCRI: What do they mean for you?

On November 25, 2025, the U.S. Court of Appeals for the D.C. Circuit to set a revised briefing schedule for the case of American Water Works Association (AWWA) v. Environmental Protection Agency (EPA).

The new schedule is: 

• Respondents' (EPA) brief: February 20, 2026 
• Respondent-Intervenors' (concerned stakeholders) brief: March 13, 2026 
• Amicus Curiae for Respondents' brief: March 13, 2026 
• Petitioner's reply brief: April 3, 2026 
• Deferred appendix: April 10, 2026 
• Final briefs: April 17, 2026 

Oral argument has not yet been scheduled. The LCRI remains in effect during this review period, and utilities should continue compliance planning and implementation. 

The Biden administration's LCRI, finalized in October 2024, requires nearly all lead service lines in the U.S. to be replaced by 2037 and the identification of any “unknown” service lines by the same deadline. It also lowers the allowable lead action level from 15 to 10 parts per billion among many other new requirements. It's the most significant update to federal lead-in-water standards in more than 30 years.

AWWA's lawsuit argues that: 

• The cost (estimated at over $100 billion) is excessively burdensome for water systems and could lead to higher water bills for households. 
• The mandate to replace service lines on private property is problematic, as "access" does not necessarily mean "control." 
• The 10-year replacement deadline is unrealistic due to potential worker shortages and logistical challenges. 

EPA has signaled its intent to defend the rule while developing new tools and guidance to support implementation flexibilities and provide regulatory clarity. This could mean future changes to timelines or requirements but for now, the rule stands. 

With the new court schedule established, water systems should stay the course on compliance. Key deadlines remain in effect: annual notifications are required by the end of 2025 and 2026, and baseline inventories, replacement plans, and updated sampling protocols are due by November 1, 2027. Replacement obligations also begin in 2027, requiring utilities to replace lead and galvanized requiring replacement service lines at a minimum average annual rate of 10%, with full replacement of both utility and private-side lines expected by 2037. 

In the longer term, we recommend water systems keep making progress on inventories (reducing unknowns), planning for compliance requirements in late 2027, and continuing any replacement programs that are underway or planned.