Is your utility ready for the LCRI? Lessons from Illinois's early experience

1. No more unknowns allowed
   Systems with known lead or galvanized service lines must return to standard monitoring with larger sample pool sizes every six months. Most importantly, under LCRI unknown service line materials are no longer allowed in sampling pools for tiers 1-4.

2. Fifth liter sampling
   In addition to the traditional first-draw sample, utilities need to collect a fifth-liter sample and use the higher lead level of the two results under LCRI. This creates new challenges for resident instruction and participation.

   "Residents who used to just fill one bottle—pretty simple to explain—now have to fill five bottles, and it can be confusing that we’re not even analyzing the middle three," Andrea says, emphasizing the need for crystal clear sampling instructions.

1. Response rates are low
   "We were seeing 10% response rates to cold calls and emails in some communities. We started to realize it's not common for people to pick up the phone these days, especially from an unknown number," she notes. Utilities need to plan for extensive outreach efforts with multiple contact methods.
2. Free sampling requests aren't overwhelming
   "We're typically encouraging residents in the compliance pool to fill out their samples and we still don't get a huge response. So when you're talking about voluntary sampling programs, a lot of people request kits but don't follow through," Andrea explains. "They just don't want to stagnate the water for six hours because it's understandably not convenient. I encourage utilities to offer free voluntary sampling because they usually won't get an avalanche of free sampling requests but it helps with transparency and building positive relationships with the community."
3. Communication must be multi-modal
   Utilities have just three business days to report results to residents, and for mailed letters, that means postmarked within three business days. Collecting email addresses and phone numbers, not just mailing addresses, will be essential. As volume increases, utilities will need efficient systems to track compliance with these tight timelines. Additionally, starting in 2026, utilities must account for USPS clarifications around delayed postal transportation to processing facilities where postmarking occurs. This means a sampling results letter may be postmarked on a different day than when it was mailed.

1. Premise plumbing materials
   Systems need to identify the plumbing materials inside homes, not just service line materials, for LCRI compliance sampling pools. This requires inspections or detailed surveys. As Andrea explains, Illinois no longer allows for assumptions: "Illinois shut down the guessing game. You can't assume the material is copper with lead solder just because of the home's age, you have to go physically inspect it now."
2. Filters and water treatment
   Utilities need to know if residents have point-of-entry (POE) or point-of-use (POU) filters and water softeners because the EPA prefers sampling through untreated water for LCRI compliance sampling pools. For Illinois, that information must be recorded for each sampling site. Modern POE or POU filters have bypass modes that can be used for sampling. However, residents should never remove a POU filter immediately before sampling, as this can dislodge debris that has accumulated behind the faucet screen, contaminating the first-liter sample.
3. Building types
   Single-family (SF) versus multifamily (MF) designation impacts compliance sampling tiers. "The intent with this is to determine if you're sharing a service line and if people can reliably stagnate the water in that service line for six hours," she says.

1. Leverage existing home visits
   "If most utilities had known 10 years ago, they needed to get premise plumbing materials for compliance, they would have been conducting this while replacing water meters," Andrea adds. Make the most of home visits to record data you might be missing in a unified system.

2. Prepare for survey challenges
   Using phone surveys instead of home inspections can work, but phone surveys require some skill. Andrea recalls, "At in-person visits, I'd ask someone, 'Do you have a water softener?' And they'd say, 'Oh no, no, no.' Then I'd take a closer look and see something that looks like a water softener... so I'd ask, 'Do you add salt to any equipment in your house on a regular basis?' And they'd go, 'Oh yes, yes, yes!'"

   The key to phone surveys is gauging whether residents truly understand your questions. They can reduce stress on residents, but you need to assess if they're giving you accurate information.

1. Coordinate between departments
   "Your inventory staff and sampling compliance staff might be in separate departments, but communication between them is essential," she notes. As inventory identification progresses, compliance sampling requirements may change. You'll also want to avoid sampling soon after any potholing for material identification.
2. Consider service line replacement timing
   Utilities must carefully coordinate lead sampling with replacement programs. If you accidentally conduct sampling after a replacement, it won't count towards your sampling. Track replaced lines in real time to remove them from the sampling pool and add newly identified lead service lines as they're discovered.
3. Retain reliable participants
   According to Andrea, "Many utilities rely on retired employees for compliance samples. They'll let you into their homes, they get why the samples matter, and you can count on them." If existing sampling participants meet new requirements, keeping them is valuable. Having long-term participants also makes it easier to evaluate corrosion control trends over time.

Learn from Illinois: start early, gather good data, and build systems that handle the complexity
The LCRI requirements are complex but manageable with smart planning and realistic expectations. "Compliance sampling programs can be expensive and cumbersome. If you don't have large numbers of lead and galvanized lines and can remove lead and galvanized lines sooner in your system, it's going to save you money in the long run," Andrea recommends. Some utilities even chose to remove them as they find them, keeping them in a less rigorous sampling category.