Preparing for non-lead validation under the LCRI should start now

What utilities underestimate is that this affects inventory accuracy, documentation, procurement, field logistics and multi-year budgets, too. For utilities operating on five-year capital plans or longer, early planning can keep costs more predictable and utilities can have a little more schedule flexibility.

Procurement alone can take about 3–6 months. If locations are scattered, production may average 4 locations per day, per crew, or less. At that pace, plan on roughly 3–4 months of field work for one crew depending on total locations and access constraints. And build in about 3 more months to review results and compile documentation before submittal.

Build a schedule backward from deadlines. Procurement, field production and reporting can easily span most of a year.

There isn’t one “right” approach, and most utilities weigh three paths. The first is pursuing a waiver if their state permits. The second is running a validation study. The third is to physically inspect all service lines. In the third case, a utility would submit a validation pool of zero eligible service lines. The choice between a waiver, a validation study and a full inspection has real operational consequences. There are different costs, different timelines, different staffing and a very different story you'll have to tell regulators down the line.

By November 1, 2027, utilities must submit their waiver request along with supporting documentation showing their completed study. State approval is not required by this deadline, but the study itself must be finished and the documentation ready to submit. It's important to note that the November 1, 2027 inventory is the first one eligible for use in an official study. This means utilities cannot begin their study using an earlier inventory and continue past the deadline. The study must be completed entirely before November 1, 2027, or use the November 1, 2027 inventory as the starting point going forward.

For systems using the November 1, 2027 inventory, they may select their validation study properties from the available pool at that time and then have 7 years to investigate those sites. To help manage costs, some sites may be inspected in conjunction with other scheduled work.

A physical inspection, a record of a physical inspection and a historical record carry different weight. Collapsing them into one bucket makes establishing the validation pool significantly harder. Separate “inspection” from “record” now so your inventory remains defensible and your validation pool stays as small as possible.

If they’re properly documented, and clearly a record of a visual inspection, they can remove service lines from the validation pool completely.

This matters because every service line removed from the pool could reduce the number of required validation inspections. For smaller systems, even the more modest reductions can make a significant difference on the scope and cost.

 When a line classified as non-lead turns out to be lead, the LCRI sets the required steps of the notification timelines and replacement for that service line. Utilities may consider reclassifying a group of service lines or changing material identification methods going forward so deciding the path early makes follow-through easier. However, ultimately the decision on follow-up lives at the state level. Additional federal guidance is not anticipated anytime soon.

Validation is heavily state-driven. EPA sets the framework, but states review approaches, approve waivers, and decide what happens when results raise concerns. States decide whether certain records qualify as inspections, how modeling and statistical methods are accepted and what additional steps are required if validation results raise concerns. This makes early coordination with primacy agencies essential!

Validation takes real resources, field work, data analysis, reporting, and follow-up, so it’s difficult to fund at the last minute. It’s important to build it into multi-year budgeting cycles.

Potholing typically runs about $500–$1,500 per location and is used often when meter inspections aren’t feasible. In some areas, plan for $1,500+ per location. Water systems can assume spending several hundred thousand dollars to complete this study. Small systems with less than 1,500 services lines have to inspect 20% of the validation pool and will see a higher cost per service line in the pool. Large systems with more than 50,000 service lines will only need to inspect less than 1% of the validation pool, seeing a lower cost per service line in the pool.

Set yourself up for success by deciding which path makes the most sense for your system, cleaning up inventory classifications and pressure-testing inventory methods through a “will this end up in the validation pool?” lens.

You also should determine what your state will expect and how approvals work. Build validation into long-range budgets and work plans, too. Non-lead validation will catch a lot of utilities off guard. Not because the deadline is unclear, but because the workload isn't obvious until you're already behind on scope, schedule and cost.