What Small Systems Must File by November 1, 2027 Under the LCRI

November 1, 2027 is the LCRI compliance date. It isn't a reminder to start the inventory. It's the day the baseline package has to be on file, the lead action level drops, and the replacement clock is measured against a finished plan.

If you want the inventory how-to, use LCRI lead service line inventory: what to file and when. This page is the November 1, 2027 package: what a small system must file that day, what changes that morning, and what you're still held to until then. This isn't legal advice. Confirm the forms with your state primacy agency.

The three filings due November 1, 2027

By November 1, 2027, community and non-transient non-community water systems owe a baseline package. For most small systems it's three pieces:

• A baseline service-line inventory, or a statement that the system has no lead, no galvanized requiring replacement (GRR), and no unknown lines. The inventory includes connectors.
• A replacement plan, if any line is lead, GRR, or unknown.
• For community water systems, a list of the schools and licensed child-care facilities you serve, or a certification that you serve none.

Those three items are the filing. A spreadsheet on a laptop isn't a submittal. A system that filed an initial inventory in 2024 still has to bring that record up to the LCRI baseline, including connectors, by November 1, 2027.

Baseline inventory, including connectors

Every service line is classified as lead, GRR, non-lead, or unknown. Connectors belong in that record. If you left goosenecks, pigtails, or other connectors out of the 2024 initial inventory, November 1, 2027 is when that gap becomes a late baseline.

If you truly have no lead, no GRR, and no unknown lines, the rule still wants a statement that says so. An empty folder isn't a statement. Write it, sign it, and file it with the PWSID on the page. Unknown isn't a parking spot. Under the LCRI, unknown lines travel with lead and GRR for planning and notice purposes until you prove the material.

Replacement plan if anything is lead, GRR, or unknown

If the baseline shows any lead, GRR, or unknown line, you also file a replacement plan. Most systems must replace lead and GRR under their control within 10 years. The plan is how the state sees that you can do that work on a schedule.

A usable plan names the lines, the order of work, the annual pace, how you'll handle customer-side lines you don't control, and how you'll keep the public inventory current. "We'll apply for a grant" isn't a plan. It belongs in a funding conversation after the plan exists.

Schools and licensed child care (community systems)

Community water systems submit the list of schools and licensed child-care facilities they serve, or they certify that they serve none. Don't skip the list because you're small. Don't invent facilities you don't serve. Confirm with the state how they want the list formatted and what "licensed" means in that state.

What changes the morning of November 1, 2027

The lead action level drops from 0.015 mg/L (15 ppb) to 0.010 mg/L (10 ppb) on that date. A system that has been under 15 ppb can exceed 10 ppb without changing a pump or a main. That exceedance is an action-level exceedance, not an MCL violation. It still starts follow-up, public education, and corrosion-control work. Brief the board on the new number before the first LCRI sampling round.

Most systems then replace lead and GRR under their control within 10 years. Small community systems serving 3,300 or fewer people, and all non-transient non-community water systems, may have state-approved flexibilities after an action-level exceedance. Those flexibilities can include point-of-use treatment or full plumbing replacement instead of corrosion-control treatment. Replacement itself is still required. Flexibility is about how you handle treatment after an exceedance, not about leaving lead in the ground.

What you're still on until November 1, 2027

Until November 1, 2027, systems stay on the pre-July 2021 Lead and Copper Rule, except for the LCRR items that started October 16, 2024:

• The initial service-line inventory (due October 16, 2024). If you missed it, you're already late. File it and tell the state.
• Lead service line notices to customers.
• 24-hour Tier 1 public notice for a lead action-level exceedance.

Don't tell the board that LCRI is 2027, so nothing is due. The 2024 inventory, the customer notices, and the 24-hour ALE notice are already in force. November 1, 2027 adds the baseline package, the action-level drop, and the replacement-plan clock. It doesn't rewind the last two years.

A working calendar from here to that date

• This quarter: pull the 2024 initial inventory. List every unknown. List every connector you never classified. Confirm the PWSID on every file.
• Through spring 2027: resolve unknowns you can resolve, and write the replacement plan against the lines that will remain lead, GRR, or unknown.
• Through summer 2027: build the school and child-care list, or the certification that you serve none. Ask the state which form they want.
• By October 2027: file early enough that a rejected upload isn't a November 2 problem.
• November 1, 2027: baseline inventory or no-lead statement, replacement plan if needed, school and child-care list or certification. Action level is now 10 ppb.

What you tell the board

We owe a baseline inventory (including connectors), a replacement plan if anything is lead, GRR, or unknown, and a school and child-care list or a none certification, by November 1, 2027. The lead action level drops to 10 ppb that day. Today's 15 ppb pass isn't a 2028 pass. Until that date we're still on the old LCR, plus the October 16, 2024 inventory, LSL notices, and 24-hour Tier 1 notice for an ALE. Small-system treatment flexibility after an ALE, if the state approves it, doesn't cancel replacement.

Missing the 2024 initial inventory can already be a violation. Missing the November 1, 2027 package will be one. An action-level exceedance isn't an MCL. It's still a public event with a clock.

FAQ

We filed an inventory in 2024. Are we done?

No. The October 16, 2024 initial inventory was the LCRR starting point. The LCRI baseline due November 1, 2027 includes connectors and has to support a replacement plan if any line is lead, GRR, or unknown. Bring the 2024 file forward. Don't assume the state will convert it for you.

Do small systems get out of replacement?

No. Most systems replace lead and GRR under their control within 10 years. Small CWS serving 3,300 or fewer, and all NTNCWS, may have state-approved flexibilities after an action-level exceedance, such as point-of-use treatment or full plumbing replacement instead of corrosion-control treatment. Replacement itself is still required.

What if we have no schools or licensed child care?

Community water systems still file. You certify that you serve none. A missing certification is a missing piece of the November 1, 2027 package. Confirm the language with the state.

Does the 10 ppb action level apply before November 1, 2027?

The LCRI drops the action level to 0.010 mg/L (10 ppb) on November 1, 2027. Until then, the action level remains 0.015 mg/L (15 ppb), and a lead ALE already requires 24-hour Tier 1 public notice. Confirm any stricter state number with your primacy agency.

Check my system free at /find-my-system. Complete System Report is $199. No subscription.

Orevant provides compliance information tools. This page isn't legal advice. Confirm current LCRI filings and dates with your state primacy agency.