Every community water system must file this by November 1, 2027. No small-system exemption exists.
The Lead and Copper Rule Improvements (LCRI) require every CWS and NTNCWS — regardless of size — to hold a baseline service line inventory that includes connector materials, and a replacement plan for any line that is lead, galvanized-requiring-replacement, or unknown. This is that document: built from what you already know about your system, cited to 40 CFR 141.84 as amended (89 FR 86416), and ready to bring to your board and your state primacy agency.
- Cited to 40 CFR 141.84 as amended (LCRI, 89 FR 86416)
- Built from your intake answers — not a generic template
- Includes DWSRF and lead-focused funding programs your system likely qualifies for
- Board-ready with signature block for state filing
Why this deadline is real
The Lead and Copper Rule Improvements compliance date is November 1, 2027. By that date every CWS and NTNCWS must have a baseline service line inventory that includes connector materials, and systems with any lead, galvanized-requiring-replacement, or unknown lines must have a service line replacement plan.
This applies to every system regardless of size — there is no small-system exemption from the inventory and planning requirements. Systems whose inventories still contain 'unknown' lines must show how they will identify them. Federal infrastructure funding (DWSRF, including set-asides for small and disadvantaged systems) can pay for inventory and replacement work.
40 CFR 141.84 as amended; LCRI (89 FR 86416) · EPA source
What the LCRI baseline inventory must include
Under 40 CFR 141.84, the baseline inventory is not a simple spreadsheet. It must capture specific data elements for every service line in your system, and the LCRI adds connector-material requirements that the original LCRR did not.
Service line classification (all four categories)
- Lead — any portion of the service line that is lead
- Galvanized Requiring Replacement (GRR) — galvanized that is or was downstream of lead
- Non-lead — confirmed not lead or GRR (copper, plastic, etc.)
- Unknown — material cannot be determined from available records
Connector materials (LCRI addition)
- Goosenecks, pigtails, and corporation stops
- Must be identified as lead, non-lead, or unknown
- Counted separately from service line totals
Replacement plan (required if any lead/GRR/unknown)
- Prioritization methodology (highest risk first)
- Annual replacement rate (minimum 10% rolling 3-year average)
- Funding strategy with identified programs
- Public access and annual update commitment
Key point: Under 40 CFR 141.84, a service line classified as "unknown" is treated as lead for compliance purposes — triggering treatment technique and replacement planning obligations until the material is confirmed. This is why the percent-unknown figure in your inventory is the single most scrutinized number at your next sanitary survey.
Funding programs that can pay for inventory and replacement
The LCRI document we generate matches your system to the programs most likely to fund lead service line work. Every plan includes a funding section with program names, eligibility notes, and application timing.
DWSRF Principal Forgiveness
State revolving fund set-asides specifically for lead service line replacement — often 49%+ principal forgiveness for disadvantaged systems.
WIIN Act Lead Testing & Remediation
Federal grant program for schools and child care facilities — applicable if your system serves these facilities.
USDA Water & Waste Disposal
Loans and grants for rural systems under 10,000 population — frequently used for LSL replacement projects.
State-specific programs
CA SB 1398, IL Lead Service Line Replacement Act, NJ Lead Service Line Replacement, and others — matched by your system's state.
How it works — three steps to a filed-ready document
Enter your PWSID
We pull your system details from EPA SDWIS — population, source type, state, existing violations — so you don't have to re-enter known data.
Complete the intake form
Answer 13 questions about your service line counts, connector materials, verification methods, replacement approach, and funding plans. Takes 15–20 minutes with your records handy.
Get the board-ready document
PDF generated instantly with regulatory citations, your data, funding matches, and a signature block. Print, sign, file with your state primacy agency.
Related guides and resources
What to File and When — LCRI Inventory
The federal framework, initial submission deadline (Oct 16, 2024), annual update requirements, and how unknown lines are treated.
LCRI Replacement Funding — DWSRF & LSL Programs
Deep dive on Drinking Water State Revolving Fund principal forgiveness, WIIN grants, USDA, and state programs for LSL replacement.
Lead Service Line Inventory Requirements (LCRR)
The 2021 LCRR baseline — what the initial inventory required, classification categories, and public availability rules.
FAQ
Is this the same as the Orevant compliance report?
No. The compliance report is a diagnosis — it scans your EPA record and tells you what obligations apply. The LCRI Baseline Inventory & Replacement Plan is the deliverable itself — the actual document you file with your state, built from your intake answers. Both are included with Orevant.
We already submitted an initial inventory in 2024. Do we need this?
Yes. The LCRI (finalized October 2024) adds connector-material requirements and a replacement plan that the 2021 LCRR did not require. Your 2024 submission likely does not satisfy the LCRI baseline inventory due November 1, 2027.
What if we don't know our connector materials?
The intake form includes "unknown" as a valid answer for connector materials. The generated document flags your percent-unknown and includes the rule's requirement that unknown connectors be treated as lead until identified — with your stated investigation approach.
Can we pay by invoice / purchase order?
Yes. Government and municipal buyers can use invoice checkout (net-30) with board-ready justification at /checkout/invoice/justification. No card required.
What if we have multiple water systems?
Each system needs its own LCRI plan. The intake is per-PWSID. If you manage multiple systems, start with the one that has the highest lead/unknown exposure.
Does Orevant submit this to the state for us?
No. We generate the document; you file it. The document includes a signature block and names the correct state primacy agency based on your PWSID. Submitting on your behalf would create liability we explicitly do not assume.
Ready to build your LCRI plan?
Included with Orevant — $199/month, everything included. Built from your data. Cited to the rule. Ready to file.
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