LCRI service line inventory: what to check before 1 Nov 2027
Short answer. By 1 November 2027 every community and non-transient non-community water system must have a baseline inventory of all service lines and connectors, a service line replacement plan and a public inventory (40 CFR 141.84). Before you submit, check that every line has a location, a material for each side, an entire-line classification that follows EPA's rules, a recorded basis for every non-lead call, and a connector status; then count the replacement pool and send the required letters within 30 days (141.85(e)).
The checklist
- Every service line has a location. An address or other locational identifier on every row; no duplicate IDs.
- Both sides are recorded. The material of the system-owned and the customer-owned portion, in words your State accepts (watch "PB": lead or polybutylene?).
- The entire line is classified with EPA's rules. Lead, Galvanized Requiring Replacement, Lead Status Unknown or Non-lead, combining both sides: any lead portion makes the line Lead.
- GRR is decided by the definition. Galvanized pipe is GRR when it is or ever was downstream of a lead line, or is downstream of a line of unknown material (40 CFR 141.2). A galvanized customer side is GRR unless your records show the system side was never lead.
- Connectors are in the inventory. Lead goosenecks and pigtails are new in the LCRI baseline: Lead, Non-Lead, Unknown or No connector present for each line.
- Non-lead calls have evidence. A recorded basis for every non-lead portion, and a method and date for field verification. A "lead ban" basis needs an installation date after your ban year.
- Unknowns have a plan. List unknown lines installed after your ban year or wider than 2 inches as candidates for the methods your State accepts.
- Replacement numbers are right. The replacement pool counts lead, GRR and lead status unknown lines in the baseline (unknowns found to be non-lead come out at the annual update); replace at least 10% of it a year on average, and whether the 39-per-1,000-connections test allows a deferred deadline. All replaced by 1 November 2037.
- The public inventory has no customer names. Location and material only; systems serving more than 50,000 people post it online.
- Letters go out within 30 days. Every customer served by a lead, GRR or lead status unknown line, with the health-effects language the rule requires, and again after each annual update.
Three ways to do it, compared
| Spreadsheet + EPA template | Inventory platform or engineering firm | Linewarden | |
|---|---|---|---|
| Cost | Free | Platforms: $17,000–$20,280 a year in council records (120Water); engineering firms quote per project | $990 a year per water system ($594 founding price until 30 Nov 2026) |
| Entire-line rule and GRR | By hand, with EPA's template logic | Yes | Applied to every line, with the reason |
| Rows your State will question | You find them | Usually | Listed with the row in your file and how to fix it |
| Letters and public inventory | You write them | Usually included | Generated from your file |
| Field collection, maps | No | Yes | No: use what you have |
| Where customer data goes | Stays on your computer | The vendor's systems | Stays in your browser |
A spreadsheet works for a small system with good records and time to check the rules. A platform or an engineering firm also collects field data and writes the plan narrative. Linewarden checks and counts the inventory you already have and writes the letters; it does not inspect lines or write the plan narrative.
Check your own inventory free
Open the free sample or check your own inventory: the counts, the problems and the first 25 lines show on screen without sign-up. The workbook, letters, public inventory and plan files for your own data need a license: Single system $990, Multi-system $1,990 (up to 10), Consultant $3,900 (unlimited), each one payment for 12 months; $594, $1,194 and $2,340 with FOUNDING40 until 30 Nov 2026. Purchase orders: procurement page.