Linewarden by Atesen Software

LCRI service line inventory: what to check before 1 Nov 2027

Last updated 30 October 2026 · for community and non-transient non-community water systems

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

  1. Every service line has a location. An address or other locational identifier on every row; no duplicate IDs.
  2. 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?).
  3. 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.
  4. 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.
  5. 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.
  6. 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.
  7. 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.
  8. 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.
  9. The public inventory has no customer names. Location and material only; systems serving more than 50,000 people post it online.
  10. 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 templateInventory platform or engineering firmLinewarden
CostFreePlatforms: $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 GRRBy hand, with EPA's template logicYesApplied to every line, with the reason
Rows your State will questionYou find themUsuallyListed with the row in your file and how to fix it
Letters and public inventoryYou write themUsually includedGenerated from your file
Field collection, mapsNoYesNo: use what you have
Where customer data goesStays on your computerThe vendor's systemsStays 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.

Sources: 40 CFR 141.84, 141.2 and 141.85(e) (eCFR, in force 1 October 2026); Federal Register 2024-23549 (89 FR 86418); EPA: Lead and Copper Rule Improvements. A court challenge to the LCRI is pending; the inventory and notification duties of the earlier Lead and Copper Rule Revisions continue in any case. Linewarden is independent software, not affiliated with EPA, and not legal or engineering advice.