As the U.S. Environmental Protection Agency’s Lead and Copper Rule Improvements (LCRI) advance, water utilities are facing rising expectations to move from compliance to active risk reduction. The updated rule builds on the Lead and Copper Rule Revisions (LCRR), strengthening expectations for service line inventories, replacement planning, corrosion control, sampling and public communication.

For utilities, the challenge is turning those requirements into coordinated programs that reflect real system conditions, staffing, funding and community needs.

Brad Montgomery, engineering director with STV’s Water team in Kentucky, has been closely involved in regional lead and copper compliance efforts across Kentucky and beyond. In this Q&A, he discusses what utilities are focused on now, why corrosion control remains central to near-term risk reduction and how technical planning and public engagement need to work together as LCRI implementation moves forward.

1. How should utilities think about the difference between LCRR and LCRI?

Utilities can think of LCRR as the foundation and LCRI as the shift toward more proactive, system-level management.

LCRR focused on building service line inventories and improving visibility into where lead, galvanized requiring replacement and unknown materials may exist. LCRI raises expectations by moving the industry from reactive compliance toward ongoing system management.

Utilities are expected to maintain inventory data, connect it to replacement planning, strengthen corrosion control programs, expand sampling at schools and childcare facilities and communicate more clearly with customers as the work evolves.

For utilities everywhere, that is a meaningful shift. Many systems include infrastructure installed before the 1986 federal ban on lead water lines, and older records are often incomplete. Utilities are still working through legacy records, unknown service line materials and customer-side data gaps.

2. What does LCRI require beyond what many utilities have already done?

LCRI requires utilities to integrate several workstreams into a single coordinated program:

• Maintain and update service line inventories (with public access)
• Develop replacement plans where lead or galvanized lines are present
• Resolve unknowns through field verification and predictive modeling over time
• Align sampling, corrosion control, and replacement planning

The rule also strengthens customer communication. Utilities must clearly explain what is known, what is still being verified and what customers can expect as work progresses.

LCRI establishes an ongoing obligation to keep information current, accessible and understandable – not a one-time compliance effort.

3. What concerns are utilities raising most often?

Programmatic cost and lack of staffing for program implementation are two of the most consistent concernsThe most common concerns that I hear are cost and lack of staffing to implement new programs. The cost is not just the cost for replacements, but also the programmatic costs. Many utilities are making progress on individual pieces, such as inventories, corrosion control and expanded sampling, but LCRI requires those efforts to work together on a shared timeline. That is especially challenging for smaller systems, with limited staff balancing operations, capital planning and compliance.

Kentucky’s “Check Your Pipes, KY” initiative is one example of outreach support helping utilities and customers understand lead risks and service line ownership.

The key challenge is keeping technical work and customer communication aligned. If inventory validation, replacement planning and outreach move out of sync, customers receive mixed signals.

4. Why is corrosion control such a central focus under the updated rule?

Corrosion control is one of the most effective near-term ways to reduce lead exposure, even before service lines are replaced.

Replacement programs take time. Utilities must validate inventory data, plan work, secure funding, coordinate construction and communicate with affected customers. Corrosion control helps reduce risk while the longer-term work proceeds.

LCRI raises the bar for how corrosion control programs are studied, documented and maintained. Utilities need to understand how treatment changes, source water conditions and seasonal variation affect performance. Utilities also need to explain that corrosion control reduces risk now, but does not replace accurate inventories or long-term replacement planning.

5. What’s a strong example of a city adapting to these regulations?

The City of Ashland’s Water Service Line Identification Program also illustrates how customer communication can be operationalized. The city is asking customers with unknown service line materials to participate through surveys and simple verification steps, helping close data gaps while explaining what the utility is doing and why.

From a technical perspective, the issue is often not widespread lead use, but incomplete historical data that must be verified and made usable for planning. Communication like this needs to be built into the program from the start – not added at the end.

6. What practical challenges should utilities anticipate as LCRI deadlines approach?

Data quality and prioritization are two of the biggest challenges. Many inventories require validation before they can support replacement planning. The challenge is less about confirming the presence of lead and more about resolving unknowns at scale. Utilities must balance public health, constructability and funding, equity and customer disruption. This work spans engineering, operations and public communication, requiring clear prioritization and defensible decision-making.

7. How can utilities move from planning to implementation?

The utilities making the most progress are treating LCRI as a single, connected program. That means linking:

• inventory data
• corrosion control strategies
• sampling plans
• replacement schedules

GIS and data tools can help identify unknowns and prioritize field verification, while predictive methods can focus limited resources where they reduce uncertainty most. Technology supports decisions – it does not replace them. Plans still need to reflect staffing, budget and construction capacity.

Outreach also needs to move in step with implementation. If crews are verifying service lines or priorities are changing, customers need clear, plain-language explanations.

8. Where can experienced partners add the most value?

The biggest value is helping utilities connect technical, regulatory and communication work into a clear path forward.

On the technical side, that includes inventory validation, corrosion control evaluations, sampling strategy and replacement planning. On the program side, it means organizing those efforts into a defensible implementation plan.

There is also a growing need for public engagement. Utilities are being asked to explain complex issues in ways customers can understand and act on. Effective support aligns technical delivery with ongoing, trust-building communication.

STV’s strength is bringing those disciplines together so utilities can move from compliance to sustained risk reduction.

9. What is one piece of advice you would give utilities that are beginning their LCRI preparations now?

Be proactive and take a holistic view. LCRI touches inventory management, treatment, sampling, capital planning, outreach and reporting.

Start with the data and be clear about what is known and what still needs to be verified. Then build a program that connects technical, regulatory and communication priorities.