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The Association of State Drinking Water Administrators (ASDWA), an association of state primacy agencies, released a white paper in August on developing lead service line inventories. The report was issued ahead of the anticipated release of EPA’s proposal to update its lead and copper rule (LCR) which is expected to require utilities to map the location of such pipes to help prioritize the most corrosive lines for replacement. ASDWA noted that in addition to the anticipated requirements in the revised LCR, EPA’s 2020 Drinking Water Infrastructure Needs Survey and Assessments will include an estimate of the number of public and private lead service lines as well as an estimate of the costs to replace all lead service lines.

The paper included a breakdown of existing strategies in four states (California, Illinois, Michigan, and Wisconsin) that currently require community water systems to provide data on the materials of their service lines, as well as three states (Indiana, Massachusetts, and Washington) that have conducted voluntary surveys. ASDWA also outlined numerous recommendations for states looking to create their own surveys, whether mandatory or voluntary.

In earlier comments to EPA, ASDWA told the agency that provisions it was considering for the proposal could significantly increase state workloads and reduce federal funding for states to administer drinking water regulations or fund infrastructure improvements. The white paper noted, “In many states, developing and implementing a LSL inventory will be a resource intensive project. Reporting through an online portal and delivering content via a website may pose significant barriers to some states, particularly when IT and computer services are centralized within the state.”