Iowa DNR's water supply program is continuing to track litigation against the LCRI and current administration review of the rule, expecting to provide more communication around LCRI requirements after there is more information about EPA's response, which is anticipated in December 2025.
In the meantime, we have the following information and recommendations to comply with the current LCRR and prepare for future LCRI deadlines:
LCRR Service Line Material Public Notice
November 15, 2025 is the next deadline for public notice to be sent to customers with lead, galvanized requiring replacement (GRR), or lead status unknown service line materials. If you were previously required to conduct public notice, but no longer have lead, GRR, or unknown lines in your inventory, DNR needs a record of that to avoid unnecessary public notice violations. At this time, DNR is asking that this record be provided by submission of an updated inventory file through the Iowa Drinking Water Data Portal (IDWDP). DNR is not looking for other updated inventory files at this time - see more on this in the LCRI Implementation information below.
LCRI Implementation
November 1, 2027 is the date to memorize - this is the compliance date of the LCRI and when the LCRI baseline inventory and replacement plans are due.
What water systems owners and operators can do right now:
Iowa Drinking Water Data Portal Updates
Iowa DNR is working on Iowa Drinking Water Data Portal (IDWDP) changes that will allow LCRI baseline and annual inventories to be managed directly in the portal. This will be a change from sending DNR an Excel-based inventory file. In the interim, we recommend that water systems keep track of updates to their service line inventories locally until we have LCRI related features added to the portal.
Validation of non-lead service lines
The DNR is aware there may be some confusion on 2-point validation of non-lead service lines. The LCRI does not require 2-point verification to identify an unknown service line in an inventory; single point verification is acceptable. However, 2-point validation for a portion of non-lead lines is required by the LCRI. This 2-point validation is not due to be completed until December 31, 2034, with results due to the Iowa DNR on January 30, 2035. This is over 9 years away and we strongly recommend focusing on LCRI baseline inventories and replacement plans first, as those are currently due on November 1, 2027, roughly 2 years away.
EPA LCRI Fact Sheets: https://www.epa.gov/dwreginfo/lead-and-copper-rule-improvements-supporting-materials
Questions on these topics can be directed to:
TA Provider Preston Kizer, [email protected], 515-289-5203
or
[email protected]
In the meantime, we have the following information and recommendations to comply with the current LCRR and prepare for future LCRI deadlines:
LCRR Service Line Material Public Notice
November 15, 2025 is the next deadline for public notice to be sent to customers with lead, galvanized requiring replacement (GRR), or lead status unknown service line materials. If you were previously required to conduct public notice, but no longer have lead, GRR, or unknown lines in your inventory, DNR needs a record of that to avoid unnecessary public notice violations. At this time, DNR is asking that this record be provided by submission of an updated inventory file through the Iowa Drinking Water Data Portal (IDWDP). DNR is not looking for other updated inventory files at this time - see more on this in the LCRI Implementation information below.
LCRI Implementation
November 1, 2027 is the date to memorize - this is the compliance date of the LCRI and when the LCRI baseline inventory and replacement plans are due.
What water systems owners and operators can do right now:
- Work on your Service Line Inventory
- Identify Unknowns. The following are accepted, single-point verification methods for service line material identification for LCRI inventories: available construction and plumbing codes, permits, and records; water system records on service lines and connectors (such as distribution system maps and drawings, recent or historical records on each service connection and connector, meter installation records, historical capital improvement or master plans, and standard operating procedures); and distribution system inspection records.
- Update your inventory and keep it current. Save as a local copy until we share how these can be submitted to DNR in the future through the IDWDP.
- Update your service line connector material information or start gathering information on your connector materials. The LCRI will require connectors to be identified as either lead, non-lead, unknown, or to be noted as not present. If you want to update your local inventory file to note that a connector is not present, you may use the "General Notes" column at this time.
- NOTE: these inventory updates do not require physical verification of service line materials. If there are records of visual material inspection/identification, make sure those records are kept.
- Make sure your location identifiers for service lines and connectors in your inventory are street addresses whenever possible.
Iowa Drinking Water Data Portal Updates
Iowa DNR is working on Iowa Drinking Water Data Portal (IDWDP) changes that will allow LCRI baseline and annual inventories to be managed directly in the portal. This will be a change from sending DNR an Excel-based inventory file. In the interim, we recommend that water systems keep track of updates to their service line inventories locally until we have LCRI related features added to the portal.
Validation of non-lead service lines
The DNR is aware there may be some confusion on 2-point validation of non-lead service lines. The LCRI does not require 2-point verification to identify an unknown service line in an inventory; single point verification is acceptable. However, 2-point validation for a portion of non-lead lines is required by the LCRI. This 2-point validation is not due to be completed until December 31, 2034, with results due to the Iowa DNR on January 30, 2035. This is over 9 years away and we strongly recommend focusing on LCRI baseline inventories and replacement plans first, as those are currently due on November 1, 2027, roughly 2 years away.
EPA LCRI Fact Sheets: https://www.epa.gov/dwreginfo/lead-and-copper-rule-improvements-supporting-materials
Questions on these topics can be directed to:
TA Provider Preston Kizer, [email protected], 515-289-5203
or
[email protected]
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