Lead Inventory Desk Free gap check

For US water systems serving 10,000 people or fewer

Your service line inventory and replacement plan are due November 1, 2027.

Under EPA's Lead and Copper Rule Improvements, every community water system, and every school, plant or other site that runs its own regulated water system, must send the state a baseline inventory of all its service lines by that date. If any line is lead, galvanized requiring replacement, or unknown, you also need a service line replacement plan by the same date.

We turn the records you already have into both, for a fixed price.

Email us for a free gap check See a sample gap check

Send your PWSID or system name. You get a short PDF back within 2 business days. No cost, no obligation.

What is due

Due to your state by

  • Baseline inventory of every service line and connectorTo the state
  • Service line replacement plan, if any line is lead, galvanized requiring replacement or unknownTo the state
  • Notice to every home or building on one of those linesWithin 30 days
  • Inventory and plan open to the publicKept current

Rule text: 40 CFR 141.84 and 40 CFR 141.85(e)

In 2024, 3,902 public water systems had a health-based violation for missing the October 16, 2024 initial inventory. Source: EPA National Public Water Systems Compliance Report, 2024

The rule

What the rule asks of your system

EPA published the Lead and Copper Rule Improvements on October 30, 2024, and the rule took effect December 30, 2024. Most of its duties start November 1, 2027. Here is the short version for a small system, with the rule text linked under each point.

  1. Send the state a baseline inventory

    List every service line, whoever owns it. Where you and the customer each own part of a line, list both parts. List the connectors too. Due November 1, 2027.

    Rule text: 40 CFR 141.84(a)(2)

  2. Put each line in one of four categories

    Lead, galvanized requiring replacement, non-lead, or lead status unknown. The four categories are explained below.

    Rule text: 40 CFR 141.84(a)(3)

  3. Write a replacement plan if any line is lead, galvanized or unknown

    The plan says how you will identify unknown lines, how you will replace lines and in what order, how you will pay for it, how you will tell customers, how people should flush after work on a line, and which local laws affect getting onto private property. Due November 1, 2027.

    Rule text: 40 CFR 141.84(c)

  4. Tell the people on those lines

    Every home or building on a lead, galvanized requiring replacement or unknown line gets a notice within 30 days of the baseline inventory, then again every year until the line is replaced or shown to be non-lead. Under the 2021 rule, yearly notices already apply today.

    Rule text: 40 CFR 141.85(e)

  5. Keep it open to the public

    The inventory and the plan must be publicly accessible. Systems serving more than 50,000 people must post them online.

    Rule text: 40 CFR 141.84(a)(5) and (c)(2)

  6. Update it every year

    Send the state an updated inventory, and an updated plan or a note that nothing changed, by January 30 each year, starting January 30, 2029.

    Rule text: 40 CFR 141.90(e)(3) and (e)(4)

  7. Replace lead and galvanized lines within 10 years

    Replacement programs start November 1, 2027. Lead and galvanized requiring replacement lines under your control must be replaced within 10 years, unless your state sets a different deadline. Every unknown line must be identified by then.

    Rule text: 40 CFR 141.84(b)(1)(i) and (d)(4)

Key dates

  1. Initial inventory due under the 2021 rule. Notices to people on lead, galvanized or unknown lines within 30 days, then every year.

  2. The 2024 rule takes effect.

  3. A federal appeals court hears a challenge to the 2024 rule. No ruling yet.

  4. Baseline inventory and replacement plan due. Replacement program starts.

  5. First yearly update of the inventory and plan. Then every January 30.

  6. Spot check of a random sample of lines marked non-lead, for most systems.

  7. Replacement deadline for most systems, 10 years after November 1, 2027.

Rule text: 40 CFR 141.80(a), 40 CFR 141.84(b)(5) and (d)(4), 40 CFR 141.90(e)

Every line goes in one of four categories

Where ownership is split, each part of the line gets its own category.

  • Lead

    Any part of the line is lead. Lead-lined galvanized pipe counts as lead.

    Replace

  • Galvanized requiring replacement

    Galvanized pipe that is, or ever was, downstream of a lead line, or is now downstream of an unknown line. If you cannot show it was never downstream of lead, it counts.

    Replace

  • Non-lead

    Records, a method or an inspection show it is not lead and not galvanized requiring replacement. You do not have to name the exact material.

    No action

  • Lead status unknown

    No reliable evidence either way. Each unknown line gets a yearly notice and must be identified by your replacement deadline.

    Identify

Rule text: 40 CFR 141.84(a)(3) and definitions in 40 CFR 141.2

What counts as the service line From left to right: the water main, a short connector, the system side of the service line, the curb stop or meter, the property line, the customer side of the service line, and the building inlet. The service line runs from the main to the building inlet and both sides go in the inventory. Water main Connector gooseneck or pigtail System side Curb stop or meter Property line Customer side Building inlet Service line: both sides go in the inventory What counts as the service line From top to bottom: the water main, a short connector, the system side of the service line, the curb stop or meter, the property line, the customer side of the service line, and the building inlet. The service line runs from the main to the building inlet and both sides go in the inventory. Water main Connector gooseneck or pigtail System side Curb stop or meter Property line Customer side Building inlet Service line: both sides go in the inventory
The service line runs from the water main to the building inlet. The connector, often called a gooseneck or pigtail, is a short bendable piece of up to three feet. It is listed separately as lead, non-lead, unknown, or no connector present.

About the court case

The American Water Works Association has challenged the 2024 rule in the U.S. Court of Appeals for the D.C. Circuit (American Water Works Association v. EPA, No. 24-1376). The court heard argument on September 30, 2026 and has not ruled. EPA is defending the rule.

Until the court says otherwise, the rule is in effect and the November 1, 2027 date stands. The challenge is aimed mainly at the replacement requirements. The duty to keep a service line inventory also exists under the 2021 rule, in force since October 16, 2024, so inventory work is needed either way. If the ruling changes anything, we will update this page.

The first deadline was enforced

In 2024, 3,902 public water systems, about 2.7 percent of active systems, had a health-based violation because they did not meet the October 16, 2024 initial inventory requirement.

Your state handles enforcement in most cases. EPA does so directly in Wyoming, the District of Columbia and most of Indian country.

Official sources

Rule facts on this page were checked against these sources on October 13, 2026.

The kit

What you get: the Inventory and Replacement Plan Kit

Built from the records you already have, and ready for your certified operator or responsible official to review, sign and send.

  • Baseline inventory in your state's template

    We turn your tap cards, permits, meter and billing records, maps, construction dates and plumbing code dates into a line-by-line inventory, set up in the format your state asks for.

  • Every line classified by the rule's categories

    Each line, and each side where ownership is split, sorted into lead, galvanized requiring replacement, non-lead or unknown, plus each connector.

  • Unknown lines, with the cheapest way to settle each

    A list of the lines still unknown, grouped by what it will take to find out: more records, a look in the meter pit or curb box, or field work.

  • Service line replacement plan, drafted

    Covers the parts the rule lists, including priority order, funding sources such as state revolving fund lead money, customer communications, flushing, and access to the private side of the line.

  • Customer notification letters

    Letters for homes and buildings on lead, galvanized requiring replacement and unknown lines, with the content the rule calls for.

  • Public inventory table

    A plain table of your inventory that you can post or hand out, so the public can see it.

Reviewed before you get it

Every kit is reviewed by an experienced water-industry reviewer before delivery. Your certified operator or responsible official then signs and submits it.

Not included

  • Field verification: no potholing, excavation or site visits.
  • An engineer's stamp. Where your state requires an engineer to sign, we work alongside your engineer.
  • Legal advice.

What we are

We prepare documents. We do not act as your system's engineer, and your state makes the final call on your inventory and plan.

Prices

One fixed price, set by the size of your system

Inventory and Replacement Plan KitFixed price in US dollars, by number of service connections
Service connectionsFixed price
Up to 500US$2,900
501 to 3,300US$4,900
3,301 to 10,000US$6,900
  • You know the full price before work starts.
  • Field work and engineering are not part of the price.
  • Ask your state's revolving fund office whether lead service line money can cover it.

Annual inventory update

From US$900 a year. We add what you learned during the year from meter reads, repairs and replacements, and prepare the updated inventory for your January 30 filing with the state.

Not sure of your size?

The free gap check shows your service connection count from your public record, and which price applies. Get the free gap check

Free

Start with a free inventory gap check

Email us your Public Water System ID (PWSID), or your system name and state. Within 2 business days we send a short PDF built from your public federal record and any inventory your state publishes.

Email us for a free gap check See a sample gap check

Your PWSID is usually two letters and seven digits. If you do not have it handy, your system name and town are enough. No cost, no obligation.

  • How much is still unknownThe share of your service lines your state's published inventory still lists as unknown.
  • What comes next, with datesThe duties that apply to your system and when each one is due.
  • What looks missingGaps between what you have on record and what the 2027 baseline inventory needs.

How it works

Three steps, all by email

  1. Get the free check

    Email your PWSID or system name. In 2 business days you get a short PDF showing where you stand and what comes next.

  2. Send your records

    If you want the kit, we confirm the fixed price for your size. You send what you have, in any form: scans, phone photos, spreadsheets. We ask follow-up questions by email.

  3. Review, sign, submit

    You get the inventory, the plan draft, the notice letters and the public table, reviewed by an experienced water-industry reviewer. Your certified operator or responsible official signs and sends them to the state.

Who it is for

Built for small systems with old records and no spare time

Community water systems serving 10,000 people or fewer, and non-transient non-community systems such as schools and workplaces with their own water.

  • Small towns and villagesthat run their own water department
  • Rural water districtswater associations and co-ops
  • Mobile home parksand manufactured housing communities
  • HOAs and subdivisionswith their own water system
  • Schools and campswith their own well
  • Plants, offices and other workplacesthat are their own water system

Probably not a fit if

  • You serve more than 10,000 people.
  • You need a crew to dig. We do records, not field work.
  • You need an engineer of record. We work alongside yours; we do not replace them.

Questions

Questions operators and boards ask

We heard about a court case. Do we still have to do this?

Yes, plan on it. The 2024 rule is in effect and its November 1, 2027 date has not changed. The court heard the challenge on September 30, 2026 and has not ruled, and EPA is defending the rule. The challenge is aimed mainly at the replacement requirements. The inventory duty already applies under the 2021 rule, in force since October 16, 2024, so inventory work is needed either way.

More about the court case

We did an inventory in 2024. Do we need this?

Most likely. The 2024 rule asks every system for an updated baseline inventory by November 1, 2027. It must list connectors, which the 2024 inventories did not have to include, plus anything you have learned since. If any line is lead, galvanized requiring replacement or unknown, you also need the replacement plan. If your 2024 inventory shows only non-lead lines, you need much less, and the free check will say so.

Rule text: 40 CFR 141.84(a)(2)

What records do you need?

Whatever you have. Tap cards, service and plumbing permits, meter install and change-out records, billing records with service addresses, distribution maps and as-builts, work orders, the years homes and subdivisions were built, and the date your town or state banned lead pipe. Scans and phone photos are fine. Gaps are normal: we work from what exists and list what is missing.

Do you dig or send a crew?

No. This is records work. We do not pothole, excavate or visit. For each line the records cannot settle, we list the cheapest way to find out, such as a look in the meter pit or curb box during a routine read, a customer photo of the pipe where your state accepts it, or potholing as a last resort. Your crew or a local contractor does any field work.

Who signs and submits?

Your system does. Your certified operator or responsible official reviews, signs and sends everything to the state. We prepare the documents. If your state wants an engineer to sign the plan, we work alongside your engineer. We do not act as your engineer and we do not give legal advice.

Can grant or loan money pay for this?

Often it can. EPA says lead service line money from the Drinking Water State Revolving Fund can pay for finding lead lines and planning, as well as replacement. Each state runs its own program and decides who it pays and for what, so ask your state's revolving fund office first. We can give you our scope and fixed price in writing for an application.

Source: EPA news release, November 25, 2025

How long does it take?

Most of the time goes into pulling records together on your end. Once we have them, plan on a few weeks for a small system and longer for a larger one. We agree a delivery date with you in writing before work starts. Starting by spring 2027 leaves room for state questions and any field checks before November 1, 2027.

What if most of our lines are unknown?

That is common where records are old. Unknown is an allowed category, but every unknown line needs a yearly notice, means you need a replacement plan, and must be identified by your replacement deadline. So it pays to shrink the list early. We sort your unknowns by the cheapest way to settle them, and the plan sets out your strategy for the rest, as the rule requires.

Rule text: 40 CFR 141.84(b)(1)(i) and (c)(1)(i)

Contact

Questions? Email us.

We work by email, so you have everything in writing. Send a question, or ask for the free gap check.

Email us for a free gap check

Who we are

Lead Inventory Desk is operated by 1414618 B.C. Ltd., Vancouver, British Columbia, Canada. We serve US water systems remotely, by email.

We are a private company. We are not part of EPA or any state agency, and this site is not an official notice.

We prepare documents for your system to review, sign and submit. We do not act as your engineer and we do not give legal advice.