What You Need to Know: The Lead Service Line Replacement and Notification Act

Reducing lead exposure by removing lead service lines is one of the top public health and infrastructure priorities in the nation. At the local level, many communities have taken proactive steps to identify and replace lead lines, and Illinois is one of only three states that now mandates the full replacement of lead service lines including the portion within private property.  
 
Illinois’ Lead Service Line Replacement and Notification Act, which went into effect January 1st of this year, requires municipalities and other operators responsible for community water supplies to create a materials inventory of water service lines and a lead service line replacement plan (LSLR) and schedule.
 
Communities will need to meet annual regulatory reporting deadlines for the Illinois Environmental Protection Agency (Illinois EPA) starting April 2023.

Key Points to Know

• ​Establishing an inventory will require reviewing historical documentation and carrying out surveys and visual inspections.
• Building owners and occupants must be notified of the existence of lead service lines connected to the building within 15 days of that discovery.
• Service lines that cannot be verified as non-lead must be identified as a suspected lead service line unless there is documentation showing otherwise.
• Water main replacement projects, effective January 1, 2022, must account for identifying and replacing all lead service lines connected to the water main. (For communities with a population of more than 1,000,000, the effective date is January 1, 2023).
• In the event of emergency repairs, communities must begin the process of replacing the entire service line for known or suspected lead lines.
• Partial replacements are prohibited unless property owner or occupants refuse to grant access and permission. Partial replacements require additional notifications and conditions.
• Communities must keep records of refusals for access and permission for verifying service line materials.
• An accurate inventory will be the basis for understanding the scope of replacements, the funding needed to replace lead service lines and how to prioritize projects.

Getting Started Checklist

• Establish the plan and schedule to complete the initial inventory in time for the April 2023 submission deadline.
• Determine your project team including any technical assistance needed to compile accurate records, develop a plan and assist with the regulatory process.
• Start creating informational and notification materials for residents and businesses.
• Update emergency repair plans and active water main replacement projects to account for lead service line identification and replacement.
• Establish a process to document refusals to provide access or permission for identifying or replacing potential lead service lines.

Inventories must identify:

​The total number of service lines connected to community water systems.

The materials that each service line is constructed of.

The number of suspected lead service lines identified since the last inventory was submitted to the Illinois EPA.
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​The number of suspected or known lead service lines replaced since the last inventory was submitted to Illinois EPA.

LSLR Plans must:
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Account for the full replacement of lead service lines (partial replacements limited to the public right of way are prohibited).

Prioritize replacements for water service to high-risk facilities such as preschools, day cares, playgrounds, hospitals and clinics.

​Follow a replacement schedule based on the total number of lead service lines reported in the final inventory.

Key Regulatory Deadlines:

4/15/2022: Develop an initial service lines materials inventory 

4/15/2023: Submit an updated materials inventory to Illinois EPA

4/15/2024: Submit a complete materials inventory and initial LSLR plan

4/15/2025 to 4/15/2027: Update and submit LSLR plans annually

4/15/2027: Submit a final LSLR plan