Baxter & Woodman is committed to helping Illinois communities stay on track with IEPA Lead Service Line compliance. In this update, you’ll find the critical tasks your water utility must complete before the end of 2025, key steps to prepare for 2026, and the latest developments on LCRI adoption in Illinois.
Key Actions for 2025
Annual Customer Notifications
- Provide notice to all customers with a lead, galvanized requiring replacement (GRR) or unknown service line by the end of the year.
- Reminder – If a new lead or GRR service line is identified, the property needs to be notified within 15 days of discovery.
Lead Notice Certification Form
- Provide Notice to IEPA using their Notice Certification Form that Annual Notifications have been provided to all impacted customers.
Schools and Childcare Facilities
- Complete the inventory submission to IEPA of all schools and childcare facilities served by your community water system.
- Sample at least 20% of identified schools and childcare facilities by year end.
Looking Ahead to 2026
Update Water Service Line Inventory
- Update your inventory to reflect any replacements completed or service line material changes identified prior to resubmission to IEPA by April 15, 2026.
Draft Lead Service Line Replacement Plan
- For communities with lead, GRR or remaining unknowns, update your Replacement Plan based on any inventory changes.
- B&W strongly recommends communities also consider planning for replacements during or in advance of capital improvement projects, as well as revisiting how your community plans to fund replacements.
- Reminder – The Final Replacement Plan will be due to IEPA in 2027, and mandated replacements will begin.
Regulatory Update
Finalized in October 2024, the U.S. EPA’s Lead and Copper Rule Improvements (LCRI) mandate full replacement of all lead and GRR service lines within 10 years, lower the lead action level to 10 ppb, and strengthen requirements for public outreach and sampling. Although the American Water Works Association has filed a legal petition and Illinois is still reviewing the rule, the LCRI remains in effect. Communities should prepare to meet compliance requirements by November 1, 2027 and engage in state public comment opportunities as needed.
The Illinois Pollution Control Board is reviewing the LCRI for adoption into state regulations (Docket R25-1/R25-9). Communities are encouraged to review the LCRI and participate in the Illinois Public Comment Period (through December 8, 2025). Submit comments electronically via the IPCB COOL Portal, by mail to the Clerk’s Office, or by speaking at public hearings. ICPB’s proposed revisions to Illinois Administrative Code per the LCRI can be found in the Illinois Register.
Helpful Links
- Lead Notice Certification Form
- Schools and Childcare Facilities
- Regulatory Update