## Insights, resources, and tips for water operators

### Securing the Future of Small Water Systems: A Conversation with Scott Huckaby of Talbot County, GA

Scott Huckaby is no stranger to the realities of small water systems. As a geologist, retired teacher, and water quality expert, he oversees eight systems across Georgia, each grappling with the same obstacles: aging infrastructure, limited funding, and increasingly complex regulations. “The systems I work with were largely installed in the 1950s, 60s, and 70s. They’re old, patched together, and expensive to maintain. Convincing local governments to invest in these systems is often an uphill battle,” he explained. One example stands out. For years, Scott worked tirelessly to convince a town council to upgrade a collapsing water system from the 1950s. “They were spending more money fixing leaks than they were earning. It took me five years of constant conversations to get them to apply for funding. But in the end, they were able to secure a loan with 60% forgiveness, and the system is finally rehabilitated.” But funding and upgrades are only part of the equation. Scott recalled an especially challenging project involving an orphanage, where decades-old galvanized lines and 50/50 lead solder created serious risks for the vulnerable population living there. “The only real solution is replacing the plumbing in every house,” he shared. “But they don’t have the funding, and there’s little help available for private systems like theirs.”

### Aging Operators and the Next Generation Crisis

Beyond infrastructure, the water industry faces another looming crisis: a mass retirement of operators with no clear pipeline of new talent. At 62 years old, Scott is part of a generation nearing retirement. “I’m 62, and most of the operators I know are my age or older. The younger generation isn’t stepping in to fill these roles,” Scott noted. Scott is training one young operator in hopes of bridging the gap. “I tell him, ‘You’ll have job security for the rest of your life. Small towns will always need clean water.’ But we need to do more to attract younger people to this industry. We need programs in high schools to show them this work doesn’t require a college degree, just hands-on training and a willingness to learn.”

### PFAS and the Next Frontier of Water Quality Challenges

While tackling aging infrastructure and the lead and copper rule remains critical, Scott pointed to PFAS contamination as the next big challenge. “PFAS is going to make lead and copper compliance look easy,” he said. One of the systems he oversees receives purchased water that already exceeds the limits for several PFAS chemicals. His county is now part of a pilot project funded by the EPA to explore solutions, including drilling new wells that aren’t contaminated. “It’s a step in the right direction, but smaller systems that lack resources to treat PFAS or even conduct proper sampling are going to face enormous hurdles,” Scott explained. He stressed the importance of having the right tools to track and manage compliance. “Operators need simple software to monitor their systems, track sample results, and stay on top of notifications. Right now, we’re drowning in paperwork, and it’s only going to get worse with these new regulations.”

### Using Technology to Overcome Barriers

Despite the challenges, Scott sees technology as a key part of the solution. He highlighted how digitizing his service line inventory with 120Water made an unexpected difference during a recent meter replacement project. “The installation company couldn’t locate addresses because the county hadn’t assigned them yet,” Scott explained. “But using the 120Water platform, we were able to map every meter location in the system. It saved us weeks of work.” Scott believes this kind of digital innovation will be essential for navigating new regulations and addressing the operator shortage. “We need tools that are easy to use and help us track everything—from sampling results to customer communication. That’s the kind of support operators need to do their jobs well.”

### Looking Ahead: A Call to Action

The challenges facing small water systems are daunting, but they’re not insurmountable. With increased funding, better training programs, and the right technology, the future of clean water for rural communities can be secured. For Scott, the mission is deeply personal. “At the end of the day, it’s about keeping people safe—especially the most vulnerable populations, like kids. We’ve known for a long time what lead and other contaminants can do to people. Now it’s time to do something about it.” By sharing Scott’s story, we hope to inspire collaboration, innovation, and action across the water industry to tackle these critical issues head-on.

### Starting Your LCRI Journey

Now that the Lead and Copper Rule Improvements (LCRI) has been finalized, many water systems may be unsure of what to do next or how to start preparing for the LCRI compliance deadline of November 1st, 2027. Each water system’s journey will be unique, but all systems can start by continuing to build on their initial service line inventory that was required to be submitted as part of the Lead and Copper Rule Revisions (LCRR) in 2024.

#### LCRR Requirements to Keep in Mind

While the October 16th, 2024 LCRR compliance deadline has come and gone there are still some LCRR elements that water systems need to consider. In addition to submitting the initial service line inventory in 2024, water systems were also required to notify customers with lead service lines (LSL), galvanized requiring replacement (GRR), and unknown service lines. The service line notification is an annual requirement and notifications need to be sent in 2025, 2026, etc. until the service line can be classified as non-lead. Moreover, moving forward, water systems are required to notify **all** of their customers within 24-hours following a systemwide lead action level exceedance at 15 µg/l. Starting in November 2027, the 24-hour notification will remain in effect but the lead action level will be 10 µg/l.

#### LCRI Deadlines

The LCRI has its own set of requirements and deadlines. Three LCRI elements must be submitted to state regulators on the LCRI compliance deadline of November 1, 2027 including:

- Updated “Baseline” inventory that includes connector material
- List of all school and childcare facilities served by the system
- Service line replacement plan (if any LSL, GRR, or Unknowns are in baseline inventory)

Water systems also need to be prepared to comply with a variety of other LCRI changes that will go into effect starting on November 1st, 2027. However, system specific characteristics will determine the exact timing of if and when an individual water system is impacted. LCRI elements that water systems need to prepare for include:

- Validate non-lead service lines and verify all unknown service lines
- Initiate a school and childcare sampling program
- Comply with a lower lead action level of 10 µg/l
- Update sampling programs to align with new the tiering structure
- Implement a new sampling protocol for LSL sites (sample 1st and 5th liter)
- Enhance customer transparency following lead action level exceedances
- Implement risk mitigation procedures following service line replacements or disturbances
- Offer to sample at properties served by a LSL, GRR, or Unknown service line
- Perform a follow up assessment at individual compliance sample sites with >10 µg/l Pb
- Assess corrosion control treatment following a Pb or Cu ALE

#### Where to Start

As numerous November 2027 deadlines approach, putting together a comprehensive LCRI compliance plan may challenge water utilities juggling many other responsibilities and new regulations. There are three steps that utilities can take today to help them start their journey.

1. **Begin Identifying Connector Materials:** The LCRI “Baseline” inventory is due on November 1st, 2027. Connectors (commonly referred to as goosenecks) are required to be added to the Baseline inventory and categorized as lead, non-lead, unknown, or no connector present. While the connector material does not impact the classification for the entire service line (some states have different interpretations) water systems should review their records to classify as many connectors as possible prior to the submission deadline.
2. **Start/Continue an Unknown Verification Program:** Whether you have 100 or 1 million unknowns, identifying service line materials is the foundation of LCRI compliance. Unknown materials will be assumed to be lead and included in the service line replacement rate that determines how many LSLs/GRRs need to be replaced each year. Water systems should develop a verification plan that assesses state-approved verification methods, evaluates opportunities to verify materials during normal field operations, and considers a data management strategy to ensure all of the data is organized and accessible to various team members.
3. **Identify Funding:** The costs to complete and manage unknown verification and service line replacement programs can be substantial, fortunately funding is available. The Bipartisan Infrastructure Law (BIL) has allocated $15 billion in federal funding, disbursed through Drinking Water State Revolving Funds (DWSRF), specifically designed to support programs to identify unknowns and replace service lines. Water systems should research funding pathways in their state and understand application submission requirements.

#### The Path Forward

All of the LCRI and LCRR required elements may overwhelm water providers, especially smaller systems with limited staff who are already at capacity. Regardless of how utilities plan to comply, continuing the inventory process will only benefit them. Compliance obligations can be minimized for those who are able to confirm there are no LSLs or GRRs in their system. Systems with unknown service lines in their Baseline Inventory submission on November 1st, 2027 will be forced into more requirements including offering to sample at customer homes, submitting a service line replacement plan, and including unknowns in their service line replacement rate calculation. The LCRI represents a new generation of data-intense regulations, with data management playing a critical role in overall compliance success. As your system works to meet LCRI’s many requirements and multiple deadlines, consider digital solutions that can help organize and manage the variety of data throughout your compliance journey.

### Introducing Insights: A Game Changer for Statewide Water System Oversight

At 120Water, we always strive to provide tools that enhance the efficiency and effectiveness of water program management. Our latest innovation is **Insights**, an addition to our State Dashboard that enhances data visualization for state primacy agencies.

**Key Features and Benefits of Insights:**

1. **Holistic Inventory Overview and Submission Progress Monitoring:**
   - **Insights** offer a comprehensive view of the inventory status across all water systems in your state.
   - You can track submission periods and see how many submissions have been received versus the total number of utilities.
2. **Data Visualization:**
   - The platform provides various ways to view data, showcasing potential areas of risk with lead service lines and other crucial data points.
   - Visualizing data in new ways helps identify areas that require additional resources, helping with informed decision-making and effective resource allocation.
3. **Detailed Material Breakdown:**
   - **Insights** includes utility material makeup statistics showing the percentage of systems with unknown, lead, galvanized, and non-lead service lines.
   - This breakdown allows for better progress tracking over time as systems continue their verifications and work toward reducing unknowns.
4. **Geographic Map-Based View:**
   - The geographic view lets you see a high-level breakdown of service line materials by region.
   - You can drill down into specific counties to see detailed service line inventories for individual water systems, allowing for targeted follow-up and support.

Insights is not just a homepage; it's a powerful asset for managing your water quality program statewide. It enhances clarity, enables better decision-making, and helps identify and address gaps in the service line data for your state.