Overview
- Partial replacements can increase lead levels and leave ongoing compliance risks.
- The LCRI prioritizes full replacement and limits when partial work is allowed.
- Pittsburgh and Cincinnati show that funding, access, and customer outreach affect participation.
- CDA provides training and guidance for properly installing copper service lines.
Lead service line replacement programs often encounter a practical question: Where does the utility’s responsibility end?
Depending on local ordinances and ownership structures, a utility may own the section between the water main and curb stop. At the same time, the property owner is responsible for the section extending toward the building. Other communities define responsibility at the property line or meter.
While those distinctions affect who pays for and authorizes the work, they do not alter the physical reality that the service line functions as a single water-delivery system. Replacing only one portion may leave lead or galvanized steel in place, requiring the utility to continue managing the associated public health and compliance risks.
Why Is Partial Lead Service Line Replacement Discouraged?
Partial replacement generally occurs when one section of a service line is replaced while another section remains in service. This may involve replacing the utility-owned side while leaving the customer-owned side intact, or the reverse.
The EPA’s Science Advisory Board concluded that available evidence did not support partial lead service line replacement as a reliably effective method for reducing lead levels.
Disturbing the line can release lead particulate.Lead levels may increase in the period following the work, particularly when replacement practices and corrosion-control conditions are not carefully managed.
Pittsburgh Water encountered this risk during its 2017 lead service line replacement program. At the time, Pennsylvania law did not allow the utility to use public funds on private property. Contractors replaced the public portion of the water main through the curb stop and reconnected it to the customer-owned lead service line.
At the 2025 Annual Conference & Exposition (ACE) hosted by the American Waterworks Association, CDA attended an educational session titled: “Hot Topic Session on Lead Service Line Replacement Programs.” During this session, Shannon Connell from Pittsburgh Water shared critical insights regarding the program.
She noted that post-construction sampling revealed elevated lead levels after several partial replacements. As a result, the utility decided to suspend the program while it developed a safer approach.
The Copper Development Association (CDA)'s field guidance reaches the same practical conclusions: Complete replacement should include both the utility and customer portions. Our guidance for contractors and inspectors warns that disturbing a service line while leaving the lead pipe in place can worsen the problem and potentially elevate lead levels.
What Does the LCRI Require Regarding Partial Replacement?
According to the Lead and Copper Rule Improvements (LCRI) Service line inventory and replacement requirements, partial replacement does not count toward a utility’s mandatory full-replacement total.
The remaining lead or galvanized requiring replacement portion must continue to be documented in the service line inventory and addressed under applicable replacement requirements. Partial replacement also triggers notification and risk-mitigation measures, including flushing instructions, certified filters, and follow-up sampling. If the remaining portion is replaced later, the utility and its contractors may need to coordinate a second construction project.
Water systems must replace lead and galvanized service lines under their control, requiring replacement service lines unless doing so would leave a partial lead service line in place. A line is considered under the system’s control when the system has the legal and physical access required to perform a full replacement.
The rule generally prohibits a water system from conducting a partial replacement unless the work is:
- part of an emergency repair; or
- coordinated with planned infrastructure work that affects service lines, excluding work undertaken solely to replace lead or galvanized requiring replacement lines.
The LCRI generally requires water systems to replace lead and galvanized requiring replacement service lines under their control within 10 program years, subject to limited provisions for shorter or deferred schedules. The rule also lowers the lead action level from 0.015 mg/L to 0.010 mg/L, beginning Nov. 1, 2027 (EPA technical fact sheet on the final LCRI).
For utilities, this combination of a lower action level, more protective sampling, and mandatory replacement requirements strengthens the case for completing the entire service line in a single coordinated project.
Lessons from Greater Cincinnati Water Works and Pittsburgh Water
The experiences of Greater Cincinnati Water Works and Pittsburgh Water show how ownership boundaries, funding policies, and property access can affect a utility’s ability to complete full lead service line replacements.
Pittsburgh Water: Policy and regulatory changes enabled full replacement
According to Pittsburgh Water, the utility-owned portion typically runs from the water main to the curb box, while the section from the curb stop to the building is considered private property. The utility notes that ownership can vary by property (Pittsburgh Water, 2026).
Pennsylvania’s Act 120 of 2018 amended the state Public Utility Code to allow regulated water utilities, with commission approval, to recover costs associated with replacing customer-owned lead service lines. Pittsburgh Water subsequently expanded its program to replace both public- and private-side lead service lines through utility-led projects at no direct cost to participating customers.
Connell also reported that partial replacements were prohibited under Pittsburgh Water’s regulatory framework. In February 2021, the Pennsylvania Public Utility Commission continued its prohibition on partial lead service line replacements by Pittsburgh Water, citing evidence that replacing the public portion while leaving the private lead line intact could cause spikes in drinking-water lead levels.
Pittsburgh Water’s experience illustrates how state law, utility policy, regulatory oversight, and property-owner consent must work together. The funding authority allowed the utility to address customer-owned lines, while its consent and outreach process helped it gain access to complete the work.
Greater Cincinnati Water Works: Boosting Community Engagement
Greater Cincinnati Water Works (GCWW) serves customers in southwest Ohio and northern Kentucky. Of its approximately 33,000 lead service lines, about two-thirds contain lead only on the customer-owned side, according to an account of the utility’s presentation at AWWA ACE ’25.
According to WaterWorld’s June 2025 report on GCWW’s ACE presentation, and as noted by a CDA representative in attendance, GCWW initially offered a cost-sharing program for private-side replacements. That approach produced a 42% participation rate. When the utility moved to a fully funded model in 2021, covering the entire replacement cost for the customer, participation increased to 56%.
The utility found that cost was only one barrier. Customers also questioned whether the no-cost offer was legitimate and worried about construction, property disruption, and restoration. Rental properties created additional challenges because property owners, including out-of-town landlords, had to authorize the work.
GCWW simplified its materials, added electronic agreements, and expanded its use of text messages, community meetings, customer testimonials, and trusted neighborhood representatives. According to the WaterWorld article, these changes helped increase participation to 89%.
The utility’s current Lead Service Line Replacement (LSLR) Program replaces publicly and privately owned lead lines with copper at no additional cost to property owners, funded through a combination of local, state, and federal funding. GCWW reports that it has been replacing lead lines through its Enhanced Lead Service Line Replacement Program since February 2018. As noted on the utility’s program landing page, Cincinnati began requiring the use of copper pipes in 1928 and stopped using lead at that time.
GCWW’s experience demonstrates that fully funding the customer-owned portion can remove a major financial barrier. However, utilities may still need sustained outreach, a straightforward consent process, and clear information about construction and restoration.
Copper LSLR Best Practices: On-site and Virtual Training
CDA offers a Do It Proper with Copper training program to utilities and contractors. It is a no-cost, expert-led educational initiative designed to help communities successfully plan and execute lead service line replacement (LSLR) projects. The training provides practical guidance on the proper installation of copper service lines, including techniques, materials science, and industry-recognized best practices.
These in-person sessions are designed to support crew or teams of all sizes, from small systems planning their first project to larger agencies coordinating comprehensive replacement programs.
Individuals who want to train in their personal capacity can sign up to receive the on-demand webinar, “Best Practices for Lead Service Line Replacement.”
A full replacement should address the entire lead or galvanized service line requiring replacement, from the water main connection to the building inlet, including portions under different ownership where access can be obtained.
CDA guidance to utilities and contractors:
- CDA recommends that utilities confirm the material and configuration of the complete line before construction.
- The field assessment should include the connection at the main, any lead connector or “pigtail,” the curb stop, both sides of an ownership boundary, and the entry into the building.
- Replacement can be completed through open trenching or trenchless methods such as impact moling, directional boring, and pulling.
- The appropriate method depends on soil conditions, existing utilities, site access, restoration requirements, and local code.
- For copper installations, CDA recommends Type K annealed copper tube for water service lines.
- CDA provides guidance on tube-end preparation, flare connections, backfill, trench conditions, sleeving, and foundation penetrations.