UCMR 6: What Water Systems Should Know About the EPA's Next Round of Unregulated Contaminant Monitoring

Every address served by a lead, galvanized requiring replacement (GRR), or unknown service line needs a notice before December 31, 2026. For many systems, this is round three. That should make it easier. It also raises the stakes a little, because residents have seen one of these letters before, and some of them still have questions nobody answered.

In 120Water's webinar on building community trust ahead of the Lead and Copper Rule Improvements (LCRI), Isaac Pellerin, SVP of Corporate Strategy, argued that the utilities that come out ahead treat notification requirements as a starting point. The requirement itself is simple. Sending a letter that moves residents to a next step takes more planning.

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The Requirement in Plain Terms

First, a common mix-up: your 2026 notices fall under the Lead and Copper Rule Revisions (LCRR), not the LCRI. Annual notification has been required under the LCRR since October 16, 2024, and the EPA kept that requirement in place when it finalized the LCRI. The LCRI brings its own notification rules, but those don't start until its compliance date.

Who gets a notice. Anyone served by a lead, GRR, or unknown service line. Yes, unknown counts. New customers at one of those addresses also get a notice when service starts.

What it has to say. Every notice states the service line's classification (for unknowns, that the material is unknown but may be lead), includes the required lead health effects language, and lists steps people can take to reduce their exposure. The last piece changes by classification:

• Lead lines need information on replacement opportunities and programs that help finance replacement.
• GRR lines need information on replacement opportunities and programs that help finance replacement.
• Unknown lines need information on how the material can be verified.

‍How to send it. By mail, or by another method your primacy agency approves.

What comes after. Notices go out every year, and the state certification covers the full calendar year. That's why 2026 letters need to reach residents by December 31. By July 1, 2027, you certify to your state that the notices went out and include a copy of what you sent. Skip that step and you're looking at a Tier 2 public notice, which is a much less fun letter to write.

Templates. The EPA provides three templates, one per classification, in English and Spanish. Some states require their own templates or specific language, so check with your primacy agency before you print anything.

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Answer Their Questions Before They Ask

When a resident opens this letter, they want to know three things. Is my water safe to drink today? What is my utility doing about lead? Why did I get this? The required language covers the regulatory facts. It wasn't written for someone reading at the kitchen table after a long shift.

Nothing stops you from adding a plain-language cover note or a short FAQ alongside the required content. The systems that handle this well have their answers ready before the letter lands, so the first thing a resident reads is a clear next step.

Unknown lines deserve extra care. To most homeowners, "unknown" sounds a lot like "lead," even when it turns out not to be. Give those residents a way to help close the gap: share records they might have, check the pipe where it enters the home, or schedule a visit.

Remember who else will field these questions. Many water and wastewater personnel work in field operations. When someone sees a crew on their street a week after the letter arrives, that crew becomes your communications channel. A few talking points and a website to point people toward will cover most conversations.

Finally, point the letter somewhere useful. Systems serving more than 50,000 people must post their inventory online, and it's a smart move for everyone else. A searchable map gives residents a place to look up their own address instead of calling the front desk.

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Get the Logistics Right

When it comes to communications, most of our webinar attendees were in decent shape. Roughly 40% had already started sending letters, and close to half had a plan ready but hadn't hit send yet. If you're in either group, these practices will keep the next few months calm.

Prep early. Address cleanup and list segmentation take longer than anyone budgets for. Lock in your content, mailing lists, internal sign-off, and staff FAQs before a single letter prints.

Batch by material type. Three classifications means three letters. Sending them in separate batches keeps the content accurate and makes follow-up calls easier for your customer care team, since they'll know which letter the caller is holding.

Send before the holidays. USPS slows down in December, and every batch of notices brings a wave of calls. Mailing in October or November spreads that volume out. Nobody wants to explain service line classifications on December 23.

Keep the paper trail. Record what went to which address and when. Come July 1, that record makes certification a quick job.

120Water's platform can handle most of this work. It filters affected customers by classification, applies EPA or state-approved templates, prints and mails through local mail houses, and tracks every notice so the audit trail builds itself.

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Quick Answers to Common Questions

If a line is classified as unknown, does that resident still need a notice? Yes. Unknown lines require an annual notice, just like lead and GRR lines. Use the letter to start the work of identifying the material.

Can we write our own letter instead of using a template? You can adapt the language, as long as every required element is there. Check your state's rules first, since some primacy agencies require their own templates or wording.

When can we stop sending notices to an address? Once the entire service line, on both the utility and customer sides, is no longer lead, GRR, or unknown.

Are notices required as part of the LCRI? Yes, and the compliance date is December 1, 2027 (thirty days after the baseline inventory deadline of 11/1/27)

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Watch the Full Session

Notices are only one piece of a community engagement strategy. The full webinar goes further: how utilities are partnering with local organizations to reach residents, how to stay transparent when the news isn't good, and why celebrating milestones matters more than most systems think.

If you missed it, watch the recording and grab our LCRR Annual Notification Checklist to keep your team on track through December.

Spreadsheets were built to hold numbers, not run a compliance program. They can't sync in real time, validate entries, or connect to other systems. For water utilities managing service line inventories and sampling schedules, that gap turns into missed deadlines, incomplete reports, and rising compliance risk as data volume grows.

Why Do Spreadsheets Break Down as a Water Utility Grows?

A spreadsheet works fine for one person and a small, static dataset. It stops working once a utility needs to track thousands of service line records, coordinate field verifications, and report to a state agency on a fixed timeline.

The problem is architecture. A spreadsheet is a file. Compliance work needs a system. Specifically, spreadsheets lack:

• Real-time sync. Field staff, lab technicians, and compliance managers can end up working from different versions of the same file.
• An audit trail. When a regulator asks who changed a record and when, there's often no reliable answer.
• Validation rules. A typo in a service line material field doesn't get flagged. It just becomes bad data.
• Connections to other systems. Lab results, GIS records, and customer data sit in separate files that never talk to each other.

The result: reports that should take minutes require days of manual data entry. When a regulator calls with a question, the answer is rarely at anyone's fingertips.

Regulatory pressure makes the gap worse. The LCRI requires accurate service line inventories on a fixed timeline, and PFAS monitoring is adding sampling requirements many utilities aren't yet equipped for. Missed or late samples already account for roughly 75% of drinking water violations. A workflow with no reminders, no validation, and no shared visibility makes that mistake easy to repeat.

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What Does This Cost Utilities in Practice?

Beyond inefficiency, there's a fragility problem. When data lives in a spreadsheet on one person's desktop, that person becomes a single point of failure. Every retirement takes years of institutional knowledge with it, because that knowledge lived in someone's head, not in a system.

That fragility compounds every time a utility adds a new program, faces a new regulation, or loses the one staff member who understood how the old system worked.

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How Do You Know You've Outgrown Spreadsheets?

A few signs are consistent across utilities:

1. Preparing a compliance report takes days of manual data gathering instead of minutes.
2. Multiple people maintain their own versions of "the real" inventory or sampling schedule.
3. A regulatory question can't be answered without pulling several people off other work.
4. Field data is collected on paper or in disconnected apps and re-entered later, introducing errors.
5. One or two staff members are the only ones who fully understand how the current system works.

If two or more of these sound familiar, the issue isn't staff effort. It's that the underlying data infrastructure hasn't kept pace with what regulations and the public now expect.

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What's the Alternative to Spreadsheet-Based Compliance?

The utilities pulling ahead aren't necessarily the largest or best-funded. They treat data as infrastructure, as fundamental as the pipes in the ground, and build one source of truth that connects sampling, service line inventories, lab results, and public communications.

This doesn't mean digitizing everything at once. Most utilities start by consolidating the highest-priority data, usually service line inventory and sampling records, into one system. Automating reporting and communication workflows comes next, once that foundation is solid.

Here’s what that shift looks like in practice: 

Effort wasn't the bottleneck in any of these cases. A spreadsheet can't drive workflows, trigger notifications, or flag anomalies before they become violations. A tool that can do that changes what's possible.

If you want a deeper framework for figuring out where your utility stands and what the next step looks like, our webinar on digital maturity for water utilities walks through four stages, from overwhelmed and spreadsheet-dependent to fully predictive, with real case studies like the ones above.

We spend a lot of time talking to the people who use 120Water every day. Program managers. Compliance leads. And more and more, the crews out in the field doing the actual work: verifications, replacements, kit drop-offs, the stuff that has to happen before any of it shows up in a report.

One thing we kept hearing, no matter who we asked: the work and the paperwork are still two different jobs.

A crew finishes a verification. They write it down, or fill out a form on a tablet, or snap a photo of a meter. Then, at some point, someone has to take all of that and get it into the system. Maybe that's the same day. Maybe it's Friday afternoon for the whole week. Either way, there's a gap between what happened in the field and what your compliance record says happened. And in this industry, that gap matters. The EPA's own database still shows roughly 22 million service lines of unknown material nationwide, including an estimated 2.1 million known lead lines still in the ground. Finding, verifying, and replacing those lines faster starts with knowing, in real time, what's already been done.

So we built something for that gap. It's called 120Field, and it's live today.

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One tool, not three habits

120Field is a single, mobile-friendly tool for capturing service line verifications, replacements, and sample or pitcher kit drop-offs. No clipboard, no separate notebook for each program, no trying to remember at 4 p.m. what happened at three different addresses. Crews log the work once, right from wherever they are, on whatever device they've got in hand.

That's the part we're most excited for field teams to feel. You shouldn't need three tools and a good memory to do your job well. You should need one tool that works the way your day actually works.

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The record catches up to reality

Here's the part we think office staff and compliance leads are going to love: what gets logged in the field flows straight into 120Water's platform. No export. No import. No re-typing a stack of paper forms into a spreadsheet at the end of the week. The compliance record reflects what actually happened, the same day it happened.

If a regulator calls and asks where things stand, the answer in your system is the real answer, not last Tuesday's answer.

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Built for how fieldwork actually happens

A lot of utilities have service areas where cell signal is a suggestion, not a guarantee. We know that, so 120Field works fully offline and syncs automatically once you're back in range. Smart routing helps plan the most efficient stop order for the day. And if your hands are full or you're standing somewhere typing isn't practical, voice-to-text has you covered.

None of this is about replacing the judgment of the people who do this work. It's about giving that work somewhere reliable to go, without adding a second job on top of the first one.

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A partnership built to move fast

We didn't build the technology behind 120Field alone. We partnered with TeamSolve, a company that's spent years building field operations technology for water and wastewater utilities, to bring this to you faster and get it right. 120Water knows compliance and the relationships that make programs work. TeamSolve knows what it takes to build something that holds up in the field. Put those together, and you get a tool that actually fits how the work gets done, not a piece of software built for the office and handed down to the field.

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What this means going forward

120Field is available now if you're running, or planning, a service line verification, replacement, or sampling program. If your crews are still working off paper, this is a way to say yes to something better without asking them to change how they do their jobs.

We also see this as a step toward something bigger: a future where the people doing the work, the people running the program, and the people overseeing it are all looking at the same real-time picture. We'll have more to say about that down the road. For now, we're glad 120Field is in your hands.

Have questions about getting 120Field set up for your team? Reach out to your 120Water account team. We'd love to help you get started.

Reach out to learn more.