Engineer warns city to accelerate lead-and-copper inventory ahead of 2027 TCEQ deadline

A consulting engineer told the City Council workshop that the city must complete a full service-line inventory under the Texas Commission on Environmental Quality’s (TCEQ) lead-and-copper rule by 2027 and begin replacement work through a 10‑year schedule ending in 2037.

Andy Visalia, engineer with Jacob & Martin, said the revised rule has expanded obligations for utilities and now makes cities responsible for service-line classification in combination with customer-side information. “Per TCEQ, you are not responsible for the customer side except for the lead and copper rules. They are now making you responsible for that, including if it is a lead line,” Visalia said, explaining that the TCEQ inventory spreadsheet (the consultant referenced the TCEQ form used for reporting) uses system-side and customer-side information to classify an entire service line.

Visalia told the council the city met an earlier October 2024 submittal deadline but still has a substantial inventory to complete. He said staff and consultant work from late 2024 into 2025 reduced the number of unknown service-line records, but the inventory remains incomplete: “We still have 1,851 to do,” Visalia said when summarizing remaining work, and he said the city has identified 74 lines as lead requiring future replacement. He said the regulation requires a plan by 2027 and a phased replacement sequence through 2037, with the rule’s replacement schedule dividing the work evenly across the 10‑year compliance window.

Because the TCEQ rule’s funding pathways and cost-allocation details remain unclear, Visalia urged the city to hire a dedicated person (full-time or part‑time) to complete the inventory. He told the council that a staff member who previously worked on the inventory advanced progress but then left city service; the consultant estimated that a dedicated hire (roughly a 0.75 FTE over the inventory period) would materially accelerate completion. Visalia volunteered to share his firm’s work products and to assist the city in training new staff.

The consultant emphasized public‑education and sampling requirements for schools and child‑care facilities, noting that buildings constructed after Jan. 1, 2014, or that received a full plumbing replacement are excluded from certain sampling obligations. The consultant recommended staging sampling and outreach (for example, one school or one child‑care site per year) to reduce operational strain on staff.

Councilmembers asked about funding and staffing. Visalia said the city previously pursued an EPA-funded program administered through the Texas Water Development Board but missed the prior funding cycle; future state or federal funding may be available but was not guaranteed. Councilmembers and staff discussed using meter-reading or other field visits to augment inventory work and agreed that additional staff or a contract hire would be necessary to meet the 2027 inventory deadline.

Ending: The city did not adopt a hiring or funding action at the workshop; staff and the consultant agreed to coordinate on next steps and to prepare a staffing and budget recommendation for council consideration.