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TCEQ to accept alternative investigation methods for lead service line baseline inventory; portal to accept baseline uploads Nov. 1, 2025
Summary
TCEQ staff said the agency will accept additional investigation methods (including predictive modeling) for baseline inventories required under the Lead and Copper Rule Improvements and will open the SWIFT submittal portal to accept baseline inventories starting Nov. 1, 2025.
Seth Kramer, team leader for TCEQ’s Lead and Copper Monitoring Team, told the Drinking Water Advisory Work Group that the agency will accept additional service-line investigation methods for the baseline inventory required under the federal Lead and Copper Rule Improvements (LCRI).
Background and timing: The LCRI was promulgated federally in 2021 and key compliance dates included an initial service-line inventory due Oct. 16, 2024. The LCRI’s baseline inventory and many new provisions have compliance dates tied to November 1, 2027. Seth said TCEQ will allow systems to begin submitting the baseline inventory through the SWIFT submittal portal as soon as Nov. 1, 2025, two years ahead of the 2027 compliance deadline.
Investigative methods and validation: Seth said EPA guidance lists multiple acceptable methods (records review, two‑point inspection, predictive modeling and emerging technologies). TCEQ will accept those additional methods on the baseline inventory, but systems remain responsible for the accuracy of determinations and must document the method’s efficacy. Under LCRI, lines classified by methods other than records review or two‑point inspection will require a later service-line validation. Seth said the validation pool uses random selection and that the federal rule’s validation sample requirements cap at a fixed number “somewhere around 385” service lines for large systems.
Connectors and template changes: When the portal opens for baseline submissions, the upload template will require connector classification (lead, nonlead, unknown, or no connector present). Systems that previously submitted initial inventories without connector data should plan to add connector information before or after the portal accepts baseline uploads.
Notifications and timing: Seth advised systems that made initial filings or that have many unknowns to plan updates and to watch forthcoming TCEQ guidance; the agency will publish more implementation details and technical guidance ahead of the 2027 compliance dates.
Resources: Seth pointed attendees to TCEQ’s online technical fact sheets for inventory validation and baseline inventory details and said further Q&A and implementation guidance will be provided at future meetings.
