The Flagstaff Water Commission received a status update Nov. 20 on the city’s lead and copper service-line inventory and new federal requirements under the EPA’s Lead and Copper Rule Revisions. Jolene Montoya, regulatory compliance section director for water services, said the city submitted an initial inventory to the Arizona Department of Environmental Quality (ADEQ) last year and has since reduced the number of unknown service-line materials while adding roughly 200 service-line records.

Montoya said the system has not exceeded an EPA action level for lead or copper over the years. “As for the results we've gotten over the years, we've never exceeded an action level for lead or copper,” she said. She noted the highest measured lead reading in past sampling was 14 micrograms per liter (parts per billion), which is below the prior 0.015 mg/L benchmark but is relevant as the federal threshold is changing.

Under the revised federal rule, the city must submit a baseline service-line inventory by Nov. 1, 2027, and begin a new, tiered sampling program on Jan. 1, 2028. The new inventory must identify connector pieces including “goosenecks” or “pigtails,” and the city must post a public-facing inventory because it serves more than 50,000 people. Montoya said the replacement plan required by ADEQ/EPA must map how Flagstaff will fully replace lead and galvanized-replacement-risk (GRR) lines under the city’s control within roughly 10 years and include a funding strategy. “This plan has to be publicly accessible because we are over that 50,000 threshold and then posted online,” she said.

Montoya described the city’s approach: records review supported by AmeriCorps interns from Northern Arizona University, visual verification from field crews and selective meter-box inspections. She reported the city has identified a little more than 900 galvanized service lines in its inventory and noted private-side verification remains the most challenging element. To reduce unknowns, staff mailed about 7,900 letters to customers last year and have run public surveys; roughly 40–50 residents have responded to offer assistance in verification.

Commissioners pressed staff on who bears responsibility and cost for private-side replacement. Montoya said the city is waiting on ADEQ guidance about when a private-side line becomes “under the utility’s control” and indicated it appears the customer will bear private-side replacement costs in many cases, although the replacement plan must include funding strategies for customers who cannot pay. She also described required sampling rules for schools and childcare facilities (five sample locations for schools, two for childcare) and the need to provide outreach, notices and filters where criteria require them.

Next steps include continuing the inventory work, preparing the pipe-replacement plan, solidifying public outreach, drafting sampling plans for the new tiered sampling program and awaiting ADEQ/EPA templates and clarifications.

The commission did not take formal action on the item; staff will return with additional details and draft plans as guidance and templates become available.