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The Pipe Is Usually Two Pipes
A service line normally has a utility-owned length and a customer-owned length, and almost everything difficult about this subject comes from that one fact.
Straight answer
Most service lines are two pipes with an ownership split at the property boundary. EPA counts a line as replaced only when its entire length, both customer side and system side, is non-lead. Partial replacement is restricted to emergencies and planned work, and requires a dielectric coupling.
Where the split falls
Typically at the property line or at the curb stop, though it varies by jurisdiction and by the age of the arrangement. The utility is responsible for its length; the property owner is responsible for the rest.
This is why an inventory often gives you two categories for one pipe, and why they can differ. Different lengths, laid at different times, by different people.
What counts as replaced
EPA is specific: a line is fully replaced only when the entire length of the service line, both customer side and system side, is non-lead.
Systems have to fully replace the lead and GRR lines under their control within ten years, measured from the 2027 baseline inventory.
Why partial work is restricted
Partial replacement is permitted only in emergencies or alongside work that was happening anyway — a water main replacement, a meter replacement. It does not count toward the mandatory replacement rate, and where it happens a dielectric coupling has to be installed between the new length and the length left behind.
The rule treats a half-done job as something to be limited and recorded rather than as progress, which tells you how it is regarded.
If the owner cannot be reached, or says no
Where a system needs the property owner’s consent to get legal access, EPA sets a floor for trying: at least four attempts to engage the owner using at least two different methods of communication. If consent is still not obtained, the system has to keep sending the annual notification.
So a declined replacement is not the end of the relationship, and a letter that arrives every year is the rule working rather than the rule being ignored.
And the paragraph nobody quotes
A system’s replacement plan has to include a funding strategy that includes ways to accommodate customers who are unable to pay to replace the portion of the service line they own.
That is a requirement on the plan, not a promise of a specific program, and what it produces differs enormously between utilities — full funding in some places, a loan or a deferral elsewhere. It is a question worth asking before you pay for anything, and the plan itself has to be publicly accessible.
Look your address up first.Your utility has published what your service line is made of, and finding out costs nothing. If it turns out to be your side and it needs work, we will route you to a contractor covering your area, found from the ZIP code you give — you are never charged. Service lines are our subject; anything plumbing-related can be put through the same way.
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