Ask Commission staff:  What’s the difference between the DNR Service Lateral Inventory v. PSC Annual Report Schedules W-22 & W-29?

As utilities prepare to file their PSC Annual Reports, they may be wondering how the data they included in the service line inventory for DNR (required under the Lead and Copper Rule Revisions) relate to the information that they are required to submit on Schedule W-22 and Schedule W-29 of the PSC Annual Report.  The bottom line to remember in filling out these different reports for different agencies is that they are used for different purposes and therefore include different reporting parameters.  What's important to understand is *how* they differ for your utility, and how you are determining the information you submit for each agency report.  

The DNR Service Line Inventory required all utilities to submit an initial inventory by October 16, 2024.  This initial inventory identified all lead-containing infrastructure by location, regardless of who owned the lateral.  Since most laterals in Wisconsin are owned by utilities between the main and through the curb stop, and by the property owner from the curb stop to the residence, this means that the DNR inventory lists a jointly owned service lateral as a single location from the main to the residence. For more information, see DNR’s informational page for Service Line Inventory Requirements for Lead and Copper Rule Revisions (LCRR). Beginning in 2027, public water systems will be required to submit a baseline inventory that among other things will be required to include an address for every service line location as well as the presence and material of “connectors”, i.e., short segments of pipe that connects the water main to the service line. 

The PSC Annual Report divides the service line lateral inventory into two schedules by ownership type:  Schedules W-22 and W-29.  Schedule W-22 includes all utility-owned service laterals, and Schedule W-29 is reserved for customer-owned service laterals.  Both schedules require utilities to identify the size and material of the laterals in the system, and to update the inventory each year to reflect changes in the data, as well as changes in the number of service laterals. For utilities implementing lead service line replacement programs funded by a Commission-approved financial assistance plan, Schedule W-29 also asks utilities to identify the laterals replaced using this financial assistance.   Commission staff recommends that you use the footnotes in each of these schedules to describe any details that help explain how your utility has completed the report.  If it is helpful for you to keep a record of how this inventory differs from the inventory submitted to DNR, you should note it in the footnotes.   

Since DNR counts a service lateral location as a single location, and the Commission requires you to split that location into separate reports if ownership is shared between the utility and the customer, these inventories will seldom match.  Prior to the Lead and Copper Rule Revisions, which require the submittal of a service line lateral inventory to the DNR, the PSC Annual Report was the *only* inventory of Wisconsin service laterals. During this time, DNR would require utilities to complete Schedules W-22 and W-29 in order to be eligible for Safe Drinking Water Loan Program (SDWLP) funding to replace lead service lines.  DNR now relies on the data submitted to the DNR for all SDWLP requirements, and the Commission relies on Annual Report data in its financial regulation of Wisconsin public water utilities.  

If a utility requires any assistance regarding the Annual Report, please contact the Annual Report Help Desk at 608-267-2335 or by email at PSCWaterAnnualReports@wisconsin.gov.  If a utility requires an extension to the filing deadline, please submit a written request to the above email prior to May 1, 2026. The written request should include the reason the utility needs an extension and when the utility plans to submit the report.  Note that extensions are rarely authorized for more than one month.  

In January, the Commission will send letters to utilities that have not filed a conventional rate case (CRC) in more than 25 years as part of our CRC Outreach Program. The Commission began the CRC Outreach Program two years ago to ensure that utilities continue to operate in a financially sustainable manner, and that customer rates are fair and reasonable. Through this initiative, the Commission aims to ensure the financial integrity of water utilities in Wisconsin and prepare them for future financial needs. 

In the current climate, utilities face many challenges that may affect rates, including rising operation and maintenance expenses, inflation, aging infrastructure, and emerging contaminants.  It is important to file CRCs frequently to keep up with operational and capital costs and limit rate increases to reasonable amounts for customers. 

Utilities that have not filed a CRC in 25 years may be operating with outdated tariffs and insufficient revenues.  Review of accounting records through regular rate increases helps prevent billing errors, unauthorized construction, and Annual Report issues.  Regular cost of service and rate design analysis ensures tariffs are current and accurate, rate designs are up-to-date and fair, and most importantly prevents rate shock. Furthermore, regular CRC filings strengthen the relationship between utility and Commission staff. However, utilities should have a plan to evaluate their financial metrics regularly to determine if a rate increase is needed. 

In 2025, the Commission reached out to five communities through its CRC program.  Three of the five utilities responded by filing CRCs that are currently before the Commission. The Commission will open an investigation into the rates of the remaining two utilities that have not filed a CRC.  In 2026, the Commission will contact five to seven additional utilities who have not filed a CRC in at least 25 years, asking those utilities to file by December 31, 2026. To learn more about the CRC process, see this Conventional Rate Case Overview. 

New Resources Available: Updated Retirement Benchmarks

Did you miss the last Currents newsletter?  Now you can access past editions on the Commission website.  Find them here:  PSC Water Currents Newsletter 

Coming Soon:  Utility Inquiry Forms 

Commission staff in the Division of Digital Access, Consumer and Environmental Affairs receive an average of 700 utility inquiries each year. Currently, inquiries submitted via e-mail must be manually entered into the utility portal for record keeping. To improve efficiency and better utilize staff time, we are introducing a utility inquiry form, similar to the existing process for filing a customer complaint with the Commission. Additional information will be provided once the inquiry form is launched on the Commission website.

Deadlines, Training & Resources

• January 15, Noon:  Pipes, Pressure, and a Precious Resource: The Engineering Challenge of Aging Water Infrastructure.  Presented by the Environmental Finance Center Network (EFCN), a university-based organization creating innovative solutions to address the difficult how-to-pay issues of environmental improvement.   

• March 8-14:  National Groundwater Awareness Week 

• March 16-22:  Fix a Leak Week | US EPA 

• March 22:  World Water Day | UN-Water 

• March 24-27:  Commission staff will be providing an update at the Wisconsin Rural Water Association (WRWA) Annual Conference at the Resch Center in Green Bay. Watch WRWA for event details.

Simplified Rate Cases: the Commission approved each of the following utilities for a 3% increase through the SRC process: