How Fresno Turned an Inherited LCRI Backlog Into a Model Compliance Program
LSL Inventory
LSL Verification
Sampling
Lead & Copper Rule

The Challenge
Chad Colby stepped into a compliance role at the City of Fresno mid-stream. The city's agreement with 120Water was already underway before he arrived, but it had passed through more than one set of hands at the city and still wasn't finalized. Chad, new to the position and unfamiliar with vendor contracting, had to pick up the thread while he was still learning the job himself.
Once the agreement was finalized, the real lift began: data collection for the Lead and Copper Rule Improvements (LCRI). Fresno had no staff to dedicate to the effort, so Chad folded the work into his own schedule, pulling old work orders and digging through spec books and standard drawings at local libraries to document historical service line materials, including where galvanized pipe had been swapped for copper or polyethylene.
Some of that history was gone for good. The city ran largely on paper when Chad started there in 1997, and years of old timesheet data that had since been entered into a legacy system disappeared when that system was retired; nobody could say for certain whether it had ever been saved, or where. The gap meant Fresno couldn't shrink its inspection universe as much as it otherwise might have.
The Approach
120Water didn't hand Fresno a single mandate. It laid out the available paths and let the city choose the one that fit, and Fresno went with stratified random sampling. Once 120Water's team supplied address lists by date range, Fresno fed that data into routing software paired with its own GIS team, letting field crews move house to house in the most efficient order to verify service lines quickly.
When California's state portal wouldn't accept Fresno's data in its native format, 120Water worked with the state to get an approved spreadsheet format cleared, which let Fresno get its submission in on time even though the data collection on the front end had taken longer than expected.
120Water also built the public-facing service line inventory portal the state now requires, giving Fresno residents a simple way to look up their own service line status rather than relying on inserts that, as Chad puts it, most people throw away with the rest of the bill mail.
“120Water basically led us down the path we needed to go to achieve our goal, which was keeping the state happy. It's been very streamlined, based on [120Water’s] recommendations.”
— Chad Colby, City of Fresno
The Outcome: Effectively Non-Lead, But Not Finished
The stratified random sampling came back with good news: Fresno's system tested out as effectively lead-free, pending the LCRI’s non-lead validation process requirement. For most systems, reaching non-lead status clears away the bulk of LCRI's ongoing burden.
But it doesn't clear all of it. Systems that go non-lead still have Lead In Facilities (LIF) work ahead of them, and still have to keep submitting their inventory annually until every remaining connector material is formally verified, a process with no built-in end date. That's the part of the story that doesn't stop when the November 1 deadline does.
Staying Ahead of What's Next
That ongoing work is part of why Fresno didn't slow down once its system was classified as non-lead. Its water quality team is now moving on school and childcare sampling ahead of the 2028 mandate, well before the compliance clock officially starts. When Chad looped in the water quality team, they discovered another vendor they'd considered didn't have a program built for this kind of sampling. After a walkthrough with 120Water, the decision was easy.
As Chad understands it, that same public portal built for lead service line status is expected to extend to the new program, giving Fresno another forward-facing resource for residents.
The Result
- A system-wide verification that came back effectively non-lead, pending the LCRI’s final non-lead validation.
- A completed, verified LCRR service line inventory, submitted to the state on time despite a slow, records-limited start and an LCRI service line inventory to be submitted in 2027.
- A stratified random sampling program paired with GIS-integrated routing that made field verification fast and efficient.
- An approved state data submission pathway, unblocked through direct coordination with California's reporting system.
- A public-facing service line status portal that meets state disclosure requirements and, in Chad's view, beats a one-off mailer most residents would toss anyway.
- Momentum on the 2028 school and childcare sampling mandate, tackled early instead of at the deadline.
“I'm proud of our partnership, really, that's the bottom line. I'm proud of our partnership and the help that we've received and the goals that we've met together.”
— Chad Colby, City of Fresno
Looking Ahead
Asked where he sees the partnership going, Chad doesn't hesitate: he expects it to continue. 120Water's team tracks the regulatory shifts (roughly 850 pages of LCRI requirements alone, with more on the way) and translates them into language Chad can understand and act on.
For utilities staring down their own LCRI inventory, especially those managing it without dedicated staff, Chad's advice is straightforward: don't wait, and find a partner who will keep you on task while still letting you make the final call. And for the growing number of systems approaching or reaching non-lead status, Fresno's experience makes another point just as clearly: going non-lead clears most of the load, but LIF work and ongoing connector verification don't disappear, and a partner worth keeping is one that's still showing up after the deadline has passed.
"Our experience [with 120Water] has been great. They walked us through every stone that needed to be turned.”
Chad Colby
City of Fresno


