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Water staff report: lead-service-line inventory shows no lead; city to test schools and childcare sites
Summary
City staff reported that a state-required lead service line inventory found no lead service lines in the city’s sample; staff will use remaining funds and a contractor (120 Water) to sample 56 schools and childcare sites in the first year. The commission received an informational update on federal rule changes and monitoring requirements.
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City water staff told the Santa Barbara Water Commission that the city’s Lead Service Line Inventory — required by the Environmental Protection Agency’s revised Lead and Copper Rule — identified no lead service lines in the sample and that staff submitted a non-lead inventory to the State.
Dana Hoffenberg, water resources analyst, said the city asked a consultant (120 Water) and deployed staff to stratify and field‑verify a statistically significant sample of otherwise unknown customer service lines. “We did not find a single instance of customer lead service lines in the city,” Hoffenberg said, and the inventory submitted to the State listed all service lines as non-lead.
Staff said the inventory covered roughly 27,000 service lines in the city and that field crews physically inspected about 1,750 customer-owned service lines in roughly five weeks; staff reported an average of 60 verifications per day and a peak above 200 verifications in a single day. Because no customer service lines were found to be lead in the verified sample, staff said they used statistical methods (95% confidence interval, ~5% variance by decade/age cohort) to assume the remaining unknowns are non-lead for the required State submission.
The presentation covered federal and state rule changes. Staff summarized recent provisions of the Lead and Copper Rule revisions and the subsequent Lead and Copper Rule Improvements: sampling from customer taps (first-draw after six hours stagnation), a reduced federal action level of 10 parts per billion for lead (previously 15 ppb), a new requirement to inventory and sample schools and childcare facilities, and a phased requirement to replace confirmed lead service lines over 10 years. Because Santa Barbara’s submitted inventory is non-lead, staff said the city is not currently required to implement a replacement plan.
Commissioners asked how the city validated the inventory and whether older homes were likely to contain lead; Hoffenberg said the oldest-decade cohort was the smallest category, and staff noted that lead in service lines has historically been less common in the city’s water-service area. Hoffenberg emphasized that the inventory covers the service-line segment from the water main to the home connection (city-owned service line to the meter, private side from meter to building), and staff cannot certify or rule out lead fixtures or plumbing inside private dwellings.
Staff also described the requirement to sample schools and childcare facilities. The city identified 56 licensed locations (17 in-home daycares, 29 licensed childcare centers, and 30 K–12 schools, public and private) and plans to use the existing 120 Water contract to perform outreach, supply sampling kits and postage, coordinate with a laboratory, and publish results using the same public portal developed for the service-line inventory. Staff said they will complete all required school and childcare sampling in year one using contract funds freed by the non-lead inventory outcome.
The commission heard technical details about sampling: the rule requires a first-draw one-liter sample after six hours stagnation; for properties with confirmed lead service lines the federal guidance includes an additional fifth-liter sample for lead. Staff noted the city is currently on a reduced monitoring schedule (30 tap samples every three years) because historical results are well below both the old and new action levels.
The presentation was informational; no commission vote was required. Staff said further state guidance on implementation of the most recent federal improvements is pending and the city will continue to coordinate with the State and regional wastewater and water agencies.

