OBSERVER Photo by Braden Carmen Seneca Language and Culture Teacher Jordan Cooke Sr., left, is pictured with Silver Creek Superintendent Dr. Katie Ralston.

Much like the age old question of, “If a tree falls in the forest and no one is around to hear it, does it make a sound?” the Fredonia Central School District was left trying to prove to the State Comptroller’s Office that it did, in fact, take appropriate steps to remediate lead in its water supply despite a lack of required documentation.

The district issued its official response last week to the New York State Comptroller’s report on lead in water testing.

“We are accountable for creating safe learning environments, and we are actively correcting what needs to be improved,” said Superintendent Dr. Brad Zilliox. “At the same time, we believe it’s important to address discrepancies in the report and provide the full context.”

Zilliox stated the review is “a relatively new area of focus for the Comptroller’s Office”, and that the District is “learning a lot along the way.” Fredonia was one of roughly 25 school districts across the state to be selected for review. Other districts with similar results include DeRuyter, East Bloomfield, Glen Cove, Poland, Sullivan, and Tupper Lake school districts.

The report focused on water samples collected in March 2021, during the COVID-19 pandemic, when all school drinking fountains were shut down and inaccessible. The District emphasizes that these circumstances directly impacted the testing process and documentation efforts.

According to the Comptroller’s report, 178 of the 665 water outlets that students and staff could potentially access “were not sampled or properly exempted by District officials” for the 2021 round of testing. The report states that the District’s Business Administrator used a third-party vendor to conduct the lead testing, “and relied on but did not thoroughly review the Vendor’s work”, which led the Comptroller’s office to the determination that it was unclear whether the outlets were below the lead action level.

Fredonia’s response states, “The District rejects the idea that the Business Official did not thoroughly review the report from the third-party vendor. Rather, the report was thoroughly reviewed while relying on the expertise of the vendor.”

Of the 363 outlets that were tested and documented, 111 outlets exceeded the lead action level. The Comptroller reviewed 88 of those outlets with actionable levels of lead, and determined, “District officials did not take appropriate remedial action” for 85 of the 88 outlets reviewed.

The District stated in its response that the outlets were tested during the pandemic and were not accessible to students and staff at the time. The District also stated, “Many were not returned to service until well into the 2022-23 or 2023-24 school years.”

The Comptroller’s Office is not focused on what the District claims, but rather what it can prove.

A focal point of the Comptroller’s report was the lack of documentation by the District. Zilliox explained, “In 2021, the District typically relied on face-to-face interactions, with a variety of information being shared verbally.” Because of that, there was not appropriate documentation for the Comptroller’s review that proved the communication took place or that the appropriate action was taken.

The Comptroller’s Office claimed the District did not communicate with its school community throughout the process. The District clarified that parents/guardians were informed of the testing through the District’s mass communication system, but records of that communication were lost when the District switched to a new system in 2022. The District claimed its former District Clerk “explicitly recalls” facilitating communications through its system at the time. The District claims that testing results were also posted on the District’s website, but the content did not carry over when the District switched providers.

The District was also criticized for its timeliness in terms of reporting the results of the testing. Initial test results are required to be shared with the local health department within 10 business days. The Comptroller stated that while the District received a letter from the testing vendor dated May 22, 2021, but the District reported the results a month later, on June 24, 2021. Fredonia highlighted in its response that communications regarding the 2021 testing were sent to the previous Superintendent, who had already left the district.

The Comptroller criticized Zilliox for a lack of awareness, which Zilliox explained that at the time of questioning, he was unfamiliar with specific details pertaining to the actions of other employees before his tenure or at the onset of his tenure with the District.

The District recently addressed the results at Board of Education meetings in May and July. The District admitted to “gaps” in the water testing processes. These gaps were addressed and resolved when the District performed its most recent round of testing in the spring of 2025. The District’s results in 2016, as well as most recently in 2025, were in line with the associated regulations.

While disputing many of the Comptroller’s findings, the District “has taken full responsibility for areas that need improvement.” Immediate actions include updated signage, fixture replacement, educational outreach, and the development of a Corrective Action Plan in collaboration with environmental experts. The Corrective Action Plan focuses on “process, documentation, and communication” so that the District can be “as prepared as possible for water testing in the future.”

Fredonia has implemented all recommendations offered in the report. All water outlets across the district that are accessible to students and adults and do not have a “Non-potable water/Do not drink” sticker on them are confirmed safe for drinking. This includes all bottle fillers across the district, which are considered safe for drinking.

“The District is committed to the ongoing improvement and transparency in our water safety practices. We appreciate the review, input, and recommendation from (the Office of the State Comptroller), which will positively contribute to this effort,” Zilliox stated in response to the report.

For more information, contact Superintendent Brad Zilliox at the Fredonia Central School District. By phone: (716) 679-1581 or by email: bzilliox@fcsd.wnyric.org