EPA released a long-awaited “interpretive memorandum” on January 3 to clarify whether community water systems may use electronic delivery methods such as email and Internet posting to meet the requirements of the Consumer Confidence Report (CCR) Rule. According to EPA’s memorandum, beginning this year water systems will have the option of publishing the CCR on a public website and directly notifying customers of the report’s availability.
This new interpretation represents a victory for AMWA, which has spent much of the past two years advocating EPA and Congress to allow water systems to utilize methods other than postal mail for CCR delivery. AMWA supported legislation introduced in the House and Senate that would have amended the Safe Drinking Water Act to allow electronic distribution in the place of hard-copy mailing, and last fall the association submitted comments to EPA following the release of its draft interpretive memo. The final memo released last week is consistent with AMWA’s position and has the potential to save community water systems across the country millions of dollars in printing and postage costs.
Community water systems that choose to publish their CCRs on a public website in lieu of mailing a paper copy to each customer are required to include a prominent announcement on or with a water bill or other notice sent directly to customers explaining that the CCR is available online at a specified URL. If a utility sends bills to certain customers via email, links to the CCR – or an electronic copy of the CCR itself – can be emailed to those customers. Water systems utilizing electronic delivery methods still have to meet the CCR Rule’s July 1 deadline for CCR distribution and, in all cases, customers must be notified of the option to receive a paper copy of the CCR upon request.
EPA’s memo does not require any water system to change its current CCR distribution method or send CCRs electronically if it prefers not to. In addition, all other CCR Rule requirements, such as making a good faith effort to share CCRs with consumers who do not receive water bills, remain unchanged.
EPA will conduct a webinar on January 17 during which the agency will explain its envisioned electronic CCR delivery framework. The complete text of the CCR interpretive memorandum, as well as webinar registration instructions, are available at EPA’s CCR Rule webpage. The webpage also includes links to EPA’s “Consumer Confidence Report Rule Retrospective Review Summary,” which summarizes the entire CCR review process and presents findings and potential follow-up actions.