On March 9, EPA’s ended its listening session to solicit public comments for consideration as it evaluates potential changes to its Consumer Confidence Report (CCR) rule. As part of that process, AMWA’s submitted comments focused largely on the bigger picture CCR concepts under consideration for revision by EPA, including advocating for maximum flexibility for utilities in choosing the most effective, cost-efficient CCR distribution mechanism(s) and a broader effort to study and reassess the clarity and understandability of CCRs. (See AMWA’s comments at http://www.amwa.net/cs/members_only/regulatory_committee_notes.)
As an initial follow-up to the listening session, EPA conducted a short web-based meeting with AMWA and other stakeholders to summarize the comments received and outline next steps in its retrospective review process. Overall, EPA received over 600 comments during the listening session, the majority from the drinking water utility sector. During its presentation, EPA categorized the comments received, however, the relative representation of each position was not given. In particular, the CCR delivery method that appeared to receive the most backing (and advocated by AMWA) during the listening session, providing an electronic link to CCRs, was not apparent.
EPA also presented information on ongoing research and pilot studies that they may use to inform their decision-making process. One referenced pilot study indicated a penetration rate of around 4 percent when water customers were provided an electronic link to access the system’s CCR (i.e., only 4 percent of customers actually clicked through to the report). Though this rate is low, it compares favorably to a penetration rate for general paper marketing /outreach materials of 3.42 percent cited by a direct marketing association. Such information suggests that providing an electronic link to a CCR may be just as effective as current paper delivery methods.
Moving forward, EPA intends to its data collection, research and comment evaluation through this spring with a goal of completing draft recommendations for CCR revisions by late summer. An in-person public meeting will then be scheduled in conjunction with a public comment period for the draft. Final findings and recommendations are scheduled for early 2013. AMWA will continue to closely monitor and engage in this process as it moves forward.
In addition to our continued focus on potential CCR regulatory changes originating at EPA, AMWA is continuing to support bills in Congress that would give many drinking water systems the flexibility to share their annual CCRs electronically rather than through the postal mail. Legislation to this effect introduced in the House (H.R. 1340) currently has 59 bipartisan cosponsors, while a companion Senate measure (S. 1578) has 11.