Consumer Confidence Report (CCR) Rule
Retrospective Review Summary
U.S. Environmental Protection Agency
Office of Ground Water and Drinking Water
1200 Pennsylvania Ave., N.W.
Washington, DC 20460
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Office of Water (46O7M)
EPA816-S-12-001
httpc//epa.goy/safewater
December 2O12 Printed on Recycled Paper
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OF
Definitions and Abbreviations iii
Definitions iii
Abbreviations v
Executive Summary 6
The Consumer Confidence Report Rule Retrospective Review 9
The Consumer Confidence Report 9
EPA's Final Plan for Periodic Retrospective Review 10
CCRRule Retrospective Review Process 11
CCR Content Understandability 13
Summary of Stakeholder Feedback 14
Potential Follow-up Actions 15
Reporting MCLs in Numbers Greater Than or Equal to 1.0 16
Summary of Stakeholder Feedback 17
Potential Follow-up Actions 18
Reporting Tier 3 Public Notice in the CCR 20
Summary of Stakeholder Feedback 21
Potential Follow-up Actions 22
Certification of CCR Delivery and Content by the Community Water System to the Primacy
Agency 24
Summary of Stakeholder Feedback 24
Potential Follow-up Actions 25
Electronic Delivery of the CCR 26
Summary of Stakeholder Feedback 27
CCR Retrospective Review Actions on Electronic Delivery 29
Electronic Delivery Cost Savings Analysis 30
Conclusion and Next Steps 31
CCR Rule Retrospective Review Summary i December 2012
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References 32
Appendix A: Consumer Confidence Report Electronic Delivery Cost Savings Analysis
CCR Rule Retrospective Review Summary ii December 2012
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DEFINITIONS
CCR iWriter - This on-line application provided by the EPA that enables a community water
system to produce a regulation-compliant Consumer Confidence Report (www.ccriwriter.com).
Code of Federal Regulations (CFR) -A codification of the general and permanent rules
published in the Federal Register by the departments and agencies of the Federal Government.
Community Water System - Means a public water system which serves at least 15 service
connections used by year-round residents or regularly serves at least 25 year-round residents.
Compliance monitoring - The EPA's drinking water standards program has established health-
based standards for more than 90 contaminants. Water systems are responsible for conducting
monitoring of drinking water to ensure that the water meets all drinking water standards.
Health-Based Violation - A violation of a National Primary Drinking Water Standard (e.g.,
maximum contaminant level.)
Maximum Contaminant Level (MCL) - The highest level of a contaminant that is allowed in
drinking water. MCLs are set as close to MCLGs as feasible using the best available treatment
technology and taking cost into consideration.
Maximum Contaminant Level Goal (MCLG) - The level of a contaminant in drinking water
below which there is no known or expected risk to health. MCLGs allow for a margin of safety
and are non-enforceable public health goals.
Primacy agency - State, territory or Indian Tribe with primary enforcement responsibility for
public water systems.
Primacy revision application - Pursuant to 40 CFR 141.12(b)(l), states, Tribal governments or
territories must submit a complete and final request for approval of program revisions to adopt a
new or revised EPA regulation. Requests must be submitted to the EPA Administrator no later
than two years after promulgation of a regulation.
Public Notification (PN) - Public water systems must notify their consumers when they violate
EPA or state drinking water regulations (including monitoring requirements) or otherwise
provide drinking water that may pose a risk to consumer's health. SDWA § 1414 (c) & 40 CFR
§§ 141.201-211.
CCR Rule Retrospective Review Summary iii December 2012
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Public water system (PWS) - Means a system for the provision to the public of water for
human consumption through pipes or, after August 5, 1998, other constructed conveyances, if
such system has at least 15 service connections or regularly serves an average of at least 25
individuals daily at least 60 days out of the year. Such term includes: any collection, treatment,
storage, and distribution facilities under control of the operator of such system and used
primarily in connection with such system; and any collection or pretreatment storage facilities
not under such control which are used primarily in connection with such system. Such term does
not include any "special irrigation district." A public water system is either a "community water
system" or a "noncommunity water system."
Safe Drinking Water Act (SDWA) - The main federal law that ensures the quality of
Americans' drinking water. Under the SDWA, the EPA establishes standards and other
requirements for the provision of drinking water and oversees the primacy agencies and public
water systems who implement those requirements.
Treatment Technique - A required process intended to reduce the level of a contaminant in
drinking water.
Uniform resource locator (URL) - A specific character string that when typed or copied into
an Internet address box will take the user to a specific website or document.
CCR Rule Retrospective Review Summary iv December 2012
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ABBREVIATIONS
CCR: Consumer Confidence Report
CFR: Code of Federal Regulations
EPA: United States Environmental Protection Agency
ICR: Information Collection Request (as required by the Paperwork Reduction Act)
MCL: Maximum Contaminant Level
MCLG: Maximum Contaminant Level Goal
mg/L: Milligrams per Liter
MRDL: Maximum Residual Disinfectant Level
MRDLG: Maximum Residual Disinfectant Level Goal
NDWAC: National Drinking Water Advisory Committee
NPDWR: National Primary Drinking Water Regulation
PN: Public Notification
ppb: Parts per billion
ppm: Parts per million
SDWA: Safe Drinking Water Act
URL: Uniform resource locator
CCR Rule Retrospective Review Summary v December 2012
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In January 2011, President Obama issued Executive Order (EO) 13563 which charged each
federal agency to "develop.. .a.. .plan, consistent with law and its resources and regulatory
priorities, under which the agency will periodically review its existing significant regulations to
determine whether any such regulations should be modified, streamlined, expanded, or repealed
so as to make the agency's regulatory program more effective or less burdensome in achieving
the regulatory objectives.1" EPA 's Final Plan for Periodic Retrospective Reviews (the Plan),
published August 2011, identified the Consumer Confidence Report Rule as one of the
regulations to examine. The Consumer Confidence Report (CCR) Rule Retrospective Review
was conducted so that the EPA could "explore ways to promote greater transparency and public
participation in protecting the Nation's drinking water in keeping with EO 13563's directive to
promote participation and the open exchange of information." (US EPA, 2011)
The CCR is an annual water quality report that a community water system is required to provide
to its customers. The CCR is a key element of the public right-to-know provisions in the Safe
Drinking Water Act (SOWA) and the CCR Rule is the regulation that the EPA wrote to
implement this SDWA provision. The CCR Rule requires community water systems to include
the following information (and more) in their annual water quality report:
• The regulated contaminants detected during the community water system's most recent
round of monitoring (within five years), and the concentrations of these contaminants
compared to regulatory levels (called maximum contaminant levels or MCLs),
• Health effects information related to violations of MCLs and treatment technique
requirements, and
• For immunocompromised persons, specific health information about arsenic and nitrate
when detected at certain levels, in addition to lead and its effects on children.
This information is provided to help consumers make informed decisions about their drinking
water. It is a requirement in the CCR Rule that community water systems mail or otherwise
directly deliver these reports to bill-paying customers.
Stakeholders commenting on the agency's draft plan for retrospective reviews identified five
areas for the CCR Rule Retrospective Review: 1) CCR understandability; 2) reporting MCLs in
1 "Improving Regulation and Regulatory Review (Executive Order 13563)." 76 FR 3821 (January 21, 2011).
Available from: the Government Printing Office's Federal Digital System (FDsys):
http://www.gpo.gov/fdsys/pkg/FR-201 l-01-21/pdf/201 l-1385.pdf; Accessed: 08/15/11.
CCR Rule Retrospective Review Summary 6 December 2012
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numbers greater than or equal to 1.0; 3) reporting period for including a Tier 3 Public Notice
(PN) in the CCR; 4) the certification of CCR delivery and content by the community water
system to the primacy agency; and 5) electronic delivery of the CCR. This document summarizes
the five areas and the associated feedback the agency received. It also presents potential follow-
on actions, including CCR Rule revisions, which the agency could consider, as resources allow.
The agency received a wide array of feedback on the topic areas and ideas from commenters on
changes that could allow for burden reduction for community water systems and/or primacy
agencies as well as enhancing readership. CCR understandability describes commenters'
perspectives on how understandable the CCR is for readers. Commenters also suggested that
CCR certification compliance could be improved by aligning the certification and delivery
reporting dates; however, the CCR Rule does not prevent this action so a rule change is not
necessary. A possible burden reduction area identified was an adjustment of the Tier 3 public
notice timeline to allow for a full year of Tier 3 public notices to be reported in the CCR.
However, the public notice timeline was established in the SDWA and would require a statute
change which is beyond the scope of the CCR Retrospective Review. Some commenters
expressed concern with the requirement to report MCLs in units greater than 1.0. The concerns
ranged from the units causing unwarranted alarm among consumers to some small systems
having difficulty making the conversions to support for the use of the CCR units which allows
for greater public understanding of the information in the report. The EPA found that the
comments could mostly be addressed through training and guidance focusing on best practices
and proper rule implementation.
During the CCR Rule Retrospective Review, most public comments received by the EPA were
surrounding electronic delivery of the CCR. In response, the EPA released an interpretive
memorandum called Safe Drinking Water Act - Consumer Confidence Report Rule Delivery
Options along with an attachment entitled Consumer Confidence Report Electronic Delivery
Options and Considerations. The memorandum outlines a framework for what forms of
electronic delivery are and are not acceptable under the CCR Rule. In the attachment, the agency
outlined two implementation approaches for electronic delivery: 1) Paper CCR delivery with an
option to request an electronic CCR, or 2) Electronic CCR delivery with an option to request a
paper CCR. The EPA also outlined five electronic delivery methods: 1) CCR embedded in an
email message; 2) CCR sent as an attachment to an email, 3) URL linked directly to the CCR
sent via email; 4) URL linked directly to the CCR mailed to customers (e.g., via water bill itself,
water bill enclosure, separate mailing, etc.); and 5) additional electronic delivery methods that
meet the definition of direct delivery.
Based on the EPA's analyses and input provided by stakeholders throughout the CCR Rule
Retrospective Review, the agency does not intend to revise the CCR Rule at this time. The EPA
CCR Rule Retrospective Review Summary 1 December 2012
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sees the framework for electronic delivery as an opportunity for long-term burden reduction for
community water systems and primacy agencies while maintaining the integrity of the CCR and
promoting greater transparency of drinking water information to all consumers receiving water
from community water systems. A cost estimate analysis found that community water systems
may find the greatest cost savings in the fewest years by providing a URL that links directly to
the CCR included on customers' water bill statements.
In 2013, the EPA plans to host a webinar training on electronic delivery of CCRs as outlined in
the interpretive memo and attachment and work with primacy agencies to assist community
water systems that transition to CCR electronic delivery. In response to the other four topic areas
explored during the CCR Rule Retrospective Review, the EPA may host another webinar
training to review some of the best practices community water systems may want to incorporate
into their own CCRs. As resources allow, the EPA may also update guidance, templates and
factsheets to reflect what was learned during CCR Rule Retrospective Review.
CCR Rule Retrospective Review Summary 8 December 2012
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The Consumer Confidence Report (CCR) is a key element of the public right-to-know provisions
in the Safe Drinking Water Act (SDWA) to provide transparency and accountability. The SDWA
requires each community water system to mail to each customer at least once annually a report
on the level of contaminants in the drinking water delivered by those systems. The SDWA
requires CCRs to include at a minimum:
• Source(s) of water.
• Definition of the terms "maximum contaminant level goal," "maximum contaminant
level," "variances" and "exemptions."
• Any regulated contaminants detected and corresponding MCLGs, MCLs, level of
detection in water system and for any regulated contaminant under violation of the MCL
a brief statement in plain language regarding the contaminant health concerns.
• Compliance status with National Primary Drinking Water Regulations.
• Notification if the system is operating under a variance or exemption and the basis on
which the variance or exemption was granted.
• Information on monitoring for Cryptosporidium, Radon and unregulated contaminants for
which monitoring is required.
• Statement that presence of contaminants does not necessarily pose a health risk and that
more information can be obtained by call the U.S. Environmental Protection Agency
hotline.
The CCR Rule is the National Primary Drinking Water Regulation (NPDWR) that EPA wrote to
implement Section 1414 of the SDWA. EPA promulgated the CCR Rule in August 1998.
Community water systems were required to deliver their first reports by October 1, 1999, and
thereafter by July 1st annually. The CCR Rule requires community water systems to include all
required SDWA information and additional information in the annual water quality report
including:
• A detected contaminant table to display information.
• Additional definitions for "treatment technique," "action level,' "maximum residual
disinfectant level goal" and maximum residual disinfectant level."
• Specific health information about arsenic and nitrate when detected at certain levels, in
addition to lead and its effects on children.
CCR Rule Retrospective Review Summary 9 December 2012
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• A multilingual statement about the importance of the report as required following a
primacy agency determination that there are large proportions of non-English speaking
residents.
• Water system contact information.
• Ground water rule unaddressed significant deficiencies.
Along with CCR content requirements the CCR Rule establishes delivery requirements for
community water systems. All community water systems must mail or otherwise directly deliver
one copy of the CCR to customers by July 1st annually.
Community water systems serving fewer than 10,000 persons are required to mail or otherwise
directly deliver these reports unless the Governor of a state, his or her designee or certain Tribal
Leaders have allowed these community water systems to provide the reports by other means.
Under this mailing waiver allowance community water systems serving fewer than 10,000
persons must publish the CCR in one or more local newspapers and inform the customers that
the report will not be mailed. Community water systems serving 500 or fewer persons may
provide notice at least once a year to their customers by mail, door-to-door delivery or by posting
in an appropriate location that the CCR is available upon request.
All community water systems must also make a "good faith" effort to reach non-bill paying
consumers through a mix of appropriate methods including posting on the Internet, mailing to
postal patrons in metropolitan areas, advertising the availability of the report in the news media,
posting in public places, etc. No later than three months following delivery of the CCR a
community water system must certify to the primacy agency that the CCR was delivered to its
customers and that the information contained within the CCR is correct and consistent with the
compliance monitoring data previously submitted to the primacy agency.
In January 2011, President Obama issued Executive Order (EO) 13563 which charged each
federal agency to "develop.. .a.. .plan, consistent with law and its resources and regulatory
priorities, under which the agency will periodically review its existing significant regulations to
determine whether any such regulations should be modified, streamlined, expanded, or repealed
so as to make the agency's regulatory program more effective or less burdensome in achieving
CCR Rule Retrospective Review Summary 10 December 2012
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r\
the regulatory objectives. " EPA 's Final Plan for Periodic Retrospective Reviews (the Plan),
published August 2011, identified 35 regulations for review. Sixteen regulations were
categorized as "early action" meaning the Agency identified specific steps which could lead to
modifying, streamlining, expanding or repealing a regulation during the 2011 calendar year. The
other 19 regulations would be reviewed over a longer time frame in order to assess whether
actions leading towards revisions would be needed. Included in the list of 19 regulations is the
Consumer Confidence Report Rule. This Rule was included in the Plan so that EPA could
"explore ways to promote greater transparency and public participation in protecting the Nation's
drinking water in keeping with EO 13563's directive to promote participation and the open
exchange of information." (US EPA, 2011)
During the development of the agency's Draft Retrospective Review Plan in 2011, there were
two opportunities for public comment as well as an opportunity for stakeholders to attend public
meetings. Stakeholders identified five areas in the CCR Rule in which the EPA could potentially
improve the effectiveness of communicating drinking water information to the public or reduce
the burden of community water systems and primacy agencies. In the final version of the Plan,
the EPA agreed to "look for opportunities to improve the effectiveness of communicating
drinking water information to the public, while lowering the burden of water systems and states."
(US EPA, 2011) The five areas for the CCR Rule Retrospective Review include the following:
1. CCR understandability;
2. Reporting MCLs in numbers greater than or equal to 1.0;
3. Reporting period for including a Tier 3 Public Notice (PN) in the CCR;
4. The certification of CCR delivery and content by the community water system to the
primacy agency; and
5. Electronic delivery of the CCR.
This document summarizes the five areas and the associated feedback the agency received. It
also presents potential follow-on actions, including CCR Rule revisions, which the agency could
consider, as resources allow.
The EPA's CCR Rule Retrospective Review consisted of two public listening sessions; an
evaluation of primacy agency regulations on CCRs and Tier 3 public notices; market research on
2 "Improving Regulation and Regulatory Review (Executive Order 13563)." 76 FR 3821 (January 21, 2011).
Available from: the Government Printing Office's Federal Digital System (FDsys):
http://www.gpo.gov/fdsys/pkg/FR-201 l-01-21/pdf/201 l-1385.pdf; Accessed: 08/15/11.
CCR Rule Retrospective Review Summary 11 December 2012
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the use of electronic delivery in the water sector and across other industries; a review of existing
studies and surveys on the usefulness of the CCR and cost estimates for electronic delivery, as
well as customers' CCR delivery method preference; and an analysis of potential cost savings
associated with electronic delivery of CCRs. The EPA also convened an internal workgroup to
consider stakeholder feedback and develop a strategy for the review. Documents supporting the
CCR Retrospective Review may be found in Docket ID No. EPA-HQ-OW-2012-003 5
(www.regulations.gov).
EPA held a CCR Rule Retrospective Review listening session in February 2012 in order to
obtain feedback on the five areas mentioned above. Discussion questions pertaining to the five
areas were presented in the web-dialogue listening session, and the public was provided an
opportunity to submit comments through a dedicated website over a two-week period. In the
online webinar that began the listening session, there were 678 attendees who participated. The
web-dialogue drew in 697 participants and received a total of 630 comments. A second public
listening session was held on October 1, 2012, in Arlington, VA, where the public could attend
in person or participate in a listening only capacity via the Internet. The October 2012 meeting
focused solely on issues involving the potential for electronic delivery of the CCR. This topic
generated the greatest number of comments received by the EPA in the development of the Plan
in 2011 and from the February 2012 listening session. The EPA solicited comment for 30 days
on a draft document outlining potential electronic delivery methods and implementation
approaches, and the agency received a total of 813 comments. (77 FR 55833, September 11,
2012)
The remainder of this document presents a summary of the issues identified by stakeholders and
describes possible agency activities to address these issues.
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The purpose of the CCR is to provide customers with information from their water system that
will enable them to make informed choices about their drinking water. SDWA Section
1414(c)(4)(A) requires the CCR regulation "to require.. .once annually a report on the level of
contaminants in the drinking water purveyed by that system. Such regulations shall provide a
brief and plainly worded definition of the terms... and brief statements in plain language
regarding the health concerns that resulted in regulation of each regulated contaminant." As
drinking water standards are established then CCR content requirements are updated, thereby
increasing the technical information found in the CCR.
In the preamble to the proposed CCR Rule, the EPA explained the importance and purpose of the
CCR as a communication tool between community water systems and customers (63 FR 7605,
February 13, 1998):
The Consumer Confidence Reports are the centerpiece of public right-to-know in SDWA.
The information contained in these reports can raise consumers' awareness of where their
water comes from, show them the process by which safe drinking water is delivered to their
homes, [and] educate them about the importance of prevention measures such as source water
protection to a safe drinking water supply. The reports can be a tool that starts a dialogue
between consumers and their drinking water utilities, and one that gets consumers more
involved in decisions which may affect their health. The information can be a means for
consumers, especially those with special health needs to make informed decisions regarding
their drinking water. And finally, the reports are a key to unlock more drinking water
information. They will provide access through references or telephone numbers to source
water assessments, health effects data, and additional information about the water system.
The EPA was aware of the potential complexity of the CCR and the information to be conveyed
while developing the CCR Rule in 1998. During regulatory development, the EPA considered
what violation information should be included without overwhelming the public. The EPA also
requested public comment on what types of violations should be included in the CCR. In the
preamble to the final CCR Rule (63 FR 44520, August 19, 1998), the EPA wrote:
The majority of commenters agreed that all violations, not just those posing a health risk,
should be reported in the CCR. Commenters stated that increased awareness of violations
would lead to increased compliance with regulations.
In the preamble to the final CCR Rule, the EPA also noted that focus groups were convened "to
test various alternatives for the definitions of MCL and MCLG and to gauge the public's
reactions to health effects statements. In addition, focus group participants were asked to give
CCR Rule Retrospective Review Summary 13 December 2012
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their reaction to two consumer confidence reports that had actually been issued by community
water systems." (63 FR 44513, August 19, 1998) In developing the final CCR Rule, the EPA
took into consideration the comments provided by the focus groups.
OF
During the CCR Rule Retrospective Review, the EPA received stakeholder feedback on the
understandability of the CCR. That feedback is summarized below:
• The information provided in the CCR can be confusing, misleading and alarming to
some readers.
o Commenters on this issue stated that they found the required detected contaminant
table confusing, because the table lacks an easy to understand interpretation of the
results that explains what is in the water and what the associated health effects could
be. Some suggestions from commenters to help make the detected contaminant table
more understandable include the following:
• Make the mandatory language shorter and easier to read; make the language
less negative.
• Reduce potential confusion by eliminating the requirement that all detected
contaminants be listed in the table and only list contaminants for which the
water system had health-based violations.
o Some of the commenters stated that the health effects language currently required to
be in the CCR may be disconcerting and frightening for the general public and not
convey the level of health risks accurately. These commenters would prefer
community water systems to have more flexibility in how the health effects language
is worded in the CCR.
o Some commenters suggested that when the EPA updates or writes new drinking water
regulations that would add language to the CCR, the agency should carefully assess
how new language would impact the complexity and readability of the CCR.
o Some commenters suggested that the EPA update and strengthen existing guidance
and templates for community water systems to improve the ability of customers to
understand the CCR. Suggestions included:
• Provide one clear statement on the CCR reporting if the water met the
standards.
• There should be a simple at-a-glance summary to indicate to the consumer if
the water is safe, something similar to the Air Quality Index which provides
color coded warnings of air quality conditions.
CCR Rule Retrospective Review Summary 14 December 2012
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• CCR is helpful and easy to understand.
o Some commenters noted that the CCR is not difficult to understand and strongly
objected to the idea that the report should be shortened. These commenters
expressed an interest in being provided greater details about water quality
analyses and how their drinking water meets the standards.
o Information was submitted indicating that CCRs have a beneficial impact on the
consumers' view of the community water system and the quality of the water
being provided by the community water system. In a 2011 American Water
Works Association (AWWA) consumer survey presentation, the majority of
respondents "somewhat agreed" that the CCR made them feel more confident in
their water and they found the CCR "somewhat useful" in developing a better
understanding of their water quality.
FOLLOW-UP ACTIONS
Although commenters differed in their opinions about the understandability of the CCR the
agency recognizes that measures could be taken to improve this aspect without a rule change.
The EPA will consider taking the following actions to aid in the understandability of the CCR:
• Clarify the existing language or requirements for the CCR when other NPDWRs are
updated.
• Identify and share examples of CCRs that convey information in a clear way.
• Review existing guidance manuals and templates to look for opportunities to improve the
clarity of CCRs.
CCR Rule Retrospective Review Summary 15 December 2012
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IN OM
TO 1.0
Before the CCR Rule was promulgated in 1998, the EPA met with many stakeholders and
conducted focus groups on various proposed elements of the regulation. One of the topics of the
focus groups was the public's understanding of MCLs less than 1.0 vs. numbers greater than or
equal to 1.0. EPA stated the following in the preamble to the final rule (63 FR 44518, August 19,
1998):
As recommended by NDWAC [National Drinking Water Advisory Council], EPA proposed
this requirement [reporting MCLs as numbers greater than or equal to 1.0] because it believes
that whole numbers make it easier for consumers to compare the level of a contaminant in the
system's water with the MCL. Many consumers have trouble understanding decimal points.
This was evident in the focus groups, in which people found reports containing mostly whole
numbers much easier to read than reports where the significant digits came after multiple
zeros. AWWA [American Water Works Association] found similar results in its focus
groups.
The CCR Rule requires community water systems to include in their CCRs a list of contaminants
that are detected when sampling the water, as well as the associated MCLs and maximum
contaminant level goals (MCLGs). While the MCLs included in the NPDWRs are typically
shown as numbers less than 1.0, the CCR Rule requires the CCR to list an MCL as a number
greater than or equal to 1.0, and all detected contaminants and MCLGs must be reported in the
same units as the MCL (40 CFR § 141.153(d)(4)). For example, the MCL for cadmium is 0.005
milligrams per liter (mg/L) or parts per million (ppm) and must be reported as 5 parts per billion
(ppb) in the CCR. A community water system with an average cadmium concentration of 0.0035
ppm must convert the results to ppb to report in the CCR. By multiplying the result by 1000 the
community water system now reports its cadmium monitoring as 3.5 ppb as required in the CCR.
The detected concentration result may, or may not, be greater than or equal to 1.0; however, it
does need to be reported in the same unit as the MCL.
Appendix A of 40 CFR Part 141, Subpart O, provides a list of the contaminants that must be
included in the CCR if detected by the community water system, their associated traditional
MCLs (MCL units), the associated MCL expressed as a number greater than or equal to 1.0
(CCR units) and associated conversion factors to aid community water systems converting their
analytical results to the appropriate CCR reporting units.
In 1999, the EPA issued a memorandum in response to a question about changing the
requirement of reporting MCLs in numbers greater than or equal to 1.0 (US EPA, 1999):
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At the Association of State Drinking Water Administrators (ASDWA) Winter Meeting, I
[Cynthia Dougherty, Office Director of EPA Office of Ground Water and Drinking Water]
was asked about the type of information and research that would be required before EPA
would approve a CCR Rule primacy revision application that allowed MCL reporting in
other than numbers greater than or equal to one. I responded that I would consider approval
of such an application upon a good faith State effort showing the proposed reporting format
is favored by the State's public over using numbers greater than or equal to one. I believe that
there should be a high bar for public involvement for changing the reporting format for
detected contaminants. Public involvement should include documented focus group research.
This research should target members of communities served. Representatives from water
systems and other drinking water professionals can be involved in the research, but they
should not be considered the target audience. If the process shows that consumers find an
alternative MCL format easier to understand, I would consider approving a State primacy
revision application including that format. Thus far no State has tried to make this
demonstration.
At the time this summary document was published, EPA was not aware of any primacy agency
that approached EPA to change the requirement.
OF
The following discussion highlights key concerns expressed by stakeholders on the topic of
reporting CCR units:
• Numbers greater than 1.0 may give some consumers a false impression of greater
contamination
o Some commenters noted that reporting a result as a number greater than 1.0 might
give the false impression that there is a larger quantity of a contaminant in the
drinking water. For example, 29 ppb of arsenic seems like a larger amount of arsenic
than 0.029 ppm of arsenic.
o One commenter noted that a more simple explanation should be included in the CCR
regarding the units of measure. A suggestion was to define ppm as "1 drop in 1
million gallons" and ppb as " 1 drop in 1 billion gallons" so consumers would
understand that ppb is a very small amount.
• Laboratories often report results in a different concentration unit (according to the
MCL unit) than what is required in the CCR (CCR unit).
o Laboratories report concentrations in units according to the MCL, or MCL units,
which is often less than 1.0. The community water system must convert the
CCR Rule Retrospective Review Summary 17 December 2012
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laboratory result before reporting it in the CCR. Some community water systems find
the conversion to be a burden.
• Numbers greater than 1.0 are easier for consumers to understand.
o Other commenters supported the use of units greater than 1.0 if other EPA-required
reporting became consistent with CCR units.
• There may be confusion about different units being reported in different public
outreach materials
o Commenters mentioned that MCLs are often presented in many information sources,
(e.g., public notices or fact sheets) in different concentration units than the units
required in the CCR Rule. For instance, a public notice may report MCLs and
analytical results in mg/L, or ppm, which typically means the MCL and analytical
results will be reported as numbers less than 1.0. Whereas, when reporting the same
contaminant in the CCR the MCL and analytical results are in ppb, which will result
in the values being reported as a number greater than or equal to 1.0. This could cause
confusion between the public notice and CCR, because consumers may not notice
that the units are different and read different results.
• Some community water systems inaccurately perform the unit conversions.
o Primacy agencies noted that they had observed conversion problems when a
community water system converts the analytical results from MCL units to numbers
that are greater than 1.0, especially from smaller community water systems.
FOLLOW-UP ACTIONS
At this time, the EPA does not intend to make any changes to the way MCLs or contaminant
concentrations are reported in the CCR. However, there are some actions that could be taken to
enhance the understanding of CCR units:
• As noted above, primacy agencies can conduct the research needed to change the
requirement in their own state, without a federal regulatory change. Some primacy agencies
may no longer be aware of this memo, so the EPA will work to promote awareness of the
guidance to primacy agencies.
• The EPA has included a table in 40 CFR Part 141, Subpart O, Appendix A, with the MCLs
converted to values greater than 1.0. This information is also available on the EPA website
on the CCR Rule Compliance Help webpage -
http://water.epa.gov/lawsregs/rulesregs/sdwa/ccr/compliancehelp.cfm. The agency may
CCR Rule Retrospective Review Summary 18 December 2012
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consider providing a factsheet on how to perform the numerical conversions and/or promote
awareness (e.g., encourage more community water systems, specifically small community
water systems, to use the CCR iWriter to create the CCR, and calculate the unit conversion in
order to reduce the burden on the community water system creating the CCR.)
CCR Rule Retrospective Review Summary 19 December 2012
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3 IN
The Public Notification (PN) Rule requires public water systems to notify their customers when
they violate drinking water standards and regulations (including monitoring requirements) or
otherwise provide drinking water that may pose a risk to consumer's health. 40 CFR §§141.201-
211. The PN Rule specifies three categories or tiers of public notification.
• A Tier 1 notice is required for violations or situations that have significant potential to have
serious adverse effects on human health as a result of short-term exposure. Water systems
have 24 hours to notify people who may drink the impacted water.
• A Tier 2 notice is required any time a water system provides water with levels of a
contaminant that exceed drinking water standards or that has not been treated properly, or
that has a significant potential to have serious adverse effects on human health. Water
systems must provide a Tier 2 notice as soon as possible, but within 30 days of learning of
the violation or situation.
• A Tier 3 notice is required for all other violations (e.g., failure to monitor or comply with
established testing procedure) or situations not included in Tier 1 or Tier 2. The water system
has up to 12 months from the date of the violation to provide a notice of this situation to its
customers.
The PN Rule allows community water systems to use the CCR to meet Tier 3 PN requirements
(both initial and repeat notices) as long as the CCR is provided to customers no later than 12
months after the community water system learns of the Tier 3 violation. 40 CFR § 141.204(d).
In the preamble of the final CCR Rule (63 FR 44520, August 19, 1998) the EPA discussed the
duplication of effort that may occur using the CCR to issue PN:
The [SDWA] Statute clearly requires some duplication between CCR and PN requirements
since both provisions mandate reporting of violations. Since neither the PN nor the CCR can
assure complete notification of all consumers, in many instances the information will not be
repetitive for the public. The Agency will explore in its revisions to the PN rule the feasibility
of allowing the CCR to serve as PN for some violations, thereby eliminating some
duplication. States can use their authority to promulgate alternative requirements in
accordance with Sec. 141.151(e) to modify this requirement for the purpose of their final
regulation.
In 2000, when the EPA revised the Public Notification Rule, the agency looked for opportunities
to combine Tier 3 PN and the CCR. In response to the timing of the notices not aligning to allow
for 12 months of Tier 3 PN inclusion in the CCR, the EPA wrote the following in the preamble
to the Public Notification Rule revision (65 FR 25982, May 4, 2000):
CCR Rule Retrospective Review Summary 20 December 2012
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In response to comments that EPA should change the public notice requirements to better fit
into the format and content of the CCR, EPA believes such changes would undermine the
intent of the public notice. EPA is also limited by the specific timing, delivery, and content
requirements of the public notification provisions in the SDWA, as amended. Because EPA
encourages water systems to use the CCR where possible, EPA investigated ways to extend
the deadline for Tier 3 notices to 18 months. EPA concluded such a change could not be
made in the rule because the 12-month period is clearly required by statute. This limits the
use of the CCR as the initial public notice to only those violations occurring within 12
months of the CCR publication. Practically, this means that for CCRs published on July 1 (as
required under the CCR rule), the CCR could only be used as the initial public notice for
violations that occurred after July 1 of the previous year.
The CCR Rule Retrospective Review investigated the burden reduction achieved by use of the
CCR to meet Tier 3 PN requirements. The Review considered burden reduction for both
community water systems and primacy agencies that provide oversight of the use of CCRs for
reporting Tier 3 PNs.
While reviewing primacy agency regulations, the EPA found that most primacy agencies allow
the use of the CCR to distribute Tier 3 PN. Two primacy agencies do not allow the Tier 3 PN to
be distributed through the CCR as the primacy agency regulations have a shorter time frame than
the federal regulation for issuing a Tier 3 PN.
There are three primacy agencies that do not use the same tiering nomenclature as the federal PN
Rule, and have instances described in their regulations allowing community water systems to use
the CCR to issue public notification if the CCR is distributed within 12 months of the "Tier 3
type" violation. One of these primacy agencies requires a shorter timeframe for issuing
monitoring PN so it does not permit initial notification to be distributed through the CCR;
however, repeat notices are allowed.
OF
Although community water systems expressed a general appreciation for the ability to use the
CCR as the vehicle to report Tier 3 PN, there were some implementation issues that were
identified by commenters:
• Concerns with the reporting timeline of Tier 3 PNs.
o The requirement that Tier 3 PNs are issued within 12 months of the violation was
identified by community water systems as the biggest obstacle to reporting Tier 3
PNs via the CCR. The production time needed in order to distribute the CCR by July
1 further prevents a full year of violations to be included in the CCR (e.g., a Tier 3
CCR Rule Retrospective Review Summary 21 December 2012
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notice cannot be included in the 2012 CCR delivered by July 1, 2013, if the violation
occurred in 2012 any time prior to July 2, 2012.)
o Commenters suggested extending the time allowed for reporting Tier 3 PNs in the
CCR beyond 12 months (e.g., 18 months) so that a full calendar year of violations
could be reported in the CCR.
• There is a potential for improper implementation of Tier 3 PN using CCR.
o Some primacy agencies indicated that not all community water systems appear to
understand how to incorporate a Tier 3 PN into the CCR. For example, some
community water systems do not include all of the required information for the Tier 3
PN language in the CCR. This can result in additional primacy agency burden by
requiring the community water system to reissue the CCR with the full PN language.
o One recommendation by a commenter was to encourage community water systems to
attach the Tier 3 PN, as a separate document, to the CCR. In addition, more education
regarding the requirement to include all information required for a Tier 3 PN in the
CCR may be needed.
• Primacy agencies may experience a burden to track CCR and PN implementation.
o Primacy agencies noted that there can be significant resources used to track public
notices and CCRs.
o The opinions on the usefulness of the CCR to deliver Tier 3 PN to reduce burden
were mixed. Some primacy agencies stated that the same resources and procedures
are used whether the PN is distributed separately or with the CCR. Other primacy
agencies noted that the oversight burden increases when the CCR is used to report a
Tier 3 public notice.
The PN timeframe established in the SDWA cannot be addressed by the EPA through this
retrospective review. The agency will consider the following suggestion that may help
community water systems (providing notice for violations after July 1st of the previous year)
understand how to properly incorporate a Tier 3 public notice into the CCR:
• EPA could host an annual webinar on CCR requirements for community water systems
and include discussions on proper incorporation of the Tier 3 PN language and
distribution requirements. For example, a best practice of attaching a completed Tier 3
public notice to a CCR does not require reformatting of the CCR reducing production
time. The webinar could also demonstrate how community water systems can use the PN
CCR Rule Retrospective Review Summary 22 December 2012
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iWriter and/or CCR iWriter to efficiently create their own CCRs and Tier 3 public
notices.
CCR Rule Retrospective Review Summary 23 December 2012
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OF
BY TO
The CCR Rule requires a community water system to certify to its primacy agency that the CCR
has been distributed to its customers, and that the information is correct and consistent with the
compliance monitoring data previously submitted to the primacy agency. 40 CFR § 141.155(c).
Under the CCR Rule a community water system is required to send the CCR to customers no
later than July 1 of each year and the certification must be sent to the primacy agency within
three months of CCR distribution each year. Approximately 13 primacy agencies require
community water systems to submit their certifications sooner than that required by the federal
regulation.
The CCR Rule certification requirement provides flexibility for primacy agencies and
community water systems regarding how to certify. EPA does provide example certification
forms which primacy agencies can use and adapt to their own drinking water programs in the
CCR State Implementation Guidance (EPA 816-R-09-010, April 2010). Also, there are examples
of certification forms in Preparing Your Drinking Water Consumer Confidence Report (EPA
816-R-9-011, April 2010).
OF
Feedback pertaining to the certification requirement that EPA received from community water
systems, primacy agencies and other stakeholders includes the following:
• There are existing approaches to minimize the CCR certification burden for
community water systems.
o Some primacy agencies noted that they accept a variety of certification forms and
also allow certification to be provided via email.
o Some primacy agencies and community water systems suggest that the CCR delivery
and certification deadlines should be the same date so that community water systems
are less likely to forget to send the certification to the primacy agency. Primacy
agencies may see a reduction in burden as there would be no duplication of effort
tracking both the CCR and the certification submissions separately. In addition, there
could be an implementation burden reduction by making the CCR and certification
due on the same date.
CCR Rule Retrospective Review Summary 24 December 2012
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• The importance of CCR certification.
o Some primacy agencies viewed certification as a means to ensure the CCR is
delivered while others found tracking certification an unnecessary burden.
Implementing some of the suggestions above (e.g., one deadline) would require a change in the
federal regulation. Federal regulation does not hinder a community water system from
submitting the CCR and certification to the primacy agency at the same time. The EPA is
currently documenting these suggestions and considering potential actions that may help
alleviate burden on community water systems and primacy agencies.
CCR Rule Retrospective Review Summary 25 December 2012
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OF
The CCR Rule requires all community water systems to "mail or otherwise directly deliver" a
CCR to each customer by July 1 annually. 40 CFR § 141.155(a). Each community water system
must also make a "good faith effort" to reach consumers who do not receive water bills by using
other means recommended by the primacy agency. A good faith effort to reach consumers
should include a mix of appropriate methods including posting on the Internet, mailing to postal
patrons in metropolitan areas, advertising the availability of the report in the news media, posting
in public places, etc. 40 CFR §141.155(b).
Over the past few years, a number of community water systems, technical service providers and
primacy agencies have inquired as to whether the current rule allows electronic delivery of the
CCR to each customer. During the development of the EPA's Retrospective Review Plan in
2011, stakeholders noted that there has been an increase in the number and types of
communication tools since 1998 when the CCR Rule was promulgated. They also suggested that
a community water system could reduce mailing and printing costs and perhaps improve
readership if the CCR Rule allows electronic delivery of CCRs in lieu of postal delivery.
In section 141.155(a) of the proposed CCR Rule, the language regarding direct delivery stated
"each community water system must mail one copy of the report to each customer." When the
proposed rule was released to the public, commenters suggested changing this language because
they felt it was too specific. As a result of these comments, the EPA modified the CCR delivery
language in the final CCR Rule and provided the following response in the preamble of the final
Rule (63 FR 44521, August 19, 1998):
In response to comments, some minor modifications have been made to this section. First,
commenters argued that as written, Section 141.155(a) [of the proposed CCR Rule] implied
that systems could use only the U.S. Postal Service to deliver reports to customers. EPA
agrees that other means of delivering the reports could be used as long as reports get into
customers' homes. For example, a system's water meter readers could deliver the reports.
Therefore, the regulations now state in § 141.155(a) that reports must be mailed or otherwise
directly delivered to the customer.
Another indication that other forms of delivery may be allowed under the CCR Rule is found in
the Conference Report for the 1996 SDWA amendments (a joint statement from the House and
Senate about the bill.) The Report states that it is congressional intent that the EPA may allow
the CCR requirement "to be satisfied by a means other than postal delivery, such as personal
CCR Rule Retrospective Review Summary 26 December 2012
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delivery or electronic mail, if the Administrator determines that the alternative means will
provide equivalent notice to individual customers3." This statement confirms the reading of both
the SDWA statute and CCR regulations that "mail" and "directly deliver" are not limited to post
office or hand delivery.
Therefore, during the CCR Rule Retrospective Review, EPA evaluated several electronic
delivery methods to determine which forms meet existing CCR Rule requirements.
OF
The EPA received public feedback on issues surrounding electronic delivery of CCRs through its
web-dialogue in February 2012 and public meeting in October 2012. The following points were
made by commenters:
• Production and mailing costs are expensive.
o Water systems do not include additional information beyond the mandatory language,
because of the costs of delivery and production of the reports.
o The provision requiring that CCRs be put into the newspaper is not always a burden
reduction, and in many cases the cost of putting the entire CCR in the paper costs
more than printing and mailing to customers.
• There are technological concerns regarding email-based delivery methods.
o Community water systems may find it difficult to collect and maintain up-to-date
email addresses. Those community water systems with customer email addresses
typically have an e-billing program; however, even these community water systems
typically do not have email addresses for all of their customers.
o Some commenters expressed concern over receiving their CCR through email versus
an Internet URL citing technology issues (e.g., limited bandwidth, incompatible
computer software, and email viruses.)
o Stakeholders encouraged the EPA to consider future technologies for electronic
delivery.
• Allow community water systems to have multiple electronic delivery options available.
o The exact combination of options used will vary from water system to water system,
but the commenters stated that they believed that their water system would provide
the options to their customers which would work best in their community.
3 Joint Explanatory Statement of the Committee on Conference, Safe Drinking Water Act Amendments of 1996, S. Rep. No. 104-
192(1996), at 4.
CCR Rule Retrospective Review Summary 27 December 2012
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o Commenters were interested in a variety of electronic delivery methods from separate
mailings, in customer bills and through emails.
• Electronic delivery provides multiple advantages to customers.
o There may be a cost savings from not having to mail and print the CCRs, and there
may be a reduced environmental impact as less paper and ink are used.
o Electronic delivery allows water systems to improve their communications with their
customers. The CCR is available online for a customer at all times to read when it is
convenient for them. The CCR can be posted on a water system's website where
customers can also find other valuable information.
o Those who receive their bills electronically also would prefer to receive their CCR
electronically.
The EPA requested feedback on the draft document entitled Consumer Confidence Report
Electronic Delivery Options and Considerations. The agency outlined two possible
implementation approaches for electronic delivery:
1. Paper CCR delivery with an option to request an electronic CCR, or
2. Electronic CCR delivery with an option to request a paper CCR.
EPA also outlined five possible electronic delivery methods:
1. CCR embedded in an email message;
2. CCR sent as an attachment to an email;
3. URL linked directly to the CCR sent via email;
4. URL linked directly to the CCR mailed to customers (e.g., via water bill itself, water bill
enclosure, separate mailing, etc.); and
5. Additional electronic delivery methods that meet the definition of direct delivery.
EPA received approximately 830 comments from the public on the draft document or the topic
of electronic delivery of the CCR. The following is a brief summary of the comments received:
• Community water systems may provide more information to consumers about water quality,
research and additional information not required by the CCR Rule since they are not
restricted by paper size or a printing budget.
• Many commenters indicated that there would be a large cost savings for a community water
system not providing paper CCRs.
• Commenters stated that electronic delivery would save natural and monetary resources.
Others believed that managing an email address database may offset some of the cost savings
from reduced printing and mailing.
CCR Rule Retrospective Review Summary 28 December 2012
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• CCRs may be distributed faster and be easier to update. Some community water systems
indicated they would provide up-to-date water quality data on their websites if they did not
have to print and mail a paper CCR to customers, unless requested.
• Many community water systems favored printing the direct URL on the water bill statement
as their preferred electronic delivery method.
• Commenters appreciated that the EPA allowed for a variety of the methods and approaches
so that the best method(s) could be found for both the community water system and
customers.
• Some commenters stated that electronic delivery offers a new opportunity to engage
customers who may currently ignore the paper version of the CCR but prefer reading
information electronically.
• Commenters recommended that the EPA specify the location and size of a direct URL on a
bill to avoid small print that may go unnoticed by consumers. It was suggested that the EPA
ensure that the direct URL be simple, short and prominent on all CCR notifications.
• Some stakeholders expressed concern that low-income neighborhood residents may not have
Internet access in their home and may be more at risk of having lower quality water. In
addition, these individuals may not receive their CCRs if they are only delivered
electronically.
• Some commenters stated that EPA's draft CCR Electronic Delivery Options and
Considerations document did not provide strong enough standards, because it is guidance.
• Others indicated that customers may not want the CCR cluttering their email inbox and
would prefer a paper version of the CCR.
ON
DELIVERY
The EPA issued an interpretive memorandum at the conclusion of the retrospective review
clarifying the requirements of the CCR Rule associated with the delivery of the CCR. The
memorandum's attachment, Consumer Confidence Report Electronic Delivery Options and
Considerations, provides an overview of electronic delivery methods and describes approaches
for community water systems that want to implement electronic delivery. It is important to note
that the attachment document provides a framework of information, recommendations and
interpretations of existing CCR Rule provisions. It is not a rulemaking action and does not add to
or replace any existing CCR Rule requirements. It also does not supersede any additional
primacy agency requirements for content or delivery of CCRs. The interpretive memorandum
and attachment can be found on the EPA website at
^
CCR Rule Retrospective Review Summary 29 December 2012
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The EPA notes that delivery of a paper CCR may still be the most appropriate option for some
community water systems and their customers. Community water systems should consider a
combination of delivery methods based on available technology and the preferences of their
customer base. The EPA recommends that community water systems provide options for their
customers that are cost-effective and practicable for the community water system as well as
convenient for their customers. In addition, the EPA recommends that primacy agencies reach
out to their community water systems and provide assistance to ensure that methods of electronic
delivery being considered by community water systems meet CCR Rule requirements.
The EPA evaluated existing studies and comments received to understand potential cost savings
associated with electronic delivery of CCRs, including an estimate of the point at which a
community water system may break even or realize a savings benefit from delivering a
percentage of CCRs electronically. This analysis applies to three generic community water
systems with variable preexisting technological capabilities and three different system size
categories. Appendix A to this document summarizes assumptions and provides detailed cost
calculations used to estimate costs associated with electronic delivery.
CCR Rule Retrospective Review Summary 30 December 2012
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Based on the EPA's analyses and the input provided by stakeholders throughout the CCR Rule
Retrospective Review, the agency does not intend to revise the CCR Rule at this time. The
interpretive memorandum and attachment establish the framework for community water systems
to utilize electronic delivery of CCRs. The EPA sees this as an opportunity for long-term burden
reduction for community water systems and primacy agencies while maintaining the integrity of
the CCR and promoting greater transparency of drinking water information to all consumers
receiving water from community water systems.
In 2013, the EPA plans to host a webinar on electronic delivery of CCRs as outlined in its
interpretive memorandum. In addition, the EPA will work with primacy agencies to assist
community water systems that transition to CCR electronic delivery.
Other activities that the EPA may undertake include the following:
• Provide additional training and resources as issues are identified when community water
systems begin electronic delivery of CCRs according to the EPA framework.
• Host an annual webinar on the CCR for community water systems that would include the use
of the CCR iWriter so that community water systems can more efficiently create their own
CCRs. Some topics that may be addressed include proper incorporation of the Tier 3 PN
language and distribution requirements, unit conversions for the CCR and how to make the
CCR more understandable for consumers.
• Provide additional or update current factsheets on how to perform the numerical conversions.
The EPA could also promote awareness of the table in Appendix A of 40 CFR Part 141,
Subpart O, which provides the MCLs in CCR units and provides conversion factors so the
community water system knows how to convert each analytical result to the correct unit. The
guidance could encourage more community water systems, specifically small community
water systems, to use the CCR iWriter which is designed to calculate the unit conversion in
order to reduce the burden on the community water systems creating the CCR.
CCR Rule Retrospective Review Summary 31 December 2012
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Dougherty, C., 1999, Consumer Confidence Report (CCR) Rule — Units for Reporting Detected
Contaminants, memorandum. Water Supply Guidance No. 128. Available on-line at:
http://water.epa.gov/aboutow/ogwdw/wsg_subject.cfm.
Grevatt, P., 2012, Safe Drinking Water Act - Consumer Confidence Report Rule Delivery
Options, memorandum. Available on-line at:
http://water.epa.gov/lawsregs/rulesregs/sdwa/ccr/regulations.cfm.
Joint Explanatory Statement of the Committee on Conference, Safe Drinking Water Act
Amendments of 1996, S. Rep. No. 104-192 (1996), at 4.
Rezania, L., 2012. Minnesota Department of Health, Consumer Confidence Report Pilot Study.
Unpublished presentation delivered to EPA 07/11/12.
Roberson, A., 2011. The Results from AWWA's Surveys and Pilot Tests on Electronic Delivery
of Consumer Confidence Reports (CCRs). Unpublished presentation delivered to EPA
workgroup 10/18/11.
Safe Drinking Water Act of 1974, 42 U.S.C. §300g-3 (1996).
US EPA, 1998a. National Primary Drinking Water Regulations: Consumer Confidence;
Proposed Rule 63 Federal Register 7606-7633, February 13, 1998.
US EPA, 1998b. National Primary Drinking Water Regulation: Consumer Confidence Reports;
Final Rule. 63 Federal Register 44512-44536, August 19, 1998.
US EPA, 1998c. Announcement of Public Meeting on the Consumer Confidence Report (CCR)
Rule Retrospective Review and Request for Public Comment on Potential Approaches to
Electronic Delivery of the CCR. 77 Federal Register 55833, September 11, 2012.
US EPA, 2000. National Primary Drinking Water Regulation: Public Notification Rule; Final
Rule. 65 Federal Register 25982-26049. May 4, 2000.
US EPA, 2010a. CCR State Implementation Guidance. Office of Water, U.S. Environmental
Protection Agency, Washington, DC 20460. EPA 816-R-09-010.
US EPA, 201 Ob. Preparing Your Drinking Water Consumer Confidence Report. Office of Water,
U.S. Environmental Protection Agency, Washington, DC 20460. EPA 816-R-9-011.
CCR Rule Retrospective Review Summary 32 December 2012
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US EPA, 2011. Improving Our Regulations: Final Plan for Periodic Retrospective Reviews of
Existing Regulations. Regulatory Policy Office, U.S. Environmental Protection Agency,
Washington, DC, 20460. Accessed on-line 12/12/12 at www.regulatk>nsigp_v Docket ID:
EPA-HQ-OA-2011-0156.
CCR Rule Retrospective Review Summary 33 December 2012
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A:
CCR Rule Retrospective Review Summary A-i December 2012
Appendix A
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Table of Contents
Introduction 1
Data Sources 2
The2011PWSSICR 2
The 2011 AWWA Customer Survey 2
The 2012 MDHCCR Pilot Project Survey 3
AWWA Survey andMDH Survey Comparisons 4
CCR Delivery Approaches 5
Approach 1 5
Approach 2 6
Factors and Assumptions Influencing Electronic Delivery Transition Costs 6
Population Size 7
Total O&M Costs 7
Website Costs 8
Mass Email Delivery Costs 8
Email Address Collection Costs 9
Electronic Delivery Method Choices 10
Cost Savings Analysis - National Summary 10
Analysis for Approach 1 11
Analysis for Approach 2 11
Analysis Summary 11
Cost Savings Analyses - CWS Scenarios 12
CWS Scenario Analyses for Approach 1 13
CWS Scenario Analyses for Approach 2 14
Cost Savings Difference Summary 16
Conclusions 17
CCR Rule Retrospective Review Summary A-i December 2012
Appendix A
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List of Tables
Table 1: AWWA 2011 Customer Survey Results - Delivery Method Preferences
Table 2: MDH 2012 Customer Survey Results - Delivery Method Preferences
Table 3: Paper CCR Delivery with a Customer Option for Electronic Delivery - AWWA and
MDH Surveys
Table 4: Electronic CCR Delivery with a Customer Option to Request a Paper CCR - AWWA
and MDH Surveys
List of Supporting Attachments
Attachment 1: National First Year Cost Difference Summary
Attachment 2: National First Year Cost Difference Analyses
Attachment 3: CWS Scenario Breakeven Points Summary
Attachment 4: CWS Scenario First Year Cost Difference Summary
Attachment 5: CWS Scenario Breakeven Points and First Year Cost Difference Analyses for
Approach 1
Attachment 6: CWS Scenario Breakeven Points and First Year Cost Difference Analyses for
Approach 2
CCR Rule Retrospective Review Summary A-ii December 2012
Appendix A
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INTRODUCTION
In an effort to determine the costs for a community water system (CWS) to transition to CCR electronic
delivery, the EPA conducted a cost savings analysis to estimate the expected costs and breakeven points
for CWSs choosing one of the CCR electronic delivery methods for bill paying customers.
This analysis focused on:
1. Gathering available information regarding customers' preferred CCR delivery method;
2. Determining the expected percentage of customers who would participate in CCR electronic
delivery;
3. Determining factors which could influence a CWS's initial investment to transition to electronic
delivery;
4. Estimating the first year's costs for a CWS to commence electronic delivery of the CCR; and
5. Estimating the subsequent years' costs and a breakeven point when a CWS recoups the initial
investment costs for CCR electronic delivery.
The methods for electronic delivery examined in this cost savings analysis are:
• Mail - notification on a utility bill or separate mailing that the CCR is available - CWS mails
each bill-paying customer a notification that the CCR is available and provides a direct website
address (URL) to the CCR where it can be viewed. The URL must not navigate to a webpage
that requires a customer to search for the CCR. The direct URL webpage must display all
minimum information on one scrolling webpage or connect to the viewable electronic file (e.g.,
PDF document.) The mail method for the notification may be, but is not limited to, a water bill
insert, statement on the water bill or community newsletter.
• Email direct URL to CCR - CWS emails a direct URL to the CCR on a publicly accessible
website. The direct URL webpage must display all minimum information on one scrolling
webpage or connect to the viewable PDF document. The URL must not navigate to a webpage
that requires a customer to search for the CCR.
• CCR sent as an attachment to an email - CWS emails the CCR as an electronic file email
attachment (e.g., PDF.)
• CCR sent as an embedded image in an email - CWS emails the CCR text and tables inserted into
the body of an email (not as an attachment.)
Appendix A describes the results of the cost savings analysis to estimate the expected costs and
breakeven points for CWSs transitioning to electronic delivery.
CCR Rule Retrospective Review Summary A-l December 2012
Appendix A
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DATA SOURCES
For the number of CWSs, population served, service connections and CCR preparation costs, the EPA
used the December 2011 Final Public Water System Supervision Program Information Collection
Request (PWSS ICR).
Data sources for customers' preference for CCR delivery included two recent studies, one commissioned
by the American Water Works Association (AWWA) and a CCR Pilot Project coordinated by the
Minnesota Department of Health (MDH). These documents may be found in Docket ID No. EPA-HQ-
OW-2012-0035 (www.regulations.gov).
THE 2011 PUBLIC WATER SYSTEM SUPERVISION INFORMATION
COLLECTION REQUEST
The 2011 PWSS ICR examines public water supply, primacy agency, laboratory and EPA burden and
costs for recordkeeping and reporting requirements for the PWSS Program, which includes the CCR
Rule. Information from Appendix B of the document was used to calculate the expected costs and return
on investment timeframe (breakeven points) for CWSs that choose to transition to CCR electronic
delivery for a portion of their customers.
THE 2011 AWWA CUSTOMER SURVEY
AWWA commissioned an electronic survey, conducted by Knowledge Networks, to canvas 2,348 CWS
customers regarding their preferred CCR delivery method. Customer responses to the surveys were then
aggregated to determine the respondents' preference for either electronic or paper delivery. An
electronic delivery preference indicates that a customer prefers to access the CCR in an electronic
format, and a paper delivery preference indicates that a customer prefers to access the CCR in paper
format.
The following delivery methods were aggregated into the electronic category:
• Online at water utility website
• A postcard or other mailing (this method was assumed to be similar to a separate mailing with a
URL notification)
The following delivery methods were aggregated into the paper category:
• Mailed to my residence
• CCR in maj or newspaper
CCR Rule Retrospective Review Summary A-2 December 2012
Appendix A
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There was also a portion of customers who did not want to receive their CCR in either an electronic or
paper format. These customers were categorized as "no preference." This analysis assumes that these
customers take no action and accept the CCR being delivered in either format.
The following delivery methods were placed in the "no preference" category:
• Newspaper notice reporting whether my water met all of the regulations
• Posted notice at water utility's office
• Don't want or don't need
The delivery methods presented to customers and the results of the survey are shown in Table 1:
Table 1: AWWA 2011 Customer Survey Results - Delivery Method Preferences
Delivery Method
Online at water utility website
A postcard or other mailing
Mailed to my residence
CCR in major newspaper
Newspaper notice reporting
whether my water met all of the
regulations
Posted notice at water utility's
office
Don't want or don't need
Percent of
Respondents
Choosing Method*
13.9
12.5
49.2
3.6
3.5
1.1
15.5
Electronic or
Paper Preference
Electronic
Electronic
Paper
Paper
No Preference
No Preference
No Preference
Total
Percentage for
each
Preference
26.4
52.8
20.1
*AWWA Customer Survey Presentation results did not result in a 100% but totaled to 99.3%.
THE 2012 MDH CCR PILOT PROJECT SURVEY
The MDH administered a post-CCR delivery customer survey in 2012 as part of a CCR Electronic
Delivery Pilot Project. Almost 6,000 surveys were delivered to a number of randomly selected
customers with an 11.9 percent return rate. Customer responses to the surveys were then aggregated to
determine the respondents' preference for either electronic or paper delivery. An electronic delivery
preference indicates that a customer prefers the CCR is delivered in an electronic format, and a paper
delivery preference indicates that a customer prefers the CCR is delivered in paper format.
The following delivery methods were aggregated into the electronic category:
• URL notice via postcard or bill insert/stuffer
CCR Rule Retrospective Review Summary
Appendix A
A-3
December 2012
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• Email/E-Bill notification (Note: These customers also received a paper CCR during the pilot
project.)
The following delivery methods were aggregated into the paper category:
• Paper CCR
• CCR in community newsletter/local paper
There was also a portion of customers who did not want to receive their CCR in either an electronic or
paper format. These customers were categorized as "no preference." This analysis assumes that these
customers would take no action and accept the CCR being delivered in either format.
The following delivery methods were placed in the no preference category:
• Other
The delivery options presented to customers in this survey and the results of the survey are shown in
Table 2:
Table 2: MDH 2012 Customer Survey Results - Delivery Method Preferences
Delivery Method
URL notice via postcard or bill
insert/stuff er
Email/E-Bill notification
Paper CCR
CCR in community
newsletter/local paper
Other
Percent of
Respondents
Choosing Method
11.0
35.1
42.3
9.3
2.3
Electronic or
Paper Preference
Electronic
Electronic
Paper
Paper
No Preference
Total
Percentage for
each
Preference
46.1
51.6
2.3
AWWA SURVEY AND MDH SURVEY COMPARISONS
Since the two surveys did not present the same delivery options to CWS customers, the results of the
surveys were used in the cost savings analysis to bracket a range of potential costs for CWSs.
CCR Rule Retrospective Review Summary
Appendix A
A-4
December 2012
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CCR DELIVERY APPROACHES
Once a CWS identifies appropriate CCR electronic delivery methods, it next needs to consider an
approach for electronic delivery. With stakeholder input, the EPA analyzed different delivery
approaches and identified two that meet the CCR Rule requirements to "mail or otherwise directly
deliver." The two approaches were:
• Paper CCR Delivery with a Customer Option to Request an Electronic CCR (Approach 1)
• Electronic CCR Delivery with a Customer Option to Request a Paper CCR (Approach 2)
Each approach should be considered by the CWS to determine how best to directly deliver the CCR to
its bill-paying customers. CWSs may also find it best to use a phased approach over time when
transitioning from paper delivery to electronic delivery. This document presents a general summary of
CCR electronic delivery approaches. Please see the Safe Drinking Water Act - CCR Electronic Delivery
Options memo and CCR Delivery Options and Considerations attachment for more information
regarding electronic delivery methods and approaches.
APPROACH 1
One approach to an electronic delivery program is to provide paper CCR delivery, but also allow
customers to choose to receive an electronic version of their CCR instead. Under this approach, a CWS
would notify its customers of the availability of electronic delivery of the CCR. This notification could
be accomplished through a variety of methods including, but not limited to, the water bill, a separate
mailing, a CWS's website or other means. Customers who do not identify a preference for electronic
delivery would continue to receive a paper CCR.
Based on the AWWA and MDH survey results, the EPA anticipates that a portion of the customer base
would specifically choose a paper or electronic version, but others would have no preference. The
percentages from each survey are shown in Table 3:
Table 3: Paper CCR Delivery with a Customer Option to Request an Electronic CCR - AWWA
and MDH Survey Preferences
Delivery Option
Paper
Electronic
AWWA Percentages
72.9%
26.4%
MDH Percentages
53.9%
46.1%
The larger difference in percentages between the MDH and AWWA surveys is due to the percentage of
those in each survey who fall under the no preference option. The no preference option for the AWWA
survey is 20.1 percent, while for the MDH survey is 2.3 percent. It was assumed that these customers
would not take the extra step to request a CCR in a different format. Therefore, these percentages were
CCR Rule Retrospective Review Summary A-5 December 2012
Appendix A
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included in the paper preference category, so under this delivery approach, those with no preference
continue to receive a paper CCR. As a result, fewer customers are receiving CCRs electronically in
Approach 1 based on the AWWA data than on the MDH data.
APPROACH 2
A second approach for a CCR electronic delivery program is to provide CCRs electronically to
customers while still offering an option to request a paper CCR. Under this approach, the CWS
establishes electronic delivery methods which consider its customers' needs and technology capabilities.
The CWS would deliver the CCR electronically to customers (or notify them of the availability of the
electronic CCR) and include in the electronic message (or separate mailing) an option to request paper
CCR delivery. The CWS would only provide a paper copy of the CCR to those customers who
specifically request a paper CCR.
Again, based on the AWWA and MDH surveys, the EPA anticipates that a portion of the customer base
would likely specifically choose a paper or electronic version. However, some will have no preference.
The likely preference percentages from each survey are shown in Table 4:
Table 4: Electronic CCR Delivery with a Customer Option to Request a Paper CCR - AWWA
and MDH Survey Preferences
Delivery Option
Paper
Electronic
AWWA Percentages
52.8%
46.5%
MDH Percentages
51.6%
48.4%
The difference is due to the percentage of those in each survey who fall under the no preference option.
The no preference option for the AWWA survey is 20.1 percent, while for the MDH survey it is 2.3
percent. It was assumed that these customers would not take the extra step to request a CCR in a
different format. Therefore, these percentages were included in the electronic preference category, so
under this delivery approach, those with no preference would receive an electronic CCR. As a result, the
preference percentages in Approach 2 appear to be more evenly split than in Approach 1.
FACTORS AND ASSUMPTIONS INFLUENCING
ELECTRONIC DELIVERY TRANSITION COSTS
The cost to transition to electronic delivery and the potential savings will vary from CWS to CWS
depending on the population served and other unique characteristics. An analysis was undertaken to
determine what factors could potentially impact the overall cost and potential savings available to CWSs
that choose to use electronic delivery. Those factors included population size, total operation &
maintenance (O&M) costs, website costs, mass email delivery, email collection and electronic delivery
CCR Rule Retrospective Review Summary A-6 December 2012
Appendix A
-------
method. The analysis also required several assumptions to be made regarding participation and
implementation of electronic delivery. This section discusses the factors and assumptions influencing
electronic delivery transition costs used in this analysis.
POPULATION SIZE
The cost savings analysis estimates the cost impacts to CWSs that serve more than 10,000 persons, as
the CCR Rule requires that each CWS which serves 10,000 or more persons produce and "mail or
otherwise directly deliver" a copy of its CCR to customers by July 1st each year. 40 CFR § 141.155(g).
CWSs serving fewer than 10,000 persons may deliver their CCR by other means with a Governor's
approval in the form of a small system waiver or state regulation. For this reason, systems serving fewer
than 10,001 persons are not included in the analysis.
The December 2011 PWSS ICR lists several data points that were used for this cost savings analysis.
The 2011 PWSS ICR - Appendix B, Exhibit 1 identifies three size categories for CWSs serving more
than 10,000 customers:
• 10,001 to 50,000
• 50,001 to 99,999
• 100,000 and over
These size categories were used in this cost analysis.
TOTAL O&M COSTS
CWSs in each size category will likely have different O&M costs dependent on the number of paper
CCRs that they are distributing. The varying costs are described in the PWSS ICR - Appendix B,
Exhibit 3: Report Delivery Costs (O&M Costs). The Standard O&M Costs Per Report (includes cost of
paper, photocopying or printing, folding and affixing labels) and Postage Per Report (based on bulk
rates for delivery to customers) create the Total O&M Cost Per Report. Total O&M Cost Per Report was
used to calculate the expected change in costs for all CWSs in each size category, as well as the impact
on an average size CWS in each size category.
The electronic delivery method "Mail notification in separate mailing" could use a variety of separate
mailings (e.g., postcard, bill insert, community newsletter, etc.) For this analysis, "mail notification in
separate mailing" is assumed to be a postcard and cost estimates are based on $0.28 per card based on
the bulk rate provided by the US Postal Service in 2012.
CCR Rule Retrospective Review Summary A-7 December 2012
Appendix A
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WEBSITE COSTS
CWSs have multiple options for delivering CCRs electronically. According to data collected in the 2012
AWWA CCR Electronic Delivery Cost Savings Survey, 88 percent of the 227 CWSs that responded to
the survey have and currently post their CCR on a website. For the 12 percent of CWSs that do not have
a website, an investment would need to be made to develop a website. This assumption was used in the
National Summary analysis (Attachment 2). Although maintaining a website is not necessary for some
forms of electronic delivery, this analysis assumes that all CWSs will maintain a website for the CCR to
be posted electronically and viewed year round. Research indicated an initial website development cost
of approximately $2,000 with an annual hosting fee of $240 ($20/month) for CWSs in the size
categories of 10,001 to 50,000 and 50,001 to 99,999. It was assumed that all CWSs serving a population
greater than 100,000 persons already have and maintain a website to meet the CCR Rule requirement for
larger CWSs to post their CCRs on a publicly-accessible Internet website.
Sources4:
• DesignQuote.net (website development cost estimator;
hffill//w^^
• dotLaunch (website development cost estimator;
!lfiBJ//!Q5^^
• Review of Intuit website (website hosting service; littBJ//w^
software/)
MASS EMAIL DELIVERY COSTS
For the cost savings analysis, the EPA also estimated the range of costs that CWSs in each size category
might incur if they did not already have the means to deliver a large quantity of emails to their bill-
paying customers. These costs were divided into third-party vendor and in-house options.
The least expensive mass email delivery option for a CWS is to subscribe to a third party marketing
email vendor. The vendor, once given a database of customer email addresses, could mail a message to
each customer stating that their CCR was ready to view at the CWS's website (or the CCR could be
attached to the email or embedded in the text of the email.) Third party mass email delivery costs vary
from $50 - $250 based on the population sizes identified for this analysis and the resulting numbers of
emails that must be sent based on the percentage of customers requesting electronic delivery. In the
accompanying tables this option is referred to as third-party mass emailing.
These are examples of companies that provide website hosting and development services. There may be other companies that can provide
similar services. EPA does not endorse any of these companies.
CCR Rule Retrospective Review Summary A-8 December 2012
Appendix A
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Sources5:
Constant Contact (proprietary email marketing service;
• Mail Chimp (proprietary email marketing service;
• One Call Now (proprietary email marketing service; ]rtt£^/wwwJLonecallnp^1corn/)
• GetResponse (proprietary email marketing service; Irttg^/ww^getresgon^corn/)
The more expensive option for a CWS would be to purchase an electronic billing system and software
package to be able to send mass emails, like the CCR, through the CWS's network. The purchase price
for an electronic billing system and software package varies greatly, and $100,000 was used for this
analysis. In addition, electronic billing systems require annual maintenance which can be up to 1/5 of the
purchase price, so a recurring maintenance fee of $20,000 was used for this analysis. In the
accompanying tables this option is referred to as in-house mass emailing.
Sources6:
• Aria Services (subscription billing;
httjj^/mfaanasystenis^
• Donald R. Frey & Company (proprietary billing software;
• TAK Technology Inc. (proprietary billing software;
These two options provide a range of costs that a CWS may expect to incur to email customers a CCR.
These costs do not account for email collection.
EMAIL ADDRESS COLLECTION COSTS
The EPA's analysis also identified email address collection options for a CWS, especially for those that
do not have a customer email database. Two approaches were investigated for collecting emails, passive
and active.
"Passive" email collection involves sending out a notice with a bill that a CWS wants to collect
customers' email addresses. Requests for email addresses from a smaller CWS (10,001 to 50,000
customers) are assumed to cost $0.03/bill staffer7. A returned email address would be entered into a
These are examples of companies that provide proprietary email marketing services. There may be other companies that can provide
similar services. EPA does not endorse any of these companies.
These are examples of companies that provide proprietary billing software. There may be other companies that can provide similar
software. EPA does not endorse any of these companies.
The PWSS ICR - Appendix B, Exhibit 3 defines Standard O&M costs for preparing a mailing per CWS depending on their size.
CCR Rule Retrospective Review Summary A-9 December 2012
Appendix A
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database, with each database entry costing approximately $0.54/entry8. For medium/large CWSs (50,001
customers and over), requests for email addresses are assumed to cost $0.007/bill stuffer9. A returned
email address would be entered into a database, with each database entry costing approximately
$0.54/entry8.
"Active" email collection involves calling each customer to obtain their email address. The EPA
assumes that up to 30 phone calls an hour could be completed at approximately $1.08/per call10. Entry of
each email address in a database is expected to cost approximately $0.54/entry8. This analysis assumes
that both the "passive" and "active" email collection methods are equally successful in terms of
collecting email addresses.
ELECTRONIC DELIVERY METHOD CHOICES
CWSs have multiple options for delivering CCRs by electronic delivery but the EPA has no basis for
estimating how many CWSs will choose each method or combination. In order to perform this analysis
the EPA had to make several simplifying assumptions. It was assumed that each CWS would choose to
use only one method of CCR electronic delivery rather than using multiple electronic methods, along
with paper delivery. For the analysis, the EPA also assumed that the percentage of customers choosing
electronic and paper delivery would stay the same in subsequent years.
COST SAVINGS ANALYSIS - NATIONAL SUMMARY
Electronic delivery startup costs were calculated as a lump sum for all CWSs in each size category. The
first year cost analyses were conducted for Approach 1 and Approach 2 using both of the AWWA and
MDH customer delivery preference percentages to provide a range of results. The National First Year
Cost Difference Summary using both AWWA and MDH data is provided in Attachment 1.
The analysis identified a range of costs for the first year, which included the total costs for CWSs to
make the transition to electronic delivery of a portion of their CCRs. These costs were compared to the
2011 PWSS ICR costs of mailing a paper CCR to all bill-paying customers. A cost figure that is positive
would identify the amount of money a CWS may save in the first year using electronic delivery
This cost is based on entering 60 addresses per hour at $32.38/hr loaded labor cost as defined in the PWSS ICR - Appendix B, Exhibit 5,
Column D.
9 According to the Standard O&M Cost Per Report as defined in the PWSS ICR - Appendix B, Exhibit 3.
10 This is based on the $32.38/hr loaded labor cost as defined in the PWSS ICR - Appendix B, Exhibit 5.
CCR Rule Retrospective Review Summary A-10 December 2012
Appendix A
-------
compared to mailing paper CCRs. A cost figure that is negative identifies an increased cost for CCR
electronic delivery in the first year.
The savings are heavily dependent on the percentage of customers that switch to electronic delivery. It is
anticipated that the higher percentage of customers who switch to electronic delivery, the higher the
savings may be. Based on the AWWA and MDH preference survey results, Attachment 1 provides a
range of expected first year savings or costs nationally. The range brackets the lowest and highest
calculated cost differences based on email mass mailing delivery and email address collection options.
ANALYSIS FOR APPROACH 1
Cost differences for paper CCR delivery with a customer option for electronic delivery were calculated
using the AWWA and MDH delivery preference percentages. In general, CWSs across all population
size categories will achieve a first year cost savings if they choose to mail a notification in a separate
mailing or a bill statement that the CCR is available to view via direct URL at their website. However,
CWSs across all population size categories are likely to incur an increased cost the first year if they only
use an email-based delivery method. The increased costs are due to investing in mass email delivery and
email address collection, which are higher than, for example, simply preparing and sending a separate
mailing to a physical addresses already on file. The national first year cost difference analysis using
AWWA and MDH data for Approach 1 is provided in Attachments 2-1 and 2-2, respectively.
ANALYSIS FOR APPROACH 2
Cost differences for electronic CCR delivery with a customer option to request a paper CCR were
calculated using the AWWA and MDH delivery preference percentages. In general, CWSs across all
population size categories will achieve a first year cost savings if they choose to mail a notification on a
separate mailing or on a utility bill that the CCR is available to view via direct URL at their website.
However, CWSs across all population size categories are likely to incur an increased cost the first year if
they only use an email-based delivery method. The increased costs are due to investing in mass email
delivery and email address collection. The costs are increased whether choosing the third party emailing
option and passive email collection, or an in-house emailing option with active email collection. The
national first year cost difference analysis for Approach 2 using AWWA and MDH data is provided in
Attachments 2-3 and 2-4, respectively.
ANALYSIS SUMMARY
In general, CWSs across all population size categories will achieve the highest first year cost savings if
they choose to mail a notification on a bill that the CCR is available to view at a website. CWSs across
all population size categories are likely to incur the highest increase in first year costs if they only use an
email-based method.
CCR Rule Retrospective Review Summary A-11 December 2012
Appendix A
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COST SAVINGS ANALYSES - CWS SCENARIOS
To determine the likely costs for the average size CWS in each size category, a series of example CWS
scenarios were developed. The scenarios chosen were as follows:
• Scenario A - CWS currently has a website where it can post its CCR, uses passive email
collection and invests in third-party email delivery. Analyses of the "Scenario A" CWS in all
three size categories were conducted.
• Scenario B - CWS has no website (except CWS serving 100,000 and over persons), uses active
email collection and invests in an in-house electronic billing system. Analyses of the "Scenario
B" CWS in all three size categories were conducted. This scenario is the most costly to
implement as it requires a $100,000 investment in an electronic billing system and individual
phone calls to every customer to collect email addresses solely for the purpose of CCR delivery.
• Scenario C - CWS already has a website, an electronic billing system and software package, and
has already begun collecting customer email addresses. "Scenario C" analysis was conducted for
an average size CWS in the 100,000 and over size category only. This scenario is the least costly
as many upfront investments necessary for electronic delivery are already complete.
• Scenario D - CWS has no website (except CWS serving 100,000 and over persons), uses active
email collection and third-party email delivery. Analyses of the "Scenario D" CWS in all three
size categories were conducted.
The analyses completed for the CWS size categories in each scenario include the following results:
• Breakeven Point: defined as the number of years it takes to recoup the initial investment in CCR
electronic delivery. The Breakeven Point Summaries for Approach 1 and Approach 2 using both
AWWA and MDH data are provided in Attachment 3. A range is provided to show the
breakeven point that a CWS should expect depending on the electronic delivery method chosen
and the percentage of its customers participating in electronic delivery.
• First Year Cost Difference: defined as the difference in the first year total costs of CWSs to
transition to the electronic delivery of a portion of their CCRs. A cost figure that is positive
identifies a cost savings in the first year the program is implemented. A cost figure that is
negative identifies an increased cost for that delivery method (as compared to only paper CCR
delivery) in the first year. A CWS's first year cost savings difference will be dependent on the
amount of investment the CWS is required to make to implement an electronic delivery method.
The Cost Difference Summaries for Approach 1 and Approach 2 using both AWWA and MDH
data are provided in Attachment 4. A range is provided to show the first year cost difference that
a CWS should expect depending on the electronic delivery method chosen and the percentage of
its customers switch to electronic delivery.
CCR Rule Retrospective Review Summary A-12 December 2012
Appendix A
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The savings are heavily dependent on the percentage of customers participating in electronic delivery. It
is anticipated that the higher percentage of customer electronic delivery participation, the greater the
savings will be. A range of expected first year savings or costs was found by contrasting the customer
delivery preferences based on the AWWA and MDH survey presentations.
CWS SCENARIO ANALYSES FOR APPROACH 1
Cost differences for paper CCR delivery with a customer option for electronic delivery were calculated
using the AWWA and MDH delivery preference percentages across the four CWS scenarios and are
presented in Attachment 5. The tables summarizing the breakeven points can be found in Attachment 3.
• Scenario A: The average size CWS across all population size categories will achieve a first year
cost savings if it chooses to mail a notification on a utility bill or a separate mailing that the CCR
is available to view via a direct URL on a website. However, the average size CWS across all
population size categories is likely to incur an increased cost the first year if it emails a
notification that the CCR is ready to view via a direct URL, email the CCR as a PDF attachment
or emails the CCR as an embedded image. The increased costs are due to investing in third-party
mass email delivery and passive email collection. In general, the average size CWS across all
population size categories could expect to breakeven in one to three years of delivering its CCR
by an electronic delivery method. For specific analyses using AWWA and MDH percentages see
Attachments 5-1 and 5-2, respectively. A summary of the breakeven points for Scenario A can
be found in Attachment 3-1.
• Scenario B: The average size CWS in the 10,001 - 50,000 population size category will not
achieve a first year cost savings due to the cost of investing in a website, purchasing an in-house
mass email delivery system and active email collection. This CWS will have a breakeven point
of three to five years if it chooses to mail a notification on a utility bill that the CCR is ready to
view via direct URL on a website. The average size CWS in the 50,001 - 99,999 population size
category will only achieve a first year cost savings if it mails a notification statement on a utility
bill that the CCR is ready to view via direct URL on a website. This CWS will likely have a
breakeven point of two to five years if it chooses to mail a notification on a utility bill or a
separate mailing that the CCR is ready to view via a direct URL. The average size CWS in the
100,000 and over population size category will likely only achieve a first year cost savings if it
mails a notification statement on a utility bill or a separate mailing that the CCR is ready to view
via direct URL on a website. This CWS will likely have a breakeven point of one year. For all
three population size categories, it may not be possible to recoup the cost of investing in a
website, purchasing an in-house mass email delivery system and active email collection for the
sole purpose of CCR delivery. For specific analyses using AWWA and MDH percentages see
Attachments 5-3 and 5-4, respectively. A summary of the breakeven points for Scenario B can be
found in Attachment 3-2.
CCR Rule Retrospective Review Summary A-13 December 2012
Appendix A
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• Scenario C: This scenario was only modeled on the average size CWS serving 100,000 and over
customers. The average CWS will likely achieve first year savings across all CCR electronic
delivery methods since it already has the technological infrastructure to support electronic
delivery. The average CWS will likely breakeven in the first year across all CCR electronic
delivery methods. For the specific analysis using AWWA and MDH percentages see
Attachments 5-5 and 5-6, respectively. A summary of the breakeven points for Scenario C can be
found in Attachment 3-3.
• Scenario D: The average size CWS in the 10,001 - 50,000 population size category will not
achieve a first year cost savings with electronic delivery. This CWS will likely have a breakeven
point of three to 13 years (where possible to recoup) across all electronic delivery methods due to
the costs of investing in a website, using a third-party for mass email delivery and active email
collection. CWSs in the 50,001 - 99,999 population size category will only achieve a first year
cost savings if it mails a notification statement on a utility bill that the CCR is ready to view via
direct URL on a website. These CWSs will likely have breakeven points of two to 15 years
across all electronic delivery methods. CWSs in the 100,000 and over population size category
will likely only achieve a first year cost savings if it mails a notification statement on a utility bill
or a separate mailing that the CCR is ready to view via direct URL on a website. These CWSs
will likely have breakeven points of one to 12 years based on the costs of third-party mass
emailing and active email collection. For specific analyses using AWWA and MDH percentages
see Attachments 5-7 and 5-8, respectively. A summary of the breakeven points for Scenario D
can be found in Attachment 3-4.
CWS SCENARIO ANALYSES FOR APPROACH 2
Cost differences for electronic CCR delivery with a customer option to request a paper CCR were
calculated using the AWWA and MDH delivery preference percentages across the four scenarios and
are found in Attachment 6. The tables summarizing the breakeven points can be found in Attachment 3.
This analysis was not able to account for costs incurred for any advance notice a CWS should provide
prior their CCR electronic delivery.
• Scenario A: In general, the average size CWS across all population size categories will achieve a
first year cost savings if it chooses to mail a notification on a utility bill or a separate mailing that
the CCR is available to view via direct URL on a website. However, the average size CWS
across all population size categories is likely to incur an increased costs the first year if it emails
a notification, PDF or embedded the CCR in the body of the email. The increased costs are due
to investing in third-party mass email delivery and passive email collection. In general, the
average size CWS across all population size categories could expect to breakeven in one to three
years of delivering its CCR by an electronic delivery method. For specific analyses using
CCR Rule Retrospective Review Summary A-14 December 2012
Appendix A
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AWWA and MDH percentages see Attachments 6-1 and 6-2, respectively. A summary of the
breakeven points for Scenario A can be found in Attachment 3-1.
• Scenario B: The average size CWS in the 10,001 - 50,000 population size category will not
achieve a first year cost savings due to the cost of investing in a website, purchasing an in-house
mass email delivery system and active email collection. This CWS will have a breakeven point
of three to 11 years if it chooses to mail a notification in a utility bill or on a separate mailing that
the CCR is ready to view via direct URL on a website. The average size CWS in the 50,001 -
99,999 population size category will only achieve a first year cost savings if it mails a
notification statement on a utility bill that the CCR is ready to view via direct URL on a website.
This CWS will likely have breakeven point of two to three years. The average size CWS in the
100,000 and over population size category will likely only achieve a first year cost savings if it
mails a notification statement on a utility bill or a separate mailing that the CCR is ready to view
via direct URL on a website. This CWS will likely have a breakeven point of one year. For all
three population size categories it may not be possible to recoup the cost of investing in a
website, purchasing an in-house mass email delivery system and active email collection for the
sole purpose of CCR delivery. For specific analyses using AWWA and MDH percentages see
Attachments 6-3 and 6-4, respectively. A summary of the breakeven points for Scenario B can be
found in Attachment 3-2.
• Scenario C: This scenario was only modeled on the average size CWS serving 100,000 and over
persons. The average CWS will likely achieve first year savings across all CCR electronic
delivery methods due to the established technological infrastructure to support electronic
delivery. The average CWS will likely breakeven in the first year. For the specific analysis using
AWWA and MDH percentages see Attachments 6-5 and 6-6, respectively. A summary of the
breakeven points for Scenario C can be found in Attachment 3-3.
• Scenario D: The average size CWS in the 10,001 - 50,000 population size category will not
achieve a first year cost savings with electronic delivery. This CWS will likely have a breakeven
point of three to 11 years across all electronic delivery methods due to the costs of investing in a
website, third-party mass email delivery and active email collection. The average size CWS in
the 50,001 - 99,999 population size category will only achieve a first year cost savings if it mails
a notification statement on a utility bill that the CCR is ready to view via direct URL on a
website. This CWS will likely breakeven in two to nine years across all electronic delivery
methods. The average size CWS in the 100,000 and over population size category will likely
only achieve a first year cost savings if it mails a notification statement on a utility bill or a
separate mailing that the CCR is ready to view via direct URL on a website. This CWS will
likely breakeven in one to eight years based on the costs of third-party mass emailing and active
email collection. For specific analyses using AWWA and MDH percentages see Attachments 6-7
CCR Rule Retrospective Review Summary A-15 December 2012
Appendix A
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and 6-8, respectively. A summary of the breakeven points for Scenario D can be found in
Attachment 3-4.
COST SAVINGS DIFFERENCE SUMMARY
A range of cost savings differences for the first year was calculated for all four CWS scenarios, two
approaches and four electronic delivery methods utilizing AWWA and MDH percentages and is found
in Attachment 4.
• Scenario A: In general, the average size CWS across all population size categories will achieve
the greatest first year cost savings if it mails a notification on a utility bill that the CCR is
available to view via direct URL on a website. The first year cost savings range from $875 to
$18,727 depending on CWS population size. The average size CWS across all population size
categories is likely to incur the highest increase in first year costs (e.g., up to $6,073 of costs
were found for the largest CWS size category) if it emails a notification. This trend is seen in
both Approaches 1 and 2. A summary of the first year cost difference for Scenario A can be
found in Attachment 4-1.
• Scenario B: In general, the average size CWS in the 10,001 - 50,000 population size category
will not achieve a first year cost savings utilizing electronic delivery. The average size CWS in
the 50,001 - 99,999 population size category will only achieve a first year cost savings ($257 -
$2,221) if it mails a notification statement on a utility bill that the CCR is ready to view via
direct URL on a website. The average size CWS in the 100,000 and over population size
category will likely see the greatest cost savings ($10,485 - $18,727) in the first year if it mails a
notification statement on a utility bill but will also see modest savings ($3,521 - $5,997) when
sending a separate mailing that the CCR is ready to view via direct URL on a website. For those
CWSs achieving a cost savings, the amount is greater with Approach 2. No savings may ever be
achieved (i.e., breakeven point achieved) across any CWS size category utilizing an email
method if the CWS purchases an electronic billing system and only uses it for CCR delivery. A
summary of the first year cost difference for Scenario B can be found in Attachment 4-2.
• Scenario C: The average CWS serving 100,000 or more persons will likely achieve first year
savings across all CCR electronic delivery methods. Greater savings up to $18,727 may be
achieved with Approach 2 but the savings are generally the same across both Approaches. A
summary of the first year cost difference for Scenario C can be found in Attachment 4-3.
• Scenario D: In general, the average size CWS in the 10,001 - 50,000 population size category
will not achieve a first year cost savings utilizing electronic delivery. The average size CWS in
the 50,001 - 99,999 population size category will only achieve a first year cost savings if it mails
CCR Rule Retrospective Review Summary A-16 December 2012
Appendix A
-------
a notification statement on a utility bill that the CCR is ready to view via direct URL on a
website. For the average size CWS in the two smaller population size categories, the most
expensive delivery method would be emailing a direct URL as the CWS would incur the extra
costs associated with emailing and creating/maintaining a website. The average size CWS in the
100,000 and over population size category will achieve the greatest first year cost savings
between $10,485 and $18,727 if it mails a notification statement on a utility bill that the CCR is
ready to view via direct URL on a website. A summary of the first year cost difference for
Scenario D can be found in Attachment 4-4.
CONCLUSIONS
CWSs transit!oning to electronic delivery for a portion of their CCRs may incur costs such as:
• Producing and delivering a separate mailing
• Creating a website
• Hosting a website
• Collecting email addresses from customers
• Utilizing a third-party vendor to deliver email notifications
• Investing in an electronic billing system and software package
For CWSs that send a portion of their CCRs by an electronic delivery method, there are savings
associated with a reduction in printing the CCR and mailing the CCR separately. However, those
savings may or may not be enough to outweigh the costs associated with switching to an electronic
delivery method. Therefore, first year savings are not expected for every CWS that switches to an
electronic delivery method. The less cost there is to transition to an electronic delivery method, the more
likely a CWS is to achieve first year savings.
CCR delivery costs are heavily dependent on the percentage of customers who participate in electronic
delivery, as is seen in Approach 1 with the difference between the AWWA and MDH data. In all of
these analyses a large difference in customer delivery preference is seen in the AWWA data in
Approach 1 from the rest of the data in Approaches 1 and 2. This difference is attributed to the 20.1
percent of customers who did not specify a delivery preference in the AWWA survey. In Approach 1,
this results in the AWWA data representing more customers receiving paper CCRs than the MDH data.
The MDH data reported 2.3 percent of customers who did not specify a CCR delivery method
preference and those cost estimates in Approach 1 are very similar to those in Approach 2. It is
anticipated that the higher percentage of customers who switch to electronic delivery, the greater the
anticipated savings will be.
CCR Rule Retrospective Review Summary A-17 December 2012
Appendix A
-------
When delivering a CCR electronically in subsequent years, costs are likely to be lower than in the first
year. Lower costs are attributed to the majority of the initial investment being a one-time cost such as:
• Creating a website
• Investing in an e-billing system and software package
• Collecting customer email addresses
There are likely to be ongoing maintenance costs associated with some of these initial investments, but
those are likely to be lower than the initial investment itself. Therefore, many CWSs will realize a
savings in subsequent years by using an electronic delivery method for the CCR.
To determine how long it will take to recoup the initial investment and achieve a net savings by utilizing
an electronic delivery method, a breakeven point was calculated. Breakeven points will vary. Again, this
is due to the cost of initial investment and estimated savings expected in the first year and then in
subsequent years. It is expected that high cost items, such as investing in an electronic billing system
and software package, will be used for purposes other than delivering CCRs (and therefore realize
savings in other aspects of CWS operation), but it is unlikely that the costs associated with purchasing
such a system will be offset solely by savings achieved through CCR electronic delivery.
Electronic delivery of the CCR can be a benefit for most community water systems but it is important to
examine all the factors, such as startup costs, customer delivery preference, customer technology
capabilities, etc., before investing in electronic delivery.
CCR Rule Retrospective Review Summary A-18 December 2012
Appendix A
-------
Attachment 1: National First Year Cost Difference Summary
National First Year Cost Difference Summary
CWSSize
Category
10,001 to 50,000
50,001 to 99,999
100,000 and over
Electronic Delivery
Method
Mail Notification on
Separate Mailing
Mail Notification Statement
on Bill
Email URL for CCR [2]
Email CCR as PDF [2]
Email CCR as embedded
image [21
Mail Notification on
Separate Mailing
Mail Notification Statement
on Bill
Email URL for CCR [2]
Email CCR as PDF [2]
Email CCR as embedded
image [21
Mail Notification on
Separate Mailing
Mail Notification Statement
on Bill
Email URL for CCR [2]
Email CCR as PDF [2]
Email CCR as embedded
image [21
First Year Cost Difference - Approach 1
AWWA Data
$23,475
$1,966,525
-$2,290,315 to -$351,041,645
-$1,419,403 to -$350,170,733
-$1,419,403 to -$350,170,733
$308,460
$1,205,825
-$618,559 to -$67,364,726
-$473,138 to -$67,219,305
-$473,138 to -$67,219,305
$1,465,218
$4,362,087
-$1,415,137 to -$83,951,692
-$1,415,137 to -$83,951,692
-$1,415,137 to -$83,951,692
MDH Data
$562,894
$3,955,872
-$2,825,089 to -$351,576,419
-$1,954,177 to -$350,705,507
-$1,954,177 to -$350,705,507
$586,204
$2,153,193
-$930,334 to -$67,676,500
-$784,913 to -$67,531,079
-$784,913 to -$67,531,079
$2,361,829
$7,420,377
-$2,421,606 to -$84,958,161
-$2,421,606 to -$84,958,161
-$2,421,606 to -$84,958,161
1]
First Year Cost Difference - Approach 2
AWWA Data
$648,626
$4,071,044
-$2,761,168 to -$351,512,498
-$1,890,256 to -$350,641,586
-$1,890,256 to -$350,641,586
$627,455
$2,208,041
-$901,052 to -$67,647,219
-$755,631 to -$67,501,798
-$755,631 to -$67,501,798
$2,494,996
$7,597,436
-$2,327,080 to -$84,863,635
-$2,327,080 to -$84,863,635
-$2,327,080 to -$84,863,635
MDH Data
$634,429
$4,196,687
-$2,878,968 to -$351,630,298
-$2,008,056 to -$350,759,386
-$2,008,056 to -$350,759,386
$622,705
$2,267,874
-$962,659 to -$67,708,826
-$817,238 to -$67,563,405
-$817,238 to -$67,563,405
$2,479,666
$7,790,592
-$2,525,957 to -$85,062,511
-$2,525,957 to -$85,062,511
-$2,525,957 to -$85,062,511
Notes:
[1] A positive value indicates a cost savings, while a negative value indicates an increased cost. To see national first year cost difference calculations, see Attachments 2-1 to 2-4.
[2] The ranges are based on cost differences for third party/passive electronic delivery compared to in-house/active electronic delivery.
Attachment 1
-------
Attachment 2-1: National Summary - Approach 1, AWWA Data
A
Community Water
System (CWS) Size
Category
10,001 to 50,000
50,001 to 99,999
100,000 and over
B
Number of CWSs
3,240
541
416
C
Number of
Customers (Service
Connections)
23,742,055
11,843,581
38,233,405
D
Total O&M Cost Per
Report
$0.441
$0.421
$0.421
E=C*D
CCR Paper
Delivery Cost
$10,470,247
$4,986,148
$16,096,264
F
Delivery
Approaches
Paper
Electronic
Paper
Electronic
Paper
Electronic
G
% of Customers
Receiving CCRs by
This Method
72.9%
26.4%
72.9%
26.4%
72.9%
26.4%
H
Delivery Method
Mail Paper CCR
Mail Notification on
Separate Mailing [6]
Mail Notification
Statement on Bill
[7]
Email URL for CCR
Email CCR as PDF
Email CCR as
embedded image
Mail Paper CCR
Mail Notification on
Separate Mailing [6]
Mail Notification
Statement on Bill
[7]
Email URL for CCR
Email CCR as PDF
Email CCR as
Mail Paper CCR
Mail Notification on
Separate Mailing [6]
Mail Notification
Statement on Bill
[7]
Email URL for CCR
Email CCR as PDF
Email CCR as
embedded image
I=C*D*G
CCR Mailing
Cost per CWS
Size Category
$7,632,810
$1,943,050
As part of normal
bill
$3,634,902
$897,365
As part of normal
bill
$11,734,177
$2,896,869
As part of normal
bill
J
Percent CWSs
Without a
Website [1]
0.12
0.12
0.12
/
/
0.12
0.12
0.12
/
/
/
K
Website Cost
[2]
$2,240
$2,240
$2,240
$2,240
$2,240
$2,240
,-'
$0
$0
$0
L=B*J*K
Web site Cost per
CWS Size
Category
X
$870,912
$870,912
$870,912
$145,421
$145,421
$145,421
M
Third Party
Mass Email
Cost [3]
$50
$50
$50
$100
$100
$100
$150
$150
$150
N=B*M
Third Party Mass
Email Technology
Cost per CWS Size
Category
$162,000
$162,000
$162,000
$54,100
$54,100
$54,100
$62,400
$62,400
$62,400
0
In-House Electronic
Billing System Cost [4]
$100,000
$100,000
$100,000
$100,000
$100,000
$100,000
$100,000
$100,000
$100,000
P=B*0
In-House Electronic
Billing System Cost per
CWS Size Category
$324,000,000
$324,000,000
$324,000,000
$54,100,000
$54,100,000
$54,100,000
$41,600,000
$41,600,000
$41,600,000
Q
Standard O&M
Cost
$0.03
$0.03
$0.03
x
$0.007
$0.007
$0.007
$0.007
$0.007
$0.007
R
Labor Rate
$32.38
$32.38
$32.38
$32.38
$32.38
$32.38
$32.38
$32.38
$32.38
S
Telephone Calls
per Hour
30
30
30
x
30
30
30
30
30
30
T
Database
Entries per
Hour
60
60
60
60
60
60
X
/
/
60
60
60
U=(C*Q)+(C*G)*(R/r)
Email Collection Cost
(passive)
$4,094,840
$4,094,840
$4,094,840
$1,770,284
$1,770,284
$1,770,284
$5,714,824
$5,714,824
$5,714,824
V=(C*(R/S))+(C*G)*(R/r)
Email Collection Cost (active)
$29,008,170
$29,008,170
$29,008,170
$14,470,551
$14,470,551
$14,470,551
$46,713,779
$46,713,779
$46,713,779
W=I+L+N+U
Total First Year Cost (third
party, passive) [5]
$10,446,772
$8,503,722
$12,760,562
$11,889,650
$11,889,650
$4,677,688
$3,780,323
$5,604,707
$5,459,286
$5,459,286
$14,631,046
$11,734,177
$17,511,401
$17,511,401
$17,511,401
X=I+L+P+V
Total First Year
Cost (in-house,
active) [5]
$361,511,892
$360,640,980
$360,640,980
$72,350,874
$72,205,453
$72,205,453
$100,047,956
$100,047,956
$100,047,956
Y=E-W
Cost Difference
(third party,
passive)
$23,475
$1,966,525
-$2,290,315
-$1,419,403
-$1,419,403
$308,460
$1,205,825
-$618,559
-$473,138
-$473,138
$1,465,218
$4,362,087
-$1,415,137
-$1,415,137
-$1,415,137
Z=E-X
Cost Difference (in-
house, active)
-$351,041,645
-$350,170,733
-$350,170,733
-$67,364,726
-$67,219,305
-$67,219,305
-$83,951,692
-$83,951,692
-$83,951,692
Notes:
[1] CWSs in the 100,000 and over Size Category are assumed to already have a website.
2] Website cost is assumed to include a development cost and an annual hosting cost from a third party provider.
[3] Mass emailing cost is based on the average cost for a monthly subscription from several third party providers.
[4] Electronic Billing System Cost is assumed to be the purchase of a $100,000 electronic billing system.
5] Total first year cost is the cost to mail a paper CCR to a percentage of customers plus the cost to deliver the rest of the CCRs by the selected electronic delivery method. The total cost to Mail Notification on Separate Mailing should include the cost to mail the postcard.
[6] Separate mailing is assumed to be a postcard with a mailing cost of $0.28 per postcard based on the bulk rate provided by the US Postal Service.
[7] No cost assumed if CWS adds notification to normal bill.
Assumptions:
Community Water System fCWS) Size Category: PWSS ICR 2011, Appendix B, Exhibit 2.
Number of CWSs: PWSS ICR 2011, Appendix B, Exhibit 2.
Number of Customers (Service Connections): PWSS ICR 2011, Appendix B, Exhibit 2.
Total O&M Cost Per Report: PWSS ICR 2011, Appendix B, Exhibit 3. Total O&M cost per report includes the Standard O&M cost per report (e.g., cost of paper, photocopying or printing, folding, and affixing labels) and the postage per report.
••6 Customers Receiving CCRs by This Method: 2011 AWWA Consumer Survey.
Percent CWSs Without a Website: 2012 AWWA CCR Cost Savings Survey. It is assumed that all CWSs 100,000 and over already have a website.
Standard O&M Cost: PWSS ICR 2011, Appendix B, Exhibit 3. The Standard O&M cost per report includes the cost of paper, photocopying or printing, folding, and affixing labels. It is assumed that this will also be the cost to passively collect a customer's email address.
Labor Rate: PWSS ICR 2011, Appendix B, Exhibit 5.
Telephone Calls per Hour: it assumed that each phone call will last two minutes.
Database Entries per Hour: it is assumed that each database entry takes one minute.
Email Collection Cost (active): it is assumed that CWSs have telephone contact information for all customers.
Total First Year Cost (third party, passive): the total cost of mailing a paper copy of the CCR to a portion of the customers and the cost of electronically delivering the rest. This would include costs for website development, third party email delivery and passive email collection. The costs for Mail Notification on Separate Mailing or on a Bill are included in this column.
Total First Year Cost (in-house, active): the total cost of mailing a paper copy of the CCR to a portion of the customers and the cost of electronically delivering the rest. This would include costs for website development, the purchase of an in-house electronic billing system and active email collection.
Cost Difference (third party, passive): the cost difference between paper CCR delivery and mailing a paper copy of the CCR to a portion of the customers and the cost of electronically delivering the rest. The cost difference for Mail Notification on Separate Mailing or on a Bill are included in this column.
Cost Difference Tin-house, active): the cost difference between paper CCR delivery and mailing a paper copy of the CCR to a portion of the customers and the cost of electronically delivering the rest.
Attachment 2-1
-------
Attachment 2-2: National Summary - Approach 1, MDH Data
A
Community Water
System (CWS) Size
Category
B
Number of CWSs
C
Number of Customers
(Service Connections)
D
Total O&M Cost Per
Report
E=C*D
CCR Paper
Delivery Cost
F
Delivery
Approaches
Paper
Electronic
Paper
Electronic
Paper
Electronic
G
% of Customers
Receiving CCRs
by This Method
53.9%
46.1%
53.9%
46.1%
53.9%
46.1%
H
Delivery Method
Mail Paper CCR
Mail Notification on
Separate Mailing [6]
Mail Notification
Statement on Bill [7]
Email URL for CCR
Email CCR as PDF
Email CCR as
embedded image
Mail Paper CCR
Mail Notification on
Separate Mailing [6]
Mail Notification
Statement on Bill [7]
Email URL for CCR
Email CCR as PDF
Email CCR as
embedded image
Mail Paper CCR
Mail Notification on
Separate Mailing [6]
Mail Notification
Statement on Bill [7]
Email URL for CCR
Email CCR as PDF
Email CCR as
embedded image
I=C*D*G
CCR Mailing Cost
per CWS Size
Category
$5,643,463
$3,392,978
As part of normal
bill
$2,687,534
$1,566,989
bill
/
$8,675,887
$5,058,548
As part of normal
bill
J
Percent CWSs
Without aWeb site
[1]
0.12
0.12
0.12
0.12
0.12
0.12
/
//
K
Website Cost
[2]
$2,240
$2,240
$2,240
$2,240
$2,240
$2,240
$0
$0
$0
L=B*J*K
Web site Cost per
CWS Size
Category
X'
$870,912
$870,912
$870,912
/
$145,421
$145,421
$145,421
/
//
/
M
Third Party
Mass Em ail
Cost [3]
$50
$50
$50
$100
$100
$100
$150
$150
$150
N=B*M
Third Party Mass Email
Technology Cost per
CWS Size Category
$162,000
$162,000
$162,000
$54,100
$54,100
$54,100
$62,400
$62,400
$62,400
o
In House Electronic
Billing System Cost [4]
$100,000
$100,000
$100,000
$100,000
$100,000
$100,000
$100,000
$100,000
$100,000
P=B*0
In House Electronic
Billing System Cost
per CWS Size
Category
X'
$324,000,000
$324,000,000
$324,000,000
X'
$54,100,000
$54,100,000
$54,100,000
X
$41,600,000
$41,600,000
$41,600,000
Q
Standard O&M Cost
/
$0.03
$0.03
$0.03
/
$0.007
$0.007
$0.007
/
$0.007
$0.007
$0.007
R
Lab or Rate
$32.38
$32.38
$32.38
$32.38
$32.38
$32.38
$32.38
$32.38
$32.38
S
Telephone Calls
per Hour
//
30
30
30
/
30
30
30
/
30
30
30
T
Database Entries
per Hour
X
60
60
60
X
60
60
60
X
60
60
60
U=(C*Q)+(C*G)*(R/T)
Email Collection Cost
(passive)
$6,618,961
$6,618,961
$6,618,961
$3,029,427
$3,029,427
$3,029,427
$9,779,583
$9,779,583
$9,779,583
V=(C* (R/S))+(C*G)* (R/T)
Email Collection Cost (active)
$31,532,291
$31,532,291
$31 ,532 ,291
$15,729,693
$15,729,693
$15,729,693
$50,778,538
$50,778,538
$50,778,538
W=I+L+N+U
Total First Year Cost (third
party, passive) [5]
$9,907,353
$6,514,375
$13,295,336
$12,424,424
$12,424,424
$4,399,944
$2,832,955
$5,916,482
$5,771,061
$5,771,061
$13,734,435
$8,675,887
$18,517,870
$18,517,870
$18,517,870
X=I+L+P+V
Total First Year Cost
(in-house, active) [5]
$362,046,666
$361,175,754
$361,175,754
$72,662,648
$72,517,227
$72,517,227
$101,054,425
$101,054,425
$101,054,425
Y=E-W
Cost Difference
(third party, passive)
$562,894
$3,955,872
-$2,825,089
-$1^54,177
-$1,954,177
$586,204
$2,153,193
-$930,334
-$784,913
-$784,913
$2,361,829
$7,420,377
-$2,421,606
-$2,421,606
-$2,421,606
Z=E-X
Cost Difference (in
house, active)
-$351,576,419
-$350,705,507
-$350,705,507
-$67,676,500
-$67,531,079
-$67,531,079
-$84,958,161
-$84,958,161
-$84,958,161
Notes:
[1] CWSs in the 100,000 and over Size Category are assumed to already have a website.
2] Website cost is assumed to include a development cost and an annual hosting cost from a third party provider.
3] Mass emailing cost is based on the average cost for a monthly subscription from several third party providers.
[4] Electronic Billing System Cost is assumed to be the purchase of a $100,000 electronic billing system.
[5] Total first year cost is the cost to mail a paper CCR to a percentage of customers plus the cost to deliver the rest of the CCRs by the selected electronic delivery method. The total cost to Mail Notification on Separate Mailing should include the cost to mail the postcard.
[6] Separate mailing is assumed to be a postcard with a mailing cost of $0.28 per postcard based on the bulk rate provided by the US Postal Service.
[7] No cost assumed if CWS adds notification to normal bill.
Assumptions:
Community Water System (CWS) Size Category: PWSS ICR 2011, Appendix B, Exhibit 2.
Number of CWSs: PWSS ICR 2011, Appendix B, Exhibit 2.
Number of Customers (Service Connections'): PWSS ICR 2011, Appendix B, Exhibit 2.
Total O&M Cost Per Report: PWSS ICR 2011, Appendix B, Exhibit 3. Total O&M cost per report includes the Standard O&M cost per report (e.g., cost of paper, photocopying or printing, folding, and affixing labels) and the postage per report.
% Customers Receiving CCRs by This Method: 2012 MDH Survey.
Percent CWSs Without a Website: 2012 AWWA CCR Cost Savings Survey. It is assumed that all CWSs 100,000 and over already have a website.
Standard O&M Cost: PWSS ICR 2011, Appendix B, Exhibit 3. The Standard O&M cost per report includes the cost of paper, photocopying or printing, folding, and affixing labels. It is assumed that this will also be the cost to passively collect a customer's email address.
Labor Rate: PWSS ICR 2011, Appendix B, Exhibit 5.
Telephone Calls per Hour: it assumed that each phone call will last two minutes.
Database Entries per Hour: it is assumed that each database entry takes one minute.
Email Collection Cost (active): it is assumed that CWSs have telephone contact information for all customers.
Total First Year Cost (third party, passive): the total cost of mailing a paper copy of the CCR to a portion of the customers and the cost of electronically delivering the rest. This would include costs for website development, third party email delivery and passive email collection. The costs for Mail Notification on Separate Mailing or on a Bill are included in this column.
Total First Year Cost fin-house, active): the total cost of mailing a paper copy of the CCR to a portion of the customers and the cost of electronically delivering the rest. This would include costs for website development, the purchase of an in-house electronic billing system and active email collection.
Cost Difference (third party, passive): the cost difference between paper CCR delivery and mailing a paper copy of the CCR to a portion of the customers and the cost of electronically delivering the rest. The cost difference for Mail Notification on Separate Mailing or on a Bill are included in this column.
Cost Difference fin-house, active): the cost difference between paper CCR delivery and mailing a paper copy of the CCR to a portion of the customers and the cost of electronically delivering the rest.
Attachment 2-2
-------
Attachment 2-3: National Summary - Approach 2, AWWA Data
A
Community Water
System (CWS) Size
Category
B
Number of CWSs
C
Number of Customers
(Service Connections)
D
Total O&M Cost Per
Report
E=C*D
CCR Paper
Delivery Cost
F
Delivery Approaches
Paper
Electronic
Paper
Electronic
Paper
Electronic
G
-------
Attachment 2-4: National Summary - Approach 2, MDH Data
A
Community Water
Category
an over
B
C
(Service Connections)
/ '
D
Report
'
E=C*D
Delivery Cost
'
F
Paper
Electronic
Paper
Electronic
Paper
Electronic
G
% of Customers
This Method
51.6%
48.4%
51.6%
48.4%
51.6%
48.4%
H
Mail Paper CCR
Mail Notification on
Separate Mailing [6]
Mail Notification
Statement on Bill [7]
Email URL for CCR
Email CCR as PDF
Email CCR as
embedded image
Mail Paper CCR
Mail Notification on
Separate Mailing [6]
Mail Notification
Statement on Bill [7]
Email URL for CCR
Email CCR as PDF
Email CCR as
embedded image
Mail Paper CCR
Mail Notification on
Separate Mailing [6]
Mail Notification
Statement on Bill [7]
ai as
Email CCR as
embedded image
I=C*D*G
CCR Mailing Cost
Category
$5,402,648
$3,562,258
As part of normal
bill
$2,572,853
$1,645,169
As part of normal
bill
/
//
$8,305,672
$5,310,926
As part of normal
bill
J
Percent CWSs
[1]
0.12
0.12
0.12
0.12
0.12
0.12
K
P]
$2,240
$2,240
$2,240
X'
$2,240
$2,240
$2,240
/
X
$0
$0
L=B*J*K
Website Cost per
Category
$870,912
$870,912
$870,912
$145,421
$145,421
$145,421
M
Third Party
Cost [3]
$50
$50
$50
$100
$100
$100
N=B*M
Third Party Mass Email
CWS Size Category
$162,000
$162,000
$162,000
$54,100
$54,100
$54,100
'
'
O
Billing System Cost [4]
$100,000
$100,000
$100,000
$100,000
$100,000
$100,000
'
'
P=B*O
In-House Electronic
CWS Size Category
$324,000,000
$324,000,000
$324,000,000
$54,100,000
$54,100,000
$54,100,000
'
'
Q
/
$0.03
$0.03
$0.03
/
$0.007
$0.007
$0.007
/
'
R
$32.38
$32.38
$32.38
$32.38
$32.38
$32.38
'
S
per Hour
/
30
30
30
//
30
30
30
/
T
per Hour
60
60
60
60
60
60
U=(C*Q)-f
-------
Attachment 3-1: CWS Scenario Breakeven Point Summary
Scenario A - CWS has website, chooses third party mass emailing and passive email collection
Scenario A Breakeven Point Summary [1]
CWS Size Category
10,001 to 50,000
50,001 to 99,999
100,000 and over
Electronic Delivery
Method
Mail Notification on
Separate Mailing
Mail Notification
Statement on Bill
Email URL for CCR
Email CCR as PDF
Email CCR as
embedded image
Mail Notification on
Separate Mailing
Mail Notification
Statement on Bill
Email URL for CCR
Email CCR as PDF
Email CCR as
embedded image
Mail Notification on
Separate Mailing
Mail Notification
Statement on Bill
Email URL for CCR
Email CCR as PDF
Email CCR as
embedded image
Breakeven Point (yrs) -
Approach 1
(per average size CWS)
AWWA Data
1
1
3
3
3
1
1
3
3
3
1
1
3
3
3
MDH Data
1
1
3
3
3
1
1
3
3
3
1
1
3
3
3
Breakeven Point (yrs) -
Approach 2
(per average size CWS)
AWWA Data
1
1
3
3
3
1
1
3
3
3
1
1
3
3
3
MDH Data
1
1
3
3
3
1
1
3
3
3
1
1
3
3
3
Breakeven Point
Range (yrs)
1
1
3
3
3
1
1
3
3
3
1
1
3
3
3
Notes:
[1] A breakeven point is defined as the number of years it takes to recoup the initial investment in CCR electronic delivery.
To see the breakeven point calculations for Scenario A, see Attachments 5-1, 5-2, 6-1 and 6-2.
Attachment 3-1
-------
Attachment 3-2: CWS Scenario Breakeven Point Summary
Scenario B - CWS has no website, buys a $100,000 electronic billing system and uses active email collection
Scenario B Breakeven Point Summary [1]
CWS Size Category
10,001 to 50,000
50,001 to 99,999
100,000 and over [2]
Electronic Delivery
Method
Mail Notification on
Separate Mailing
Mail Notification
Statement on Bill
Email URL for CCR
Email CCR as PDF
Email CCR as
embedded image
Mail Notification on
Separate Mailing
Mail Notification
Statement on Bill
Email URL for CCR
Email CCR as PDF
Email CCR as
embedded image
Mail Notification on
Separate Mailing
Mail Notification
Statement on Bill
Email URL for CCR
Email CCR as PDF
Email CCR as
embedded image
Breakeven Point (yrs) -
Approach 1
(per average size CWS)
AWWA Data
Not Possible
5
Not Possible
Not Possible
Not Possible
5
2
Not Possible
Not Possible
Not Possible
1
1
Not Possible
Not Possible
Not Possible
MDHData
13
3
Not Possible
Not Possible
Not Possible
4
2
Not Possible
Not Possible
Not Possible
1
1
Not Possible
Not Possible
Not Possible
Breakeven Point (yrs) -
Approach 2
(per average size CWS)
AWWA Data
11
3
Not Possible
Not Possible
Not Possible
3
2
Not Possible
Not Possible
Not Possible
1
1
Not Possible
Not Possible
Not Possible
MDH Data
11
3
Not Possible
Not Possible
Not Possible
3
2
Not Possible
Not Possible
Not Possible
1
1
Not Possible
Not Possible
Not Possible
Breakeven Point
Range (yrs)
11-13
3-5
Not Possible
Not Possible
Not Possible
3-5
2
Not Possible
Not Possible
Not Possible
1
1
Not Possible
Not Possible
Not Possible
Notes:
[1] A breakeven point is defined as the number of years it takes to recoup the initial investment in CCR electronic delivery.
To see the breakeven point calculations for Scenario B, see Attachments 5-3, 5-4, 6-3 and 6-4.
[2] It is assumed that all CWSs in the Size Category of 100,000 and over already have a website.
Not Possible: it is not possible to recoup costs solely based on CCR Delivery.
Attachment 3-2
-------
Attachment 3-3: CWS Scenario Breakeven Point Summary
Scenario C - CWS has website, has electronic billing system and a percentage of the customer's emails
Scenario C Breakeven Point Summary [1]
CWS Size Category
100,000 and over
Electronic Delivery
Method
Mail Notification on
Separate Mailing
Mail Notification
Statement on Bill
Email URL for CCR
Email CCR as PDF
Email CCR as
embedded image
Breakeven Point (yrs) -
Approach 1
(per average size CWS)
AWWA Data
1
1
1
1
1
MDHData
1
1
1
1
1
Breakeven Point (yrs) -
Approach 2
(per average size CWS)
AWWA Data
1
1
1
1
1
MDH Data
1
1
1
1
1
Breakeven Point
Range (yrs)
1
1
1
1
1
Notes:
[1] A breakeven point is defined as the number of years it takes to recoup the initial investment in CCR electronic delivery.
To see the breakeven point calculations for Scenario C, see Attachments 5-5, 5-6, 6-5 and 6-6.
Attachment 3-3
-------
Attachment 3-4: CWS Scenario Breakeven Point Summary
Scenario D - CWS has no website, chooses third party mass emailing and active email collection
Scenario D Breakeven Point Summary [1]
CWS Size Category
10,001 to 50,000
50,001 to 99,999
100,000 and over [2]
Electronic Delivery
Method
Mail Notification on
Separate Mailing
Mail Notification
Statement on Bill
Email URL for CCR
Email CCR as PDF
Email CCR as
embedded image
Mail Notification on
Separate Mailing
Mail Notification
Statement on Bill
Email URL for CCR
Email CCR as PDF
Email CCR as
embedded image
Mail Notification on
Separate Mailing
Mail Notification
Statement on Bill
Email URL for CCR
Email CCR as PDF
Email CCR as
embedded image
Breakeven Point (yrs) -
Approach 1
(per average size CWS)
AWWA Data
Not Possible
5
21
12
12
5
2
15
13
13
1
1
12
12
12
MDH Data
13
3
12
8
8
4
2
10
9
9
1
1
8
8
8
Breakeven Point (yrs) -
Approach 2
(per average size CWS)
AWWA Data
11
3
11
8
8
3
2
9
8
8
1
1
8
8
8
MDH Data
11
3
11
8
8
3
2
9
8
8
1
1
8
8
8
Breakeven Point
Range (yrs)
11-13
3-5
11-21
8-12
8-12
3-5
2
9-15
8-15
8-13
1
1
8-12
8-12
8-12
Notes:
[1] A breakeven point is defined as the number of years it takes to recoup the initial investment in CCR electronic delivery.
To see the breakeven point calculations for Scenario D, see Attachments 5-7, 5-8, 6-7 and 6-8.
[2] It is assumed that all CWSs in the Size Category of 100,000 and over already have a website.
Not Possible: it is not possible to recoup costs solely based on CCR Delivery.
Attachment 3-4
-------
Attachment 4-1: CWS Scenario First Year Cost Difference
Scenario A - CWS has website, chooses third party mass emailing and passive email collection
Scenario A First Year Cost Difference Summary [1]
CWS Size
Category
10,001 to 50,000
50,001 to 99,999
100,000 and over
Electronic Delivery
Method
Mail Notification on
Separate Mailing
Mail Notification
Statement on Bill
Email URL for CCR
Email CCR as PDF
Email CCR as
embedded image
Mail Notification on
Separate Mailing
Mail Notification
Statement on Bill
Email URL for CCR
Email CCR as PDF
Email CCR as
embedded image
Mail Notification on
Separate Mailing
Mail Notification
Statement on Bill
Email URL for CCR
Email CCR as PDF
Email CCR as
embedded image
First Year Cost Difference -
Approach 1
(per average size CWS)
AWWA Data
$275
$875
-$439
-$439
-$439
$838
$2,497
-$876
-$876
-$876
$3,521
$10,485
-$3,403
-$3,403
-$3,403
MDH Data
$441
$1,489
-$604
-$604
-$604
$1,352
$4,249
-$1,451
-$1,451
-$1,451
$5,677
$17,837
-$5,822
-$5,822
-$5,822
First Year Cost Difference -
Approach 2
(per average size CWS)
AWWA Data
$468
$1,525
-$584
-$584
-$584
$1,428
$4,350
-$1,397
-$1,397
-$1,397
$5,997
$18,263
-$5,594
-$5,594
-$5,594
MDH Data
$464
$1,564
-$620
-$620
-$620
$1,420
$4,461
-$1,511
-$1,511
-$1,511
$5,960
$18,727
-$6,073
-$6,073
-$6,073
First Year Cost
Difference Range
$275 - $468
$875 - $1,564
$-439 . $-620
$-439 - $-620
$-439 - $-620
$838 - $1,428
$2,497 - $4,461
$-876 -$-1,5 11
$-876 -$-1,5 11
$-876 -$-1,5 11
$3,521 - $5,997
$10,485 - $18,727
$-3,403 - $-6,073
$-3,403 - $-6,073
$-3,403 - $-6,073
Notes:
[1] First Year Cost Difference is defined to be the difference in first year total costs for CWSs to transition to the electronic
delivery of a portion of their CCRs. A positive value indicates a savings, while a negative value indicates an increased cost.
To see the first year cost difference calculations for Scenario A, see Attachments 5-1, 5-2, 6-1 and 6-2.
Attachment 4-1
-------
Attachment 4-2: CWS Scenario First Year Cost Difference
Scenario B - CWS has no website, buys a $100,000 electronic billing system and uses active email collection
Scenario B First Year Cost Difference Summary [1]
CWS Size
Category
10,001 to 50,000
50,001 to 99,999
100,000 and over
[2]
Electronic Delivery
Method
Mail Notification on
Separate Mailing
Mail Notification
Statement on Bill
Email URL for CCR
Email CCR as PDF
Email CCR as
embedded image
Mail Notification on
Separate Mailing
Mail Notification
Statement on Bill
Email URL for CCR
Email CCR as PDF
Email CCR as
embedded image
Mail Notification on
Separate Mailing
Mail Notification
Statement on Bill
Email URL for CCR
Email CCR as PDF
Email CCR as
embedded image
First Year Cost Difference -
Approach 1
(per average size CWS)
AWWA Data
-$1,965
-$1,365
-$110,319
-$108,079
-$108,079
-$1,402
$257
-$126,491
-$124,251
-$124,251
$3,521
$10,485
-$201,808
-$201,808
-$201,808
MDH Data
-$1,799
-$751
-$110,484
-$108,244
-$108,244
-$888
$2,009
-$127,067
-$124,827
-$124,827
$5,677
$17,837
-$204,227
-$204,227
-$204,227
First Year Cost Difference -
Approach 2
(per average size CWS)
AWWA Data
-$1,772
-$715
-$110,464
-$108,224
-$108,224
-$812
$2,110
-$127,013
-$124,773
-$124,773
$5,997
$18,263
-$203,999
-$203,999
-$203,999
MDH Data
-$1,776
-$676
-$110,500
-$108,260
-$108,260
-$820
$2,221
-$127,126
-$124,886
-$124,886
$5,960
$18,727
-$204,478
-$204,478
-$204,478
First Year Cost
Difference Range
$-1,772 -$-1,965
$-676 -$-1,365
$-110,319 -$-110,500
$-108,079 - $-108,260
$-108,079 - $-108,260
$-812 -$-1,402
$257 - $2,221
$-126,491 - $-127,126
$-124,251 -$-124,886
$-124,251 -$-124,886
$3,521 - $5,997
$10,485 - $18,727
$-20 1,808 -$-204 ,478
$-20 1,808 -$-204,478
$-20 1,808 -$-204 ,478
Notes:
[1] First Year Cost Difference is defined to be the difference in first year total costs for CWSs to transition to the electronic
delivery of a portion of their CCRs. A positive value indicates a savings, while a negative value indicates an increased cost.
To see the first year cost difference calculations for Scenario B, see Attachments 5-3, 5-4, 6-3 and 6-4.
[2] It is assumed that all CWSs in the Size Category of 100,000 and over already have a website.
Attachment 4-2
-------
Attachment 4-3: CWS Scenario First Year Cost Difference
Scenario C - CWS has website, has electronic billing system, and a percentage of the customer's emails
Scenario C First Year Cost Difference Summary [1]
CWS Size
Category
100,000 and over
Electronic Delivery
Method
Mail Notification on
Separate Mailing
Mail Notification
Statement on Bill
Email URL for CCR
Email CCR as PDF
Email CCR as
embedded image
First Year Cost Difference -
Approach 1
(per average size CWS)
AWWA Data
$3,521
$10,485
$10,485
$10,485
$10,485
MDH Data
$5,677
$17,837
$17,837
$17,837
$17,837
First Year Cost Difference -
Approach 2
(per average size CWS)
AWWA Data
$5,997
$18,263
$18,263
$18,263
$18,263
MDH Data
$5,960
$18,727
$18,727
$18,727
$18,727
First Year Cost
Difference Range
$3,521 - $5,997
$10,485 - $18,727
$10,485 - $18,727
$10,485 - $18,727
$10,485 - $18,727
Notes:
[1] First Year Cost Difference is defined to be the difference in first year total costs for CWSs to transition to the electronic
delivery of a portion of their CCRs. A positive value indicates a savings, while a negative value indicates an increased cost.
To see the first year cost difference calculations for Scenario C, see Attachments 5-5, 5-6, 6-5 and 6-6.
Attachment 4-3
-------
Attachment 4-4: CWS Scenario First Year Cost Difference
Scenario D - CWS has no website, chooses third party mass emailing and active email collection
Scenario D First Year Cost Difference Summary [1]
CWS Size
Category
10,001 to 50,000
50,001 to 99,999
100,000 and over
[2]
Electronic Delivery
Method
Mail Notification on
Separate Mailing
Mail Notification
Statement on Bill
Email URL for CCR
Email CCR as PDF
Email CCR as
embedded image
Mail Notification on
Separate Mailing
Mail Notification
Statement on Bill
Email URL for CCR
Email CCR as PDF
Email CCR as
embedded image
Mail Notification on
Separate Mailing
Mail Notification
Statement on Bill
Email URL for CCR
Email CCR as PDF
Email CCR as
embedded image
First Year Cost Difference -
Approach 1
(per average size CWS)
AWWA Data
-$1,965
-$1,365
-$10,369
-$8,129
-$8,129
-$1,402
$257
-$26,591
-$24,351
-$24,351
$3,521
$10,485
-$101,958
-$101,958
-$101,958
MDH Data
-$1,799
-$751
-$10,534
-$8,294
-$8,294
-$888
$2,009
-$27,167
-$24,927
-$24,927
$5,677
$17,837
-$104,377
-$104,377
-$104,377
First Year Cost Difference -
Approach 2
(per average size CWS)
AWWA Data
-$1,772
-$715
-$10,514
-$8,274
-$8,274
-$812
$2,110
-$27,113
-$24,873
-$24,873
$5,997
$18,263
-$104,149
-$104,149
-$104,149
MDH Data
-$1,776
-$676
-$10,550
-$8,310
-$8,310
-$820
$2,221
-$27,226
-$24,986
-$24,986
$5,960
$18,727
-$104,628
-$104,628
-$104,628
First Year Cost
Difference Range
$-1,772 -$-1,965
$-676 -$-1,365
$-10,369 -$-10,550
$-8,129 -$-8,310
$-8,129 -$-8,310
$-8 12 -$-1,402
$257 - $2,221
$-26,591 - $-27,226
$-24,351 -$-24,986
$-24,351 -$-24,986
$3,521 - $5,997
$10,485 - $18,727
$-101,958 -$-104,628
$-101,958 -$-104,628
$-101,958 -$-104,628
Notes:
[1] First Year Cost Difference is defined to be the difference in first year total costs for CWSs to transition to the electronic
delivery of a portion of their CCRs. A positive value indicates a savings, while a negative value indicates an increased cost.
To see the first year cost difference calculations for Scenario D, see Attachments 5-7, 5-8, 6-7 and 6-8.
[2] It is assumed that all CWSs in the Size Category of 100,000 and over already have a website.
Attachment 4-4
-------
Attachment 5-1: CCR Electronic Delivery Cost Savings Estimates - Approach 1, AWWA Data
Scenario A - CWS has website, chooses third party mass emailing and passive email collection
A
Community Water
System (CWS) Size
Category
10,001 to 50,000
50,001 to 99,999
100, 000 and over
B
Average Number of
Customers (Service
Connections) per CWS
7,328
21,892
91,907
C
Total O&M
Cost Per
Report
$0.441
$0.421
$0.421
D=B*C
CCR Paper
Delivery Cost
per CWS
$3,232
$9,217
$38,693
E
Delivery
Approaches
Paper
Electronic
Paper
Electronic
Paper
Electronic
F
°/o of Customers
Receiving CCRs
by This Method
72.9%
26.4%
72.9%
26.4%
72.9%
26.4%
G
Delivery Method
Mail Paper CCR
Mail Notification on Separate Mailing [3]
Mail Notification Statement on Bill [4]
Email URL for CCR
Email CCR as PDF
Email CCR as embedded image
Mail Paper CCR
Mail Notification on Separate Mailing [31
Mail Notification Statement on Bill [41
Email URL for CCR
Email CCR as PDF
Email CCR as embedded image
Mail Paper CCR
Mail Notification on Separate Mailing [3]
Mail Notification Statement on Bill [4]
Email URL for CCR
Email CCR as PDF
Email CCR as embedded image
H=D*F
CCR Mailing Cost per
CWS in Size Category
$2,357
$600
$6,720
$1,659
$28,208
$6,964
I
Third Party
Mass Emailing
Cost [1]
$50
$50
$50
$100
$100
$100
/
$150
$150
$150
J
Standard O&M
Cost
/
$0.03
$0.03
$0.03
/
$0.007
$0.007
$0.007
$0.007
$0.007
$0.007
K
Labor Rate
$32.38
$32.38
$32.38
$32.38
$32.38
$32.38
$32.38
$32.38
$32.38
L
Database
Entries per
Hour
/
60
60
60
/
60
60
60
/
60
60
60
M=(B*J)+(B*F)*(K/L)
Email Collection Cost
(passive)
$1,264
$1,264
$1,264
$3,273
$3,273
$3,273
$13,738
$13,738
$13,738
N=H+I+M
Total First Year Cost per
CWS [2]
$2,957
$2,357
$3,671
$3,671
$3,671
$8,379
$6,720
$10,093
$10,093
$10,093
$35,172
$28,208
$42,096
$42,096
$42,096
O=D-N
First Year Cost
Difference per
CWS
$275
$875
-$439
-$439
-$439
$838
$2,497
-$876
-$876
-$876
$3,521
$10,485
-$3,403
-$3,403
-$3,403
P=I+M
Costs to
Recoup per
CWS
$0
$0
$1,314
$1,314
$1,314
$0
$0
$3,373
$3,373
$3,373
$0
$0
$13,888
'Cl Q SSS
4>1 .5,OOO
$13,888
Q=H+I
Total Costs
2nd Year
per CWS
$2,957
$2,357
$2,407
$2,407
$2,407
/
$8,379
$6,720
$6,820
$6,820
$6,820
/
$35,172
$28,208
$28,208
$28,208
$28,208
R=D-Q
Savings 2nd
Year per
CWS
$275
$875
$825
$825
$825
$838
$2,497
$2,397
$2,397
$2,397
$3,521
$10,485
$10,485
$10,485
$10,485
S=P/R
Breakeven Point
(yrs) per CWS
1
1
3
3
3
1
1
3
3
3
1
1
3
3
3
Notes:
[1] Mass emailing cost is based on the average cost for a monthly subscription from several third party providers.
[2] Total first year cost is the cost to mail a paper CCR to a percentage of customers plus the cost to deliver the rest of the CCRs by the selected electronic delivery method. The annual cost to Mail Notification on Separate Mailing will include the delivery of a postcard - see note [3].
[3] A separate mailing is assumed to be a postcard with a mailing cost of S0.28 per postcard based on a bulk rate provided by the US Postal Service. The annual cost of the postcard delivery is equal to B*F*($0.28+J).
[4] No cost assumed if CWS adds notification to normal bill.
Assumptions:
Community Water System (CWS) Size Category: PWSS ICR 2011, Appendix B, Exhibit 2.
Average Number of Customers (Service Connections) per utility: PWS S ICR 2011, Appendix B, Exhibit 1.
Total O&M Cost Per Report: PWSS ICR 2011, Appendix B, Exhibit 3. Total O&M cost per report includes the Standard O&M cost per report (e.g., cost of paper, photocopying or printing, folding, and affixing labels) and the postage per report.
% of Customers Receiving CCRs by This Method: 2011 AWWA Survey.
Standard O&M Cost: PWSS ICR 2011, Appendix B, Exhibit 3. The Standard O&M cost per report includes the cost of paper, photocopying or printing, folding, and affixing labels. It is assumed that this will also be the cost to passively collect a customer's email address.
Labor Rate: PWSS ICR 2011, Appendix B, Exhibit 5.
Database Entries per Hour: it is assumed that each database entry takes one minute.
Total first year cost: considered to be the cost for an average CWS in the size category to deliver the CCR based on the delivery method chosen.
First Year Cost Difference: considered to be the difference in first year total costs for CWSs to transition to the electronic delivery of a portion of their CCRs. A positive value indicates a savings and a negative value indicates an increased cost.
Costs to Recoup: the estimated initial investment that a CWS would make to transition to the electronic delivery of a portion of their CCRs.
Total cost second year: costs are equal to or lower than the first year costs of switching to CCR electronic delivery as a portion of the initial first year costs do not occur in subsequent years. It is assumed that percentage of customers choosing electronic and paper delivery will stay the same in subsequent years.
Savings second year: savings made in subsequent years as compared to using only paper delivery.
Breakeven point: defined as the number of years it takes to recoup the initial investment in CCR electronic delivery.
Attachment 5-1
-------
Attachment 5-2: CCR Electronic Delivery Cost Savings Estimates - Approach 1, MDH Data
Scenario A - CWS has website, chooses third party mass emailing and passive email collection
A
Community Water
System (CWS) Size
Category
10,001 to 50,000
50,001 to 99,999
100,000 and over
B
Average Number of
Customers (Service
Connections) per CWS
7,328
21,892
91,907
C
Total O&M
Cost Per
Report
$0.441
$0.421
$0.421
D=B*C
CCR Paper
Delivery Cost
per CWS
$3,232
$9,217
$38,693
E
Delivery
Approaches
Paper
Electronic
Paper
Electronic
Paper
Electronic
F
°/o of Customers
Receiving CCRs
by This Method
53.9%
46.1%
53.9%
46.1%
53.9%
46.1%
G
Delivery Method
Mail Paper CCR
Mail Notification on Separate Mailing [31
Mail Notification Statement on Bill [41
Email URL for CCR
Email CCR as PDF
Email CCR as embedded image
Mail Paper CCR
Mail Notification on Separate Mailing [3]
Mail Notification Statement on Bill [4]
Email URL for CCR
Email CCR as PDF
Email CCR as embedded image
Mail Paper CCR
Mail Notification on Separate Mailing [31
Mail Notification Statement on Bill [4]
Email URL for CCR
Email CCR as PDF
Email CCR as embedded image
H=D*F
CCR Mailing Cost per
CWS in Size Category
$1,743
$1,048
/
$4,968
$2,897
/
$20,856
$12,160
/
I
Third Party
Mass
Emailing
Cost [1]
/
$50
$50
$50
/
$100
$100
$100
/
$150
$150
$150
J
Standard O&M
Cost
$0.03
$0.03
$0.03
$0.007
$0.007
$0.007
$0.007
$0.007
$0.007
K
Labor Rate
$32.38
$32.38
$32.38
$32.38
$32.38
$32.38
$32.38
$32.38
$32.38
L
Database
Entries per
Hour
60
60
60
60
60
60
60
60
60
M=(B*J)+(B*F)*(K/L)
Email Collection Cost
(passive)
$2,043
$2,043
$2,043
/
$5,600
$5,600
$5,600
/
$23,509
$23,509
$23,509
N=H+I+M
Total First Year Cost per CWS
PI
$2,791
$1,743
$3,836
$3,836
$3,836
$7,865
$4,968
$10,668
$10,668
$10,668
/
$33,016
$20,856
$44,515
$44,515
$44,515
O=D-N
First Year Cost
Difference per
CWS
$441
$1,489
-$604
-$604
-$604
$1,352
$4,249
-$1,451
-$1,451
-$1,451
$5,677
$17,837
-$5,822
-$5,822
-$5,822
P=I+M
Costs to
Recoup per
CWS
$0
$0
$2,093
$2,093
$2,093
$0
$0
$5,700
$5,700
$5,700
$0
$0
$23,659
$23,659
$23,659
Q=H+I
Total Costs
2nd Year per
CWS
$2,791
$1,743
$1,793
$1,793
$1,793
$7,865
$4,968
$5,068
$5,068
$5,068
$33,016
$20,856
$20,856
$20,856
$20,856
R=D-Q
Savings 2nd
Year per
CWS
$441
$1,489
$1,439
$1,439
$1,439
$1,352
$4,249
$4,149
$4,149
$4,149
$5,677
$17,837
$17,837
$17,837
$17,837
S=P/R
Breakeven Point
(yrs) per CWS
1
1
3
3
3
1
1
3
3
3
1
1
3
3
3
Notes:
[1] Mass emailing cost is based on the average cost for a monthly subscription from several third party providers.
[2] Total first year cost is the cost to mail a paper CCR to a percentage of customers plus the cost to deliver the rest of the CCRs by the selected electronic delivery method. The annual cost to Mail Notification on Separate Mailing will include the delivery of a postcard - see note [3].
[3] A separate mailing is assumed to be a postcard with a mailing cost of S0.28 per postcard based on a bulk rate provided by the US Postal Service. The annual cost of the postcard delivery is equal to B*F*($0.28+J).
[4] No cost assumed if CWS adds notification to normal bill.
Assumptions:
Community Water System (CWS) Size Category: PWSS ICR 2011, Appendix B, Exhibit 2.
Average Number of Customers (Service Connections) per utility: PWS S ICR 2011, Appendix B, Exhibit 1.
Total O&M Cost Per Report: PWSS ICR 2011, Appendix B, Exhibit 3. Total O&M cost per report includes the Standard O&M cost per report (e.g., cost of paper, photocopying or printing, folding, and affixing labels) and the postage per report.
% Customers Receiving CCRs by This Method: 2012 MDH Survey.
Standard O&M Cost: PWSS ICR 2011, Appendix B, Exhibit 3. The Standard O&M cost per report includes the cost of paper, photocopying or printing, folding, and affixing labels. It is assumed that this will also be the cost to passively collect a customer's email address.
Labor Rate: PWSS ICR 2011, Appendix B, Exhibit 5.
Database Entries per Hour: it is assumed that each database entry takes one minute.
Total first year cost: considered to be the cost for an average CWS in the size category to deliver the CCR based on the delivery method chosen.
First Year Cost Difference: considered to be the difference in first year total costs for CWSs to transition to the electronic delivery of a portion of their CCRs. A positive value indicates a savings and a negative value indicates an increased cost.
Costs to Recoup: the estimated initial investment that a CWS would make to transition to the electronic delivery of a portion of their CCRs.
Total cost second year: costs are equal to or lower than the first year costs of switching to CCR electronic delivery as a portion of the initial first year costs do not occur in subsequent years. It is assumed that percentage of customers choosing electronic and paper delivery will stay the same in subsequent years.
Savings second year: savings made in subsequent years as compared to using only paper delivery.
Breakeven point: defined as the number of years it takes to recoup the initial investment in CCR electronic delivery.
Attachment 5-2
-------
Attachment 5-3: CCR Electronic Delivery Cost Savings Estimates - Approach 1, AWWA Data
Scenario B - CWS has no website, buys $100,000 electronic billing system and uses active email collection
A
Community Water
System (CWS) Size
Category
10,001 to 50,000
50,001 to 99,999
100,000 and over
B
Average Number of
Customers (Service
Connections) per CWS
7,328
21,892
91,907
C
Total O&M
Cost Per
Report
$0.441
$0.421
$0.421
D=B*C
CCR Paper
Delivery Cost
per CWS
$3,232
$9,217
$38,693
E
Delivery
Approaches
Paper
Electronic
Paper
Electronic
Paper
Electronic
F
% of Customers
Receiving CCRs by
This Method
72.9%
26.4%
72.9%
26.4%
72.9%
26.4%
O
Delivery Method
Mail Paper CCR
Mail Notification on Separate Mailing [5]
Mail Notification Statement on Bill [6]
Email URL for CCR
Email CCR as PDF
Email CCR as embedded image
Mail Paper CCR
Mail Notification on Separate Mailing [5]
Mail Notification Statement on Bill [6]
Email URL for CCR
Email CCR as PDF
Email CCR as embedded image
Mail Paper CCR
Mail Notification on Separate Mailing [5]
Mail Notification Statement on Bill [6]
Email URL for CCR
Email CCR as PDF
Email CCR as embedded image
H=D*F
CCR Mailing Cost
per CWS in Size
Category
$2,357
$600
$6,720
$1,659
$28,208
$6,964
I
Website Cost [1]
$2,240
$2,240
$2,240
$2,240
$2,240
$2,240
$0
$0
$0
J
Electronic Billing
System Cost [2]
$100,000
$100,000
$100,000
$100,000
$100,000
$100,000
/
/
$100,000
$100,000
$100,000
K
Labor Rate
$32.38
$32.38
$32.38
$32.38
$32.38
$32.38
$32.38
$32.38
$32.38
L
Telephone Calls
per Hour
,"'
/
30
30
30
/
30
30
30
30
30
30
M
Database
Entries per
Hour
60
60
60
60
60
60
/
/
60
60
60
N=(B*(K/L))+(B*F)*(K/M)
Email Collection Cost
(active)
/
$8,954
$8,954
$8,954
/
$26,748
$26,748
$26,748
$112,293
$112,293
$112,293
O=H+I+J+N
Total First Year Cost per
CWS [3]
$5,197
$4,597
$113,551
$111,311
$111,311
$10,619
$8,960
$135,708
$133,468
$133,468
/
$35,172
$28,208
$240,501
$240,501
$240,501
P=D-O
First Year Cost
Difference per
CWS
-$1,965
-$1,365
-$110,319
-$108,079
-$108,079
-$1,402
$257
-$126,491
-$124,251
-$124,251
$3,521
$10,485
-$201,808
-$201,808
-$201,808
Q=I+J+N
Costs to
Recoup per
CWS
$2,240
$2,240
$111,194
$108,954
$108,954
$2,240
$2,240
$128,988
$126,748
$126,748
$0
$0
$212,293
$212,293
$212,293
R=H+I+J
Total Costs
2nd Year per
CWS [4]
$3,197
$2,597
$22,597
$22,357
$22,357
$8,619
$6,960
$26,960
$26,720
$26,720
$35,172
$28,208
$48,208
$48,208
$48,208
S=D-R
Savings 2nd
Year per
CWS
$35
$635
-$19,365
-$19,125
-$19,125
$598
$2,257
-$17,743
-$17,503
-$17,503
$3,521
$10,485
-$9,515
-$9,515
-$9,515
T=Q/S
Breakeven Point (yrs)
per CWS
,"'
Not Possible
5
Not Possible
Not Possible
Not Possible
5
2
Not Possible
Not Possible
Not Possible
1
1
Not Possible
Not Possible
Not Possible
Notes:
[1] Website cost is assumed to include a development cost and an annual hosting cost from a third party provider. CWSs in the 100,000 and over CWS Size Category are assumed to already have a website.
[2] Electronic Billing System Cost is assumed to be the purchase of a $100,000 electronic billing system.
[3] Total first year cost is the cost to mail a paper CCR to a percentage of customers plus the cost to deliver the rest of the CCRs by the selected electronic delivery method. The annual cost to Mail Notification on Separate Mailing will include the delivery of a postcard - see note [5].
[4] Second and subsequent Year Costs will only include a website hosting fee ($240) if a website was developed and electronic billing system maintenance fee ($20,000) if one was purchased.
[5] A separate mailing is assumed to be a postcard with a mailing cost of $0.28 per postcard based on a bulk rate provided by the US Postal Service. The annual cost of the postcard delivery is equal to B*F*($0.28+Standard O&M Cost).
[6] No cost assumed if CWS adds notification to normal bill.
Assumptions:
Community Water System (CWS) Size Category: PWSS ICR 2011, Appendix B, Exhibit 2.
Average Number of Customers (Service Connections) per utility: PWSS ICR 2011, Appendix B, Exhibit 1.
Standard O&M Cost: PWSS ICR 2011, Appendix B, Exhibit 3. The Standard O&M cost per report includes the cost of paper, photocopying or printing, folding, and affixing labels. The Standard O&M Cost is $0.03 per mailing for CWSs in the 10,001 to 50,000 Size Category and $0.007 per mailing for a CWS in the larger Size Categories.
Total O&M Cost Per Report: PWSS ICR 2011, Appendix B, Exhibit 3. Total O&M cost per report includes the Standard O&M cost per report (e.g., cost of paper, photocopying or printing, folding, and affixing labels) and the postage per report.
% of Customers Receiving CCRs by This Method: 2011 AWWA Survey.
Labor Rate: PWSS ICR 2011, Appendix B, Exhibit 5.
Telephone Calls per Hour: it assumed that each phone call will last two minutes.
Database Entries per Hour: it is assumed that each database entry takes one minute.
Total first year cost: considered to be the cost for an average CWS in the size category to deliver the CCR based on the delivery method chosen.
First Year Cost Difference: considered to be the difference in first year total costs for CWSs to transition to the electronic delivery of a portion of their CCRs. A positive value indicates a savings and a negative value indicates an increased cost.
Costs to Recoup: the estimated initial investment that a CWS would make to transition to the electronic delivery of a portion of their CCRs.
Total cost second year: costs are equal to or lower than the first year costs of switching to CCR electronic delivery as a portion of the initial first year costs do not occur in subsequent years. It is assumed that percentage of customers choosing electronic and paper delivery will stay the same in subsequent years.
Savings second year: savings made in subsequent years as compared to using only paper delivery.
Breakeven point: defined as the number of years it takes to recoup the initial investment in CCR electronic delivery.
Attachment 5-3
-------
Attachment 5-4: CCR Electronic Delivery Cost Savings Estimates - Approach 1, MDH Data
Scenario B - CWS has no website, buys $100,000 electronic billing system and uses active email collection
A
Community Water
System (CWS) Size
Category
10,001 to 50,000
50,001 to 99,999
100,000 and over
B
Average Number of
Customers (Service
Connections) per CWS
7,328
21,892
91,907
C
Total O&M
Cost Per
Report
$0.441
$0.421
$0.421
D=B*C
CCR Paper
Delivery Cost
per CWS
$3,232
$9,217
$38,693
E
Delivery
Approaches
Paper
Electronic
Paper
Electronic
Paper
Electronic
F
% of Customers
Receiving CCRs by
This Method
53.9%
46.1%
53.9%
46.1%
53.9%
46.1%
O
Delivery Method
Mail Paper CCR
Mail Notification on Separate Mailing [5]
Mail Notification Statement on Bill [6]
Email URL for CCR
Email CCR as PDF
Email CCR as embedded image
Mail Paper CCR
Mail Notification on Separate Mailing [5]
Mail Notification Statement on Bill [6]
Email URL for CCR
Email CCR as PDF
Email CCR as embedded image
Mail Paper CCR
Mail Notification on Separate Mailing [5]
Mail Notification Statement on Bill [6]
Email URL for CCR
Email CCR as PDF
Email CCR as embedded image
H=D*F
CCR Mailing Cost
per CWS in Size
Category
$1,743
$1,048
/
$4,968
$2,897
/
$20,856
$12,160
I
Website Cost [1]
$2,240
$2,240
$2,240
$2,240
$2,240
$2,240
$0
$0
$0
J
Electronic Billing
System Cost [2]
/
/
$100,000
$100,000
$100,000
/
$100,000
$100,000
$100,000
$100,000
$100,000
$100,000
K
Labor Rate
$32.38
$32.38
$32.38
$32.38
$32.38
$32.38
$32.38
$32.38
$32.38
L
Telephone Calls
per Hour
/
30
30
30
30
30
30
,"'
/
30
30
30
M
Database
Entries per
Hour
60
60
60
/
/
60
60
60
,-"
60
60
60
N=(B*(K/L))+(B*F)*(K/M)
Email Collection Cost
(active)
$9,733
$9,733
$9,733
$29,076
$29,076
$29,076
$122,064
$122,064
$122,064
O=H+I+J+N
Total First Year Cost
per CWS [3]
$5,031
$3,983
$113,716
$111,476
$111,476
$10,105
$7,208
$136,284
$134,044
$134,044
,"'
$33,016
$20,856
$242,920
$242,920
$242,920
P=D-O
First Year Cost
Difference per
CWS
-$1,799
-$751
-$110,484
-$108,244
-$108,244
-$888
$2,009
-$127,067
-$124,827
-$124,827
$5,677
$17,837
-$204,227
-$204,227
-$204,227
Q=I+J+N
Costs to
Recoup per
CWS
$2,240
$2,240
$111,973
$109,733
$109,733
$2,240
$2,240
$131,316
$129,076
$129,076
$0
$0
$222,064
$222,064
$222,064
R=H+J
Total Costs
2nd Year per
CWS [4]
$3,031
$1,983
$21,983
$21,743
$21,743
/
$8,105
$5,208
$25,208
$24,968
$24,968
$33,016
$20,856
$40,856
$40,856
$40,856
S=D-R
Savings 2nd
Year per
CWS
$201
$1,249
-$18,751
-$18,511
-$18,511
$1,112
$4,009
-$15,991
-$15,751
-$15,751
,"'
$5,677
$17,837
-$2,163
-$2,163
-$2,163
T=Q/S
Breakeven Point (yrs) per
CWS
13
3
Not Possible
Not Possible
Not Possible
4
2
Not Possible
Not Possible
Not Possible
1
1
Not Possible
Not Possible
Not Possible
Notes:
[1] Website cost is assumed to include a development cost and an annual hosting cost from a third party provider. CWSs in the 100,000 and over CWS Size Category are assumed to already have a website.
[2] Electronic Billing System Cost is assumed to be the purchase of a $100,000 electronic billing system.
[3] Total first year cost is the cost to mail a paper CCR to a percentage of customers plus the cost to deliver the rest of the CCRs by the selected electronic delivery method. The annual cost to Mail Notification on Separate Mailing will include the delivery of a postcard - see note [5].
[4] Second and subsequent Year Costs will only include a website hosting fee ($240) if a website was developed and electronic billing system maintenance fee ($20,000) if one was purchased.
[5] A separate mailing is assumed to be a postcard with a mailing cost of $0.28 per postcard based on a bulk rate provided by the US Postal Service. The annual cost of the postcard delivery is equal to B*F*($0.28+Standard O&M Cost).
[6] No cost assumed if CWS adds notification to normal bill.
Assumptions:
Community Water System (CWS) Size Category: PWSS ICR 2011, Appendix B, Exhibit 2.
Average Number of Customers (Service Connections) per utility: PWSS ICR 2011, Appendix B, Exhibit 1.
Standard O&M Cost: PWSS ICR 2011, Appendix B, Exhibit 3. The Standard O&M cost per report includes the cost of paper, photocopying or printing, folding, and affixing labels. The Standard O&M Cost is $0.03 per mailing for CWSs in the 10,001 to 50,000 Size Category and $0.007 per mailing for a CWS in the larger Size Categories.
Total O&M Cost Per Report: PWSS ICR 2011, Appendix B, Exhibit 3. Total O&M cost per report includes the Standard O&M cost per report (e.g., cost of paper, photocopying or printing, folding, and affixing labels) and the postage per report.
% Customers Receiving CCRs by This Method: 2012 MDH Survey.
Labor Rate: PWSS ICR 2011, Appendix B, Exhibit 5.
Telephone Calls per Hour: it assumed that each phone call will last two minutes.
Database Entries per Hour: it is assumed that each database entry will take one minute.
Total first year cost: considered to be the cost for an average CWS in the size category to deliver the CCR based on the delivery method chosen.
First Year Cost Difference: considered to be the difference in first year total costs for CWSs to transition to the electronic delivery of a portion of their CCRs. A positive value indicates a savings and a negative value indicates an increased cost.
Costs to Recoup: the estimated initial investment that a CWS would make to transition to the electronic delivery of a portion of their CCRs.
Total cost second year: costs are equal to or lower than the first year costs of switching to CCR electronic delivery as a portion of the initial first year costs do not occur in subsequent years. It is assumed that percentage of customers choosing electronic and paper delivery will stay the same in subsequent years.
Savings second year: savings made in subsequent years as compared to using only paper delivery.
Breakeven point: defined as the number of years it takes to recoup the initial investment in CCR electronic delivery.
Attachment 5-4
-------
Attachment 5-5: CCR Electronic Delivery Cost Savings Estimates - Approach 1, AWWA Data
Scenario C - CWS has website, has an electronic billing system and a percentage of the customer's emails
A
Community Water
System (CWS) Size
Category
100,000 and over
B
Average Number of
Customers (Service
Connections) per CWS
91,907
C
Total O&M Cost
Per Report
$0.421
D=B*C
CCR Paper
Delivery Cost per
CWS
$38,693
E
Delivery Approaches
Paper
Electronic
F
% of Customers
Receiving CCRs by
This Method
72.9%
26.4%
G
Delivery Method
Mail Paper CCR
Mail Notification on Separate Mailing [3]
Mail Notification Statement on Bill [4]
Email URL for CCR
Email CCR as PDF
Email CCR as embedded image
H=D*F
CCR Mailing Cost
per CWS in Size
Category
$28,208
$6,964
I=H
Total First Year Cost per CWS [1]
$35,172
$28,208
$28,208
$28,208
$28,208
J=D-I
First Year Cost Difference per
CWS
/
$3,521
$10,485
$10,485
$10,485
$10,485
K=H
Total Costs 2nd
Year per CWS
$35,172
$28,208
$28,208
$28,208
$28,208
L=D-K
Savings 2nd Year
per CWS
$3,521
$10,485
$10,485
$10,485
$10,485
M
Breakeven Point
GTS) per CWS [2]
1
1
1
1
1
Notes:
[1] Total first year cost is the cost to mail a paper CCR to a percentage of customers plus the cost to deliver the rest of the CCRs by the selected electronic delivery method. The annual cost to Mail Notification on Separate Mailing will include the delivery of a postcard- see note [3].
[2] This scenario assumes that the CWS did not need to make any investment to switch to CCR electronic delivery, so it will break even the first year.
[3] A separate mailing is assumed to be a postcard with a mailing cost of $0.28 per postcard based on a bulk rate provided by the US Postal Service. The annual cost of the postcard delivery is equal to B*F*($0.28+Standard O&M Cost).
[4] No cost assumed if CWS adds notification to normal bill.
Assumptions:
Community Water System (CWS) Size Category: PWSS ICR 2011, Appendix B, Exhibit 2.
Average Number of Customers (Service Connections') per utility: PWSS ICR 2011, Appendix B, Exhibit 1.
Total O&M Cost Per Report: PWSS ICR 2011, Appendix B, Exhibit 3. Total O&M cost per report includes the Standard O&M cost per report (e.g., cost of paper, photocopying or printing, folding, and affixing labels) and the postage per report.
Standard O&M Cost: PWSS ICR 2011, Appendix B, Exhibit 3. The Standard O&M cost per report includes the cost of paper, photocopying or printing, folding, and affixing labels. A CWS in the 100,000 and over Size Category has a Standard O&M Cost of $0.007 per mailing.
% of Customers Receiving CCRs by This Method: 2011 AWWA Survey.
Total first year cost: considered to be the cost for an average CWS in the size category to deliver the CCR based on the delivery method chosen.
First Year Cost Difference: considered to be the difference in first year total costs for CWSs to transition to the electronic delivery of a portion of their CCRs. A positive value indicates a savings and a negative value indicates an increased cost.
Costs to Recoup: the estimated initial investment that a CWS would make to transition to the electronic delivery of a portion of their CCRs.
Total cost second year: costs are equal to the first year costs of switching to CCR electronic delivery in this scenario. It is assumed that percentage of customers choosing electronic and paper delivery will stay the same in subsequent years.
Savings second year: savings made in subsequent years as compared to using only paper delivery.
Breakeven point: defined as the number of years it takes to recoup the initial investment in CCR electronic delivery.
Attachment 5-5
-------
Attachment 5-6: CCR Electronic Delivery Cost Savings Estimates - Approach 1, MDH Data
Scenario C - CWS has website, has electronic billing system and a percentage of the customer's emails
A
Community Water
System (CWS) Size
Category
100,000 and over
B
Average Number of
Customers (Service
Connections) per CWS
91,907
C
Total O&M Cost
Per Report
$0.421
D=B*C
CCR Paper
Delivery Cost per
CWS
$38,693
E
Delivery Approaches
Paper
Electronic
F
% of Customers
Receiving CCRs by
This Method
53.9%
46.1%
G
Delivery Method
Mail Paper CCR
Mail Notification on Separate Mailing [3]
Mail Notification Statement on Bill [4]
Email URL for CCR
Email CCR as PDF
Email CCR as embedded image
H=D*F
CCR Mailing Cost
per CWS in Size
Category
$20,856
$12,160
/
I=H
Total First Year Cost per CWS [1]
$33,016
$20,856
$20,856
$20,856
$20,856
J=D-I
First Year Cost Difference
per CWS
$5,677
$17,837
$17,837
$17,837
$17,837
K=H
Total Costs 2nd
Year per CWS
$33,016
$20,856
$20,856
$20,856
$20,856
L=D-K
Savings 2nd Year
per CWS
$5,677
$17,837
$17,837
$17,837
$17,837
M
Breakeven Point
(yrs) per CWS [2]
/
1
1
1
1
1
Notes:
[1] Total first year cost is the cost to mail a paper CCR to a percentage of customers plus the cost to deliver the rest of the CCRs by the selected electronic delivery method. The annual cost to Mail Notification on Separate Mailing will include the delivery of a postcard - see note [3].
[2] This scenario assumes that the CWS did not need to make any investment to switch to CCR electronic delivery, so it will break even the first year.
[3] A separate mailing is assumed to be a postcard with a mailing cost of $0.28 per postcard based on a bulk rate provided by the US Postal Service. The annual cost of the postcard delivery is equal to B*F*($0.28+Standard O&M Cost).
[4] No cost assumed if CWS adds notification to normal bill.
Assumptions:
Community Water System (CWS) Size Category: PWSS ICR 2011, Appendix B, Exhibit 2.
Average Number of Customers (Service Connections') per utility: PWSS ICR 2011, Appendix B, Exhibit 1.
Total O&M Cost Per Report: PWSS ICR 2011, Appendix B, Exhibit 3. Total O&M cost per report includes the Standard O&M cost per report (e.g., cost of paper, photocopying or printing, folding, and affixing labels) and the postage per report.
Standard O&M Cost: PWSS ICR 2011, Appendix B, Exhibit 3. The Standard O&M cost per report includes the cost of paper, photocopying or printing, folding, and affixing labels. A CWS in the 100,000 and over Size Category has a Standard O&M Cost of $0.007 per mailing.
% Customers Receiving CCRs by This Method: 2012 MDH Survey.
Total first year cost: considered to be the cost for an average CWS in the size category to deliver the CCR based on the delivery method chosen.
First Year Cost Difference: considered to be the difference in first year total costs for CWSs to transition to the electronic delivery of a portion of their CCRs. A positive value indicates a savings and a negative value indicates an increased cost.
Costs to Recoup: the estimated initial investment that a CWS would make to transition to the electronic delivery of a portion of their CCRs.
Total cost second year: costs are equal to the first year costs of switching to CCR electronic delivery in this scenario. It is assumed that percentage of customers choosing electronic and paper delivery will stay the same in subsequent years.
Savings second year: savings made in subsequent years as compared to using only paper delivery.
Breakeven point: defined as the number of years it takes to recoup the initial investment in CCR electronic delivery.
Attachment 5-6
-------
Attachment 5-7: CCR Electronic Delivery Cost Savings Estimates - Approach 1, AWWA Data
Scenario D - CWS has no website, chooses third party mass emailing and active email collection
A
Community Water
System (CWS) Size
Category
an over
B
Average Number of
Customers (Service
Connections) per CWS
C
Total O&M
Cost Per
Report
D=B*C
CCR Paper
Delivery Cost
per CWS
E
Delivery
Approaches
Paper
Electronic
Paper
Electronic
Paper
Electronic
F
% of Customers
Receiving CCRs by
This Method
72.9%
26.4%
72.9%
26.4%
72.9%
26.4%
G
Delivery Method
Mail Paper CCR
Mail Notification on Separate Mailing [5]
Mail Notification Statement on Bill [6]
Email URL for CCR
Email CCR as PDF
Email CCR as embedded image
Mail Paper CCR
Mail Notification on Separate Mailing [5]
Mail Notification Statement on Bill [6]
Email URL for CCR
Email CCR as PDF
Email CCR as embedded image
Mail Paper CCR
Mail Notification on Separate Mailing [5]
Mail Notification Statement on Bill [6]
Email URL for CCR
Email CCR as PDF
Email CCR as embedded image
H=D*F
CCR Mailing Cost
per CWS in Size
Category
$2,357
$600
$6,720
$1,659
$28,208
$6,964
I
Website Cost [1]
/
$2,240
$2,240
$2,240
$2,240
$2,240
$2,240
/
$0
$0
$0
/
/
J
Third Party
Mass
Entailing
Cost [2]
$50
$50
$50
$100
$100
$100
$150
$150
$150
K
Labor Rate
$32.38
$32.38
$32.38
$32.38
$32.38
$32.38
$32.38
$32.38
$32.38
L
Telephone Calls
per Hour
30
30
30
30
30
30
30
30
30
M
Database
Entries per
Hour
/
60
60
60
/
60
60
60
60
60
60
N=(B*(K/L))+(B*F)*(K/M)
Email Collection Cost
(active)
$8,954
$8,954
$8,954
,"'
$26,748
$26,748
$26,748
,"'
/
$112,293
$112,293
$112,293
OH+I+J+N
Total First Year Cost per
CWS [3]
$5,197
$4,597
$13,601
$11,361
$11,361
$10,619
$8,960
$35,808
$33,568
$33,568
$35,172
$28,208
$140,651
$140,651
$140,651
P=D-0
First Year Cost
Difference per
CWS
-$1,965
-$1,365
-$10,369
-$8,129
-$8,129
-$1,402
$257
-$26,591
-$24,351
-$24,351
$3,521
$10,485
-$101,958
-$101,958
-$101,958
Q=I+J+N
Costs to
Recoup per
CWS
$2,240
$2,240
$11,244
$9,004
$9,004
$2,240
$2,240
$29,088
$26,848
$26,848
$0
$0
$112,443
$112,443
$112,443
R=H+J
Total Costs
2nd Year per
CWS [4]
$3,197
$2,597
$2,647
$2,407
$2,407
$8,619
$6,960
$7,060
$6,820
$6,820
$35,172
$28,208
$28,208
$28,208
$28,208
S=D-R
Savings 2nd
Year per
CWS
$35
$635
$585
$825
$825
$598
$2,257
$2,157
$2,397
$2,397
$3,521
$10,485
$10,485
$10,485
$10,485
T=Q/S
Breakeven Point (yrs) per CWS
Not Possible
5
21
12
12
5
2
15
13
13
1
1
12
12
12
Notes:
[1] Website cost is assumed to include a development cost and an annual hosting cost from a third party provider. CWSs in the 100,000 and over CWS Size Category are assumed to already have a website.
[2] Electronic Billing System Cost is assumed to be the purchase of a $100,000 electronic billing system.
[3] Total first year cost is the cost to mail a paper CCR to a percentage of customers plus the cost to deliver the rest of the CCRs by the selected electronic delivery method. The annual cost to Mail Notification on Separate Mailing will include the delivery of a postcard - see note [5].
[4] Second and subsequent Year Costs will include a website hosting fee ($240) if website was developed
[5] A separate mailing is assumed to be a postcard with a mailing cost of $0.28 per postcard based on a bulk rate provided by the US Postal Service. The annual cost of the postcard delivery is equal to B*F*($0.28+Standard O&M Cost).
[6] No cost assumed if CWS adds notification to normal bill.
Assumptions:
Community Water System (CWS) Size Category PWSS ICR 2011, Appendix B, Exhibit 2.
Average Number of Customers (Service Connections) per utility: PWSS ICR 2011, Appendix B, Exhibit 1.
Standard O&M Cost: PWSS ICR 2011, Appendix B, Exhibit 3. The Standard O&M cost per report includes the cost of paper, photocopying or printing, folding, and affixing labels. The Standard O&M Cost is $0.03 per mailing for CWSs in the 10,001 to 50,000 Size Category and $0.007 per mailing for a CWS in the larger Size Categories.
Total O&M Cost Per Report: PWSS ICR 2011, Appendix B, Exhibit 3. Total O&M cost per report includes the Standard O&M cost per report (e.g., cost of paper, photocopying or printing, folding, and affixing labels) and the postage per report.
'/o of Customers Receiving CCRs by This Method: 2011 AWWA Survey.
Labor Rate: PWSS ICR 2011, Appendix B, Exhibit 5.
Telephone Calls per Hour: it assumed that each phone call will last two minutes.
Database Entries per Hour: it is assumed that each database entry will take one minute.
Total first year cost: considered to be the cost for an average CWS in the size category to deliver the CCR based on the delivery method chosen.
First Year Cost Difference: considered to be the difference in first year total costs for CWSs to transition to the electronic delivery of a portion of their CCRs. A positive value indicates a savings and a negative value indicates an increased cost.
Costs to Recoup: the estimated initial investment that a CWS would make to transition to the electronic delivery of a portion of their CCRs.
Total cost second year: costs are equal to or lower than the first year costs of switching to CCR electronic delivery as a portion of the initial first year costs do not occur in subsequent years. It is assumed that percentage of customers choosing electronic and paper delivery will stay the same in subsequent years.
Savings second year: savings made in subsequent years as compared to using only paper delivery.
Breakeven point: defined as the number of years it takes to recoup the initial investment in CCR electronic delivery.
Attachment 5-7
-------
Attachment 5-8: CCR Electronic Delivery Cost Savings Estimates - Approach 1, MDH Data
Scenario D - CWS has no website, chooses third party mass emailing and active email collection
A
Community Water
System (CWS) Size
Category
B
Average Number of
Customers (Service
Connections) per CWS
C
Total O&M
Cost Per
Report
D=B*C
CCR Paper
Delivery Cost
per CWS
E
Delivery
Approaches
Paper
Electronic
Paper
Electronic
Paper
Electronic
F
% of Customers
Receiving CCRs by
This Method
53.9%
46.1%
53.9%
46.1%
53.9%
46.1%
G
Delivery Method
Mail Paper CCR
Mail Notification on Separate Mailing [5]
Mail Notification Statement on Bill [6]
Email URL for CCR
Email CCR as PDF
Email CCR as embedded image
Mail Paper CCR
Mail Notification in a Separate Mailing [5]
Mail Notification Statement on Bill [6]
Email URL for CCR
Email CCR as PDF
Email CCR as embedded image
Mail Paper CCR
Mail Notification in a Separate Mailing [5]
Mail Notification Statement on Bill [6]
Email URL for CCR
Email CCR as PDF
Email CCR as embedded image
H=D*F
CCR Mailing Cost
per CWS in Size
Category
$1,743
$1,048
$4,968
$2,897
$20,856
$12,160
I
Website Cost [1]
$2,240
$2,240
$2,240
,"'
$2,240
$2,240
$2,240
/
$0
$0
$0
J
Third Party
Mass
Entailing
Cost [2]
$50
$50
$50
$100
$100
$100
$150
$150
$150
K
Labor Rate
$32.38
$32.38
$32.38
$32.38
$32.38
$32.38
$32.38
$32.38
$32.38
L
Telephone Calls
per Hour
30
30
30
30
30
30
30
30
30
M
Database
Entries per
Hour
60
60
60
60
60
60
,"'
60
60
60
N=(B*(K/L))+(B*F)*(K/M)
Email Collection Cost
(active)
$9,733
$9,733
$9,733
$29,076
$29,076
$29,076
$122,064
$122,064
$122,064
0=H+I+J+N
Total First Year Cost per
CWS [3]
$5,031
$3,983
$13,766
$11,526
$11,526
$10,105
$7,208
$36,384
$34,144
$34,144
$33,016
$20,856
$143,070
$143,070
$143,070
P=D-0
First Year Cost
Difference per
CWS
-$1,799
-$751
-$10,534
-$8,294
-$8,294
-$888
$2,009
-$27,167
-$24,927
-$24,927
$5,677
$17,837
-$104,377
-$104,377
-$104,377
Q=I+J+N
Costs to
Recoup per
CWS
$2,240
$2,240
$12,023
$9,783
$9,783
$2,240
$2,240
$31,416
$29,176
$29,176
$0
$0
$122,214
$122,214
$122,214
R=H+J
Total Costs
2nd Year per
CWS [4]
$3,031
$1,983
$2,033
$1,793
$1,793
$8,105
$5,208
$5,308
$5,068
$5,068
$33,016
$20,856
$20,856
$20,856
$20,856
S=D-R
Savings 2nd
Year per
CWS
$201
$1,249
$1,199
$1,439
$1,439
$1,112
$4,009
$3,909
$4,149
$4,149
$5,677
$17,837
$17,837
$17,837
$17,837
T=Q/S
Breakeven Point (yrs) per CWS
13
3
12
8
8
4
2
10
9
9
1
1
8
8
8
Notes:
[1] Website cost is assumed to include a development cost and an annual hosting cost from a third party provider. CWSs in the 100,000 and over CWS Size Category are assumed to already have a website.
[2] Electronic Billing System Cost is assumed to be the purchase of a $100,000 electronic billing system.
[3] Total first year cost is the cost to mail a paper CCR to a percentage of customers plus the cost to deliver the rest of the CCRs by the selected electronic delivery method. The annual cost to Mail Notification on Separate Mailing will include the delivery of a postcard - see note [5].
[4] Second and subsequent Year Costs will include a website hosting fee ($240) if website was developed
[5] A separate mailing is assumed to be a postcard with a mailing cost of $0.28 per postcard based on a bulk rate provided by the US Postal Service. The annual cost of the postcard delivery is equal to B*F*($0.28+Standard O&M Cost).
[6] No cost assumed if CWS adds notification to normal bill.
Assumptions:
Community Water System (CWS) Size Category PWSS ICR 2011, Appendix B, Exhibit 2.
Average Number of Customers (Service Connections) per utility: PWSS ICR 2011, Appendix B, Exhibit 1.
Standard O&M Cost: PWSS ICR 2011, Appendix B, Exhibit 3. The Standard O&M cost per report includes the cost of paper, photocopying or printing, folding, and affixing labels. The Standard O&M Cost is $0.03 per mailing for CWSs in the 10,001 to 50,000 Size Category and $0.007 per mailing for a CWS in the larger Size Categories.
Total O&M Cost Per Report: PWSS ICR 2011, Appendix B, Exhibit 3. Total O&M cost per report includes the Standard O&M cost per report (e.g., cost of paper, photocopying or printing, folding, and affixing labels) and the postage per report.
'/o Customers Receiving CCRs by This Method: 2012 MDH Survey.
Labor Rate: based on the PWSS ICR 2011, Appendix B, Exhibit 5.
Telephone Calls per Hour: it assumed that each phone call will last two minutes.
Database Entries per Hour: it is assumed that each database entry will take one minute.
Total first year cost: considered to be the cost for an average CWS in the size category to deliver the CCR based on the delivery method chosen.
First Year Cost Difference: considered to be the difference in first year total costs for CWSs to transition to the electronic delivery of a portion of their CCRs. A positive value indicates a savings and a negative value indicates an increased cost.
Costs to Recoup: the estimated initial investment that a CWS would make to transition to the electronic delivery of a portion of their CCRs.
Total cost second year: costs are equal to or lower than the first year costs of switching to CCR electronic delivery as a portion of the initial first year costs do not occur in subsequent years. It is assumed that percentage of customers choosing electronic and paper delivery will stay the same in subsequent years.
Savings second year: savings made in subsequent years as compared to using only paper delivery.
Breakeven point: defined as the number of years it takes to recoup the initial investment in CCR electronic delivery.
Attachment 5-8
-------
Attachment 6-1: CCR Electronic Delivery Cost Savings Estimates - Approach 2, AWWA Data
Scenario A - CWS has website, chooses third party mass emailing and passive email collection
A
Community Water
System (CWS) Size
Category
10,001 to 50,000
50,001 to 99,999
100,000 and over
B
Average Number of
Customers (Service
Connections) per CWS
7,328
21,892
91,907
C
Total O&M
Cost Per
Report
$0.441
$0.421
$0.421
D=B*C
CCR Paper
Delivery Cost
per CWS
$3,232
$9,217
$38,693
E
Delivery
Approaches
Paper
Electronic
Paper
Electronic
Paper
Electronic
F
°/o of Customers
Receiving CCRs by
This Method
52.8%
46.5%
52.8%
46.5%
52.8%
46.5%
G
Delivery Method
Mail Paper CCR
Mail Notification on Separate Mailing [31
Mail Notification Statement on Bill [41
Email URL for CCR
Email CCR as PDF
Email CCR as embedded image
Mail Paper CCR
Mail Notification on Separate Mailing [3]
Mail Notification Statement on Bill [4]
Email URL for CCR
Email CCR as PDF
Email CCR as embedded image
Mail Paper CCR
Mail Notification on Separate Mailing [31
Mail Notification Statement on Bill [4]
Email URL for CCR
Email CCR as PDF
Email CCR as embedded image
H=D*F
CCR Mailing Cost per
CWS in Size Category
$1,707
$1,057
$4,867
$2,922
$20,430
$12,266
I
Third Party
Mass
Emailing
Cost [1]
$50
$50
$50
$100
$100
$100
$150
$150
$150
J
Standard O&M
Cost
$0.03
$0.03
$0.03
$0.007
$0.007
$0.007
$0.007
$0.007
$0.007
K
Labor Rate
$32.38
$32.38
$32.38
/
$32.38
$32.38
$32.38
/
$32.38
$32.38
$32.38
L
Database
Entries per
Hour
/
60
60
60
/
60
60
60
/
60
60
60
M=(B*J)+(B*F)*(K/L)
Email Collection Cost
(passive)
/
$2,059
$2,059
$2,059
/
$5,647
$5,647
$5,647
/
$23,707
$23,707
$23,707
N=H+I+M
Total First Year Cost per
CWS [2]
$2,764
$1,707
$3,816
$3,816
$3,816
$7,789
$4,867
$10,614
$10,614
$10,614
$32,696
$20,430
$44,287
$44,287
$44,287
O=D-N
First Year Cost
Difference per
CWS
$468
$1,525
-$584
-$584
-$584
$1,428
$4,350
-$1,397
-$1,397
-$1,397
$5,997
$18,263
-$5,594
-$5,594
-$5,594
P=I+M
Costs to
Recoup per
CWS
$0
$0
$2,109
$2,109
$2,109
$0
$0
$5,747
$5,747
$5,747
/
$0
$0
$23,857
$23,857
$23,857
Q=H+I
Total Costs
2nd Year per
CWS
/
$2,764
$1,707
$1,757
$1,757
$1,757
/
$7,789
$4,867
$4,967
$4,967
$4,967
$32,696
$20,430
$20,430
$20,430
$20,430
R=D-Q
Savings 2nd
Year per
CWS
$468
$1,525
$1,475
$1,475
$1,475
$1,428
$4,350
$4,250
$4,250
$4,250
$5,997
$18,263
$18,263
$18,263
$18,263
S=P/R
Breakeven Point
(yrs) per CWS
1
1
3
3
3
1
1
3
3
3
1
1
3
3
3
Notes:
[1] Mass emailing cost is based on the average cost for a monthly subscription from several third party providers.
[2] Total first year cost is the cost to mail a paper CCR to a percentage of customers plus the cost to deliver the rest of the CCRs by the selected electronic delivery method. The annual cost to Mail Notification on Separate Mailing will include the delivery of a postcard - see note [3].
[3] A separate mailing is assumed to be a postcard with a mailing cost of $0.28 per postcard based on a bulk rate provided by the US Postal Service. The annual cost of the postcard delivery is equal to B*F*($0.28+J).
[4] No cost assumed if CWS adds notification to normal bill.
Assumptions:
Community Water System (CWS) Size Category: PWSS ICR 2011, Appendix B, Exhibit 2.
Average Number of Customers (Service Connections) per utility: PWS S ICR 2011, Appendix B, Exhibit 1.
Total O&M Cost Per Report: PWSS ICR 2011, Appendix B, Exhibit 3. Total O&M cost per report includes the Standard O&M cost per report (e.g., cost of paper, photocopying or printing, folding, and affixing labels) and the postage per report.
% of Customers Receiving CCRs by This Method: 2011 AWWA Survey.
Standard O&M Cost: PWSS ICR 2011, Appendix B, Exhibit 3. The Standard O&M cost per report includes the cost of paper, photocopying or printing, folding, and affixing labels. It is assumed that this will also be the cost to passively collect a customer's email address.
Labor Rate: PWSS ICR 2011, Appendix B, Exhibit 5.
Database Entries per Hour: it is assumed that each database entry will take one minute.
Total first year cost: considered to be the cost for an average CWS in the size category to deliver the CCR based on the delivery method chosen.
First Year Cost Difference: considered to be the difference in first year total costs for CWSs to transition to the electronic delivery of a portion of their CCRs. A positive value indicates a savings and a negative value indicates an increased cost.
Costs to Recoup: the estimated initial investment that a CWS would make to transition to the electronic delivery of a portion of their CCRs.
Total cost second year: costs are equal to or lower than the first year costs of switching to CCR electronic delivery as a portion of the initial first year costs do not occur in subsequent years. It is assumed that percentage of customers choosing electronic and paper delivery will stay the same in subsequent years.
Savings second year: savings made in subsequent years as compared to using only paper delivery.
Breakeven point: defined as the number of years it takes to recoup the initial investment in CCR electronic delivery.
Attachment 6-1
-------
Attachment 6-2: CCR Electronic Delivery Cost Savings Estimates - Approach 2, MDH Data
Scenario A - CWS has website, chooses third party mass emailing and passive email collection
A
Community Water
System (CWS) Size
Category
B
Average Number of
Customers (Service
Connections) per CWS
C
Total O&M
Cost Per
Report
D=B*C
CCR Paper
Delivery Cost
per CWS
E
Delivery
Approaches
Paper
Electronic
Paper
Electronic
Paper
Electronic
F
°/o of Customers
Receiving CCRs by
This Method
51.6%
48.4%
51.6%
48.4%
51.6%
48.4%
G
Delivery Method
Mail Paper CCR
Mail Notification on Separate Mailing [31
Mail Notification Statement on Bill [4]
Email URL for CCR
Email CCR as PDF
Email CCR as embedded image
Mail Paper CCR
Mail Notification on Separate Mailing [3]
Mail Notification Statement on Bill [41
Email URL for CCR
Email CCR as PDF
Email CCR as embedded image
Mail Paper CCR
Mail Notification on Separate Mailing [3]
Mail Notification Statement on Bill [4]
Email URL for CCR
Email CCR as PDF
Email CCR as embedded image
H=D*F
CCR Mailing Cost per
CWS in Size Category
$1,668
$1,100
$4,756
$3,041
$19,966
$12,767
I
Third Party
Mass
Emailing
Cost [1]
$50
$50
$50
$100
$100
$100
$150
$150
$150
J
Standard O&M
Cost
$0.03
$0.03
$0.03
$0.007
$0.007
$0.007
$0.007
$0.007
$0.007
K
Labor Rate
/
$32.38
$32.38
$32.38
/
$32.38
$32.38
$32.38
$32.38
$32.38
$32.38
L
Database
Entries per
Hour
60
60
60
60
60
60
/
60
60
60
M=(B*J)+(B*F)*(K/L)
Email Collection Cost
(passive)
/
$2,134
$2,134
$2,134
/
$5,872
$5,872
$5,872
/
$24,650
$24,650
$24,650
N=H+I+M
Total First Year Cost per
CWS [2]
$2,768
$1,668
$3,852
$3,852
$3,852
$7,797
$4,756
$10,728
$10,728
$10,728
$32,733
$19,966
$44,766
$44,766
$44,766
O=D-N
First Year Cost
Difference per
CWS
$464
$1,564
-$620
-$620
-$620
$1,420
$4,461
-$1,511
-$1,511
-$1,511
$5,960
$18,727
-$6,073
-$6,073
-$6,073
P=I+M
Costs to
Recoup per
CWS
$0
$0
$2,184
$2,184
$2,184
$0
$0
$5,972
$5,972
$5,972
$0
$0
$24,800
$24,800
$24,800
Q=H+I
Total Costs
2nd Year per
CWS
$2,768
$1,668
$1,718
$1,718
$1,718
$7,797
$4,756
$4,856
$4,856
$4,856
$32,733
$19,966
$19,966
$19,966
$19,966
R=D-Q
Savings 2nd
Year per
CWS
$464
$1,564
$1,514
$1,514
$1,514
$1,420
$4,461
$4,361
$4,361
$4,361
/
$5,960
$18,727
$18,727
$18,727
$18,727
S=P/R
Breakeven Point
(yrs) per CWS
1
1
Notes:
[1] Mass emailing cost is based on the average cost for a monthly subscription from several third party providers.
[2] Total first year cost is the cost to mail a paper CCR to a percentage of customers plus the cost to deliver the rest of the CCRs by the selected electronic delivery method. The annual cost to Mail Notification on Separate Mailing will include the delivery of a postcard - see note [3].
[3] A separate mailing is assumed to be a postcard with a mailing cost of $0.28 per postcard based on a bulk rate provided by the US Postal Service. The annual cost of the postcard delivery is equal to B*F*($0.28+J).
[4] No cost assumed if CWS adds notification to normal bill.
Assumptions:
Community Water System (CWS) Size Category: PWSS ICR 2011, Appendix B, Exhibit 2.
Average Number of Customers (Service Connections) per utility: PWS S ICR 2011, Appendix B, Exhibit 1.
Total O&M Cost Per Report: PWSS ICR 2011, Appendix B, Exhibit 3. Total O&M cost per report includes the Standard O&M cost per report (e.g., cost of paper, photocopying or printing, folding, and affixing labels) and the postage per report.
% Customers Receiving CCRs by This Method: 2012 MDH Survey.
Standard O&M Cost: PWSS ICR 2011, Appendix B, Exhibit 3. The Standard O&M cost per report includes the cost of paper, photocopying or printing, folding, and affixing labels. It is assumed that this will also be the cost to passively collect a customer's email address.
Labor Rate: PWSS ICR 2011, Appendix B, Exhibit 5.
Database Entries per Hour: it is assumed that each database entry will take one minute.
Total first year cost: considered to be the cost for an average CWS in the size category to deliver the CCR based on the delivery method chosen.
First Year Cost Difference: considered to be the difference in first year total costs for CWSs to transition to the electronic delivery of a portion of their CCRs. A positive value indicates a savings and a negative value indicates an increased cost.
Costs to Recoup: the estimated initial investment that a CWS would make to transition to the electronic delivery of a portion of their CCRs.
Total cost second year: costs are equal to or lower than the first year costs of switching to CCR electronic delivery as a portion of the initial first year costs do not occur in subsequent years. It is assumed that percentage of customers choosing electronic and paper delivery will stay the same in subsequent years.
Savings second year: savings made in subsequent years as compared to using only paper delivery.
Breakeven point: defined as the number of years it takes to recoup the initial investment in CCR electronic delivery.
Attachment 6-2
-------
Attachment 6-3: CCR Electronic Delivery Cost Savings Estimates - Approach 2, AWWA Data
Scenario B - CWS has no website, buys $100,000 electronic billing system and uses active email collection
A
Community Water
System (CWS) Size
Category
10,001 to 50, 000
50,001 to 99,999
100, 000 and over
B
Average Number of
Customers (Service
Connections) per CWS
7,328
21,892
91,907
C
Total O&M
Cost Per
Report
$0.441
$0.421
$0.421
D=B*C
CCR Paper
Delivery Cost
per CWS
$3,232
$9,217
$38,693
E
Delivery
Approaches
Paper
Electronic
Paper
Electronic
Paper
Electronic
F
% of Customers
Receiving CCRs by
This Method
52.8%
46.5%
52.8%
46.5%
52.8%
46.5%
G
Delivery Method
Mail Paper CCR
Mail Notification on Separate Mailing [5]
Mail Notification Statement on Bill [6]
Email URL for CCR
Email CCR as PDF
Email CCR as embedded image
Mail Paper CCR
Mail Notification on Separate Mailing [5]
Mail Notification Statement on Bill [6]
Email URL for CCR
Email CCR as PDF
Email CCR as embedded image
Mail Paper CCR
Mail Notification on Separate Mailing [5]
Mail Notification Statement on Bill [6]
Email URL for CCR
Email CCR as PDF
Email CCR as embedded image
H=D*F
CCR Mailing Cost
per CWS in Size
Category
$1,707
$1,057
/
$4,867
$2,922
/
/
$20,430
$12,266
I
Website Cost [1]
$2,240
$2,240
$2,240
/
$2,240
$2,240
$2,240
,"'
$0
$0
$0
J
Electronic Billing
System Cost [2]
$100,000
$100,000
$100,000
$100,000
$100,000
$100,000
$100,000
$100,000
$100,000
K
Labor Rate
$32.38
$32.38
$32.38
$32.38
$32.38
$32.38
$32.38
$32.38
$32.38
L
Telephone Calls
per Hour
30
30
30
30
30
30
30
30
30
M
Database
Entries per
Hour
/
60
60
60
/
60
60
60
60
60
60
N=(B*(K/L))+(B*F)*(K/M)
Email Collection Cost
(active)
$9,749
$9,749
$9,749
$29,123
$29,123
$29,123
$122,262
$122,262
$122,262
OH+I+J+N
Total First Year Cost per
CWS [3]
$5,004
$3,947
$113,696
$111,456
$111,456
$10,029
$7,107
$136,230
$133,990
$133,990
$32,696
$20,430
$242,692
$242,692
$242,692
P=D-0
First Year Cost
Difference per
CWS
-$1,772
-$715
-$110,464
-$108,224
-$108,224
-$81 2
$2,110
-$127,013
-$124,773
-$124,773
$5,997
$18,263
-$203,999
-$203,999
-$203,999
Q=I+J+N
Costs to
Recoup per
CWS
$2,240
$2,240
$111,989
$109,749
$109,749
$2,240
$2,240
$131,363
$129,123
$129,123
$0
$0
$222,262
$222,262
$222,262
R=H+J
Total Costs
2nd Year per
CWS [4]
$3,004
$1,947
$21,947
$21,947
$21,947
$8,029
$5,107
$25,107
$25,107
$25,107
$32,696
$20,430
$40,430
$40,430
$40,430
S=D-R
Savings 2nd
Year per
CWS
$228
$1,285
-$18,715
-$18,715
-$18,715
$1,188
$4,110
-$15,890
-$15,890
-$15,890
$5,997
$18,263
-$1,737
-$1,737
-$1,737
T=Q/S
Breakeven Point (yrs)
per CWS
11
3
Not Possible
Not Possible
Not Possible
3
2
Not Possible
Not Possible
Not Possible
1
1
Not Possible
Not Possible
Not Possible
Notes:
[1] Website cost is assumed to include a development cost and an annual hosting cost from a third party provider. CWSs in the 100,000 and over CWS Size Category are assumed to already have a website.
[2] Electronic Billing System Cost is assumed to be the purchase of a $100,000 electronic billing system.
[3] Total first year cost is the cost to mail a paper CCR to a percentage of customers plus the cost to deliver the rest of the CCRs by the selected electronic delivery method. The annual cost to Mail Notification on Separate Mailing will include the delivery of a postcard - see note [5].
[4] Second and subsequent Year Costs will only include a website hosting fee ($240) if a website was developed and electronic billing system maintenance fee ($20,000) if one was purchased.
[5] A separate mailing is assumed to be a postcard with a mailing cost of $0.28 per postcard based on a bulk rate provided by the US Postal Service. The annual cost of the postcard delivery is equal to B*F*($0.28+Standard O&M Cost).
[6] No cost assumed if CWS adds notification to normal bill.
Assumptions:
Community Water System (CWS) Size Category PWSS ICR 2011, Appendix B, Exhibit 2.
Average Number of Customers (Service Connections) per utility: PWSS ICR 2011, Appendix B, Exhibit 1.
Standard O&M Cost: PWSS ICR 2011, Appendix B, Exhibit 3. The Standard O&M cost per report includes the cost of paper, photocopying or printing, folding, and affixing labels. The Standard O&M Cost is $0.03 per mailing for CWSs in the 10,001 to 50,000 Size Category and $0.007 per mailing for a CWS in the larger Size Categories.
Total O&M Cost Per Report: PWSS ICR 2011, Appendix B, Exhibit 3. Total O&M cost per report includes the Standard O&M cost per report (e.g., cost of paper, photocopying or printing, folding, and affixing labels) and the postage per report.
'/o of Customers Receiving CCRs by This Method: 2011 AWWA Survey.
Labor Rate: PWSS ICR 2011, Appendix B, Exhibit 5.
Telephone Calls per Hour: it assumed that each phone call will last two minutes.
Database Entries per Hour: it is assumed that each database entry will take one minute.
Total first year cost: considered to be the cost for an average CWS in the size category to deliver the CCR based on the delivery method chosen.
First Year Cost Difference: considered to be the difference in first year total costs for CWSs to transition to the electronic delivery of a portion of their CCRs. A positive value indicates a savings and a negative value indicates an increased cost.
Costs to Recoup: the estimated initial investment that a CWS would make to transition to the electronic delivery of a portion of their CCRs.
Total cost second year: costs are equal to or lower than the first year costs of switching to CCR electronic delivery as a portion of the initial first year costs do not occur in subsequent years. It is assumed that percentage of customers choosing electronic and paper delivery will stay the same in subsequent years.
Savings second year: savings made in subsequent years as compared to using only paper delivery.
Breakeven point: defined as the number of years it takes to recoup the initial investment in CCR electronic delivery.
Attachment 6-3
-------
Attachment 6-4: CCR Electronic Delivery Cost Savings Estimates - Approach 2, MDH Data
Scenario B - CWS has no website, buys $100,000 electronic billing system and uses active email collection
A
Community Water
System (CWS) Size
Category
an over
B
Average Number of
Customers (Service
Connections) per CWS
C
Total O&M
Cost Per
Report
D=B*C
CCR Paper
Delivery Cost
per CWS
E
Delivery
Approaches
Paper
Electronic
Paper
Electronic
Paper
Electronic
F
% of Customers
Receiving CCRs by
This Method
51 .6%
48.4%
51.6%
48.4%
51 .6%
48.4%
G
Delivery Method
Mail Paper CCR
Mail Notification on Separate Mailing [5]
Mail Notification Statement on Bill [6]
Email URL for CCR
Email CCR as PDF
Email CCR as embedded image
Mail Paper CCR
Mail Notification on Separate Mailing [5]
Mail Notification Statement on Bill [6]
Email URL for CCR
Email CCR as PDF
Email CCR as embedded image
Mail Paper CCR
Mail Notification on Separate Mailing [5]
Mail Notification Statement on Bill [6]
Email URL for CCR
Email CCR as PDF
Email CCR as embedded image
H=D*F
CCR Mailing Cost
per CWS in Size
Category
$1,668
$1,100
,"'
$4,756
$3,041
$19,966
$12,767
/
I
Website Cost [1]
$2,240
$2,240
$2,240
$2,240
$2,240
$2,240
$0
$0
$0
J
Electronic Billing
System Cost [2]
,"'
/
,"'
$100,000
$100,000
$100,000
,"'
/
$100,000
$100,000
$100,000
$100,000
$100,000
$100,000
K
Labor Rate
$32.38
$32.38
$32.38
$32.38
$32.38
$32.38
$32.38
$32.38
$32.38
L
Telephone Calls
per Hour
30
30
30
30
30
30
30
30
30
M
Database
Entries per
Hour
60
60
60
60
60
60
/
/
/
60
60
60
N=(B*(K/L))+(B*F)*(K/M)
Email Collection Cost
(active)
,"'
/
,"'
$9,824
$9,824
$9,824
,"'
/
$29,347
$29,347
$29,347
$123,205
$123,205
$123,205
OH+I+J+N
Total First Year Cost per
CWS [3]
$5,008
$3,908
$113,732
$111,492
$111,492
$10,037
$6,996
$136,343
$134,103
$134,103
$32,733
$19,966
$243,171
$243,171
$243,171
P=D-0
First Year Cost
Difference per
CWS
-$1,776
-$676
-$110,500
-$108,260
-$108,260
-$820
$2,221
-$127,126
-$124,886
-$124,886
$5,960
$18,727
-$204,478
-$204,478
-$204,478
Q=I+J+N
Costs to
Recoup per
CWS
$2,240
$2,240
$112,064
$109,824
$109,824
$2,240
$2,240
$131,587
$129,347
$129,347
$0
$0
$223,205
$223,205
$223,205
R=H+I+J
Total Costs
2nd Year per
CWS [4]
$3,008
$1,908
$21,908
$21,908
$21,908
/
$8,037
$4,996
$24,996
$24,996
$24,996
$32,733
$19,966
$39,966
$39,966
$39,966
S=D-R
Savings 2nd
Year per
CWS
,"'
$224
$1,324
-$18,676
-$18,676
-$18,676
$1,180
$4,221
-$15,779
-$15,779
-$15,779
$5,960
$18,727
-$1,273
-$1,273
-$1,273
T=Q/S
Breakeven Point (yrs)
per CWS
11
3
Not Possible
Not Possible
Not Possible
3
2
Not Possible
Not Possible
Not Possible
/
1
1
Not Possible
Not Possible
Not Possible
Notes:
[1] Website cost is assumed to include a development cost and an annual hosting cost from a third party provider. CWSs in the 100,000 and over CWS Size Category are assumed to already have a website.
[2] Electronic Billing System Cost is assumed to be the purchase of a $100,000 electronic billing system.
[3] Total first year cost is the cost to mail a paper CCR to a percentage of customers plus the cost to deliver the rest of the CCRs by the selected electronic delivery method. The annual cost to Mail Notification on Separate Mailing will include the delivery of a postcard - see note [5].
[4] Second and subsequent Year Costs will only include a website hosting fee ($240) if a website was developed and electronic billing system maintenance fee ($20,000) if one was purchased.
[5] A separate mailing is assumed to be a postcard with a mailing cost of $0.28 per postcard based on a bulk rate provided by the US Postal Service. The annual cost of the postcard delivery is equal to B*F*($0.28+Standard O&M Cost).
[6] No cost assumed if CWS adds notification to normal bill.
Assumptions:
Community Water System (CWS) Size Category PWSS ICR 2011, Appendix B, Exhibit 2.
Average Number of Customers (Service Connections) per utility: PWSS ICR 2011, Appendix B, Exhibit 1.
Standard O&M Cost: PWSS ICR 2011, Appendix B, Exhibit 3. The Standard O&M cost per report includes the cost of paper, photocopying or printing, folding, and affixing labels. The Standard O&M Cost is $0.03 per mailing for CWSs in the 10,001 to 50,000 Size Category and $0.007 per mailing for a CWS in the larger Size Categories.
Total O&M Cost Per Report: PWSS ICR 2011, Appendix B, Exhibit 3. Total O&M cost per report includes the Standard O&M cost per report (e.g., cost of paper, photocopying or printing, folding, and affixing labels) and the postage per report.
'/o Customers Receiving CCRs by This Method: 2012 MDH Survey.
Labor Rate: PWSS ICR 2011, Appendix B, Exhibit 5.
Telephone Calls per Hour: it assumed that each phone call will last two minutes.
Database Entries per Hour: it is assumed that each database entry will take one minute.
Total first year cost: considered to be the cost for an average CWS in the size category to deliver the CCR based on the delivery method chosen.
First Year Cost Difference: considered to be the difference in first year total costs for CWSs to transition to the electronic delivery of a portion of their CCRs. A positive value indicates a savings and a negative value indicates an increased cost.
Costs to Recoup: the estimated initial investment that a CWS would make to transition to the electronic delivery of a portion of their CCRs.
Total cost second year: costs are equal to or lower than the first year costs of switching to CCR electronic delivery as a portion of the initial first year costs do not occur in subsequent years. It is assumed that percentage of customers choosing electronic and paper delivery will stay the same in subsequent years.
Savings second year: savings made in subsequent years as compared to using only paper delivery.
Breakeven point: defined as the number of years it takes to recoup the initial investment in CCR electronic delivery.
Attachment 6-4
-------
Attachment 6-5: CCR Electronic Delivery Cost Savings Estimates - Approach 2, AWWA Data
Scenario C - CWS has website, has an electronic billing system and a percentage of the customer's emails
A
Community Water
System (CWS) Size
Category
100,000 and over
B
Average Number of
Customers (Service
Connections) per CWS
91,907
C
Total O&M Cost
Per Report
$0.421
D=B*C
CCR Paper
Delivery Cost per
CWS
$38,693
E
Delivery Approaches
Paper
Electronic
F
% of Customers
Receiving CCRs by
This Method
52.8%
46.5%
G
Delivery Method
Mail Paper CCR
Mail Notification on Separate Mailing [3]
Mail Notification Statement on Bill [4]
Email URL for CCR
Email CCR as PDF
Email CCR as embedded image
H=D*F
CCR Mailing Cost
per CWS in Size
Category
$20,430
$12,266
/
I=H
Total First Year Cost per CWS [1]
$32,696
$20,430
$20,430
$20,430
$20,430
J=D-I
First Year Cost Difference
per CWS
$5,997
$18,263
$18,263
$18,263
$18,263
K=H
Total Costs 2nd
Year per CWS
$32,696
$20,430
$20,430
$20,430
$20,430
L=D-K
Savings 2nd Year
per CWS
$5,997
$18,263
$18,263
$18,263
$18,263
M
Breakeven Point
(yrs) per CWS [2]
1
1
1
1
1
Notes:
[1] Total first year cost is the cost to mail a paper CCR to a percentage of customers plus the cost to deliver the rest of the CCRs by the selected electronic delivery method. The annual cost to Mail Notification on Separate Mailing will include the delivery of a postcard - see note [3].
[2] This scenario assumes that the CWS did not need to make any investment to switch to CCR electronic delivery, so it will break even the first year.
[3] A separate mailing is assumed to be a postcard with a mailing cost of $0.28 per postcard based on a bulk rate provided by the US Postal Service. The annual cost of the postcard delivery is equal to B*F*($0.28+Standard O&M Cost).
[4] No cost assumed if CWS adds notification to normal bill.
Assumptions:
Community Water System (CWS) Size Category: PWSS ICR 2011, Appendix B, Exhibit 2.
Average Number of Customers (Service Connections') per utility: PWSS ICR 2011, Appendix B, Exhibit 1.
Total O&M Cost Per Report: PWSS ICR 2011, Appendix B, Exhibit 3. Total O&M cost per report includes the Standard O&M cost per report (e.g., cost of paper, photocopying or printing, folding, and affixing labels) and the postage per report.
Standard O&M Cost: PWSS ICR 2011, Appendix B, Exhibit 3. The Standard O&M cost per report includes the cost of paper, photocopying or printing, folding, and affixing labels. A CWS in the 100,000 and over Size Category has a Standard O&M Cost of $0.007 per mailing.
% of Customers Receiving CCRs by This Method: 2011 AWWA Survey.
Total first year cost: considered to be the cost for an average CWS in the size category to deliver the CCR based on the delivery method chosen.
First Year Cost Difference: considered to be the difference in first year total costs for CWSs to transition to the electronic delivery of a portion of their CCRs. A positive value indicates a savings and a negative value indicates an increased cost.
Costs to Recoup: the estimated initial investment that a CWS would make to transition to the electronic delivery of a portion of their CCRs.
Total cost second year: costs are equal to the first year costs of switching to CCR electronic delivery in this scenario. It is assumed that percentage of customers choosing electronic and paper delivery will stay the same in subsequent years.
Savings second year: savings made in subsequent years as compared to using only paper delivery.
Breakeven point: defined as the number of years it takes to recoup the initial investment in CCR electronic delivery.
Attachment 6-5
-------
Attachment 6-6: CCR Electronic Delivery Cost Savings Estimates - Approach 2, MDH Data
Scenario C - CWS has website, has electronic billing system and a percentage of the customer's emails
A
Community Water
System (CWS) Size
Category
100,000 and over
B
Average Number of
Customers (Service
Connections) per CWS
91,907
C
Total O&M Cost
Per Report
$0.421
D=B*C
CCR Paper
Delivery Cost per
CWS
$38,693
E
Delivery Approaches
Paper
Electronic
F
% of Customers
Receiving CCRs by
This Method
51.6%
48.4%
G
Delivery Method
Mail Paper CCR
Mail Notification on Separate Mailing [3]
Mail Notification Statement on Bill [4]
Email URL for CCR
Email CCR as PDF
Email CCR as embedded image
H=D*F
CCR Mailing Cost
per CWS in Size
Category
$19,966
$12,767
I=H
Total First Year Cost per CWS [1]
$32,733
$19,966
$19,966
$19,966
$19,966
J=D-I
First Year Cost Difference per
CWS
$5,960
$18,727
$18,727
$18,727
$18,727
K=H
Total Costs 2nd
Year per CWS
$32,733
$19,966
$19,966
$19,966
$19,966
L=D-K
Savings 2nd Year
per CWS
$5,960
$18,727
$18,727
$18,727
$18,727
M
Breakeven Point
(yrs) per CWS [2]
1
1
1
1
1
Notes:
[1] Total first year cost is the cost to mail a paper CCR to a percentage of customers plus the cost to deliver the rest of the CCRs by the selected electronic delivery method. The annual cost to Mail Notification on Separate Mailing will include the delivery of a postcard - see note [3].
[2] This scenario assumes that the CWS did not need to make any investment to switch to CCR electronic delivery, so it will break even the first year.
[3] A separate mailing is assumed to be a postcard with a mailing cost of $0.28 per postcard based on a bulk rate provided by the US Postal Service. The annual cost of the postcard delivery is equal to B*F*($0.28+Standard O&M Cost).
[4] No cost assumed if CWS adds notification to normal bill.
Assumptions:
Community Water System (CWS) Size Category: PWSS ICR 2011, Appendix B, Exhibit 2.
Average Number of Customers (Service Connections') per utility: PWSS ICR 2011, Appendix B, Exhibit 1.
Total O&M Cost Per Report: PWSS ICR 2011, Appendix B, Exhibit 3. Total O&M cost per report includes the Standard O&M cost per report (e.g., cost of paper, photocopying or printing, folding, and affixing labels) and the postage per report.
Standard O&M Cost: PWSS ICR 2011, Appendix B, Exhibit 3. The Standard O&M cost per report includes the cost of paper, photocopying or printing, folding, and affixing labels. A CWS in the 100,000 and over Size Category has a Standard O&M Cost of $0.007 per mailing.
% Customers Receiving CCRs by This Method: 2012 MDH Survey.
Total first year cost: considered to be the cost for an average CWS in the size category to deliver the CCR based on the delivery method chosen.
First Year Cost Difference: considered to be the difference in first year total costs for CWSs to transition to the electronic delivery of a portion of their CCRs. A positive value indicates a savings and a negative value indicates an increased cost.
Costs to Recoup: the estimated initial investment that a CWS would make to transition to the electronic delivery of a portion of their CCRs.
Total cost second year: costs are equal to the first year costs of switching to CCR electronic delivery in this scenario. It is assumed that percentage of customers choosing electronic and paper delivery will stay the same in subsequent years.
Savings second year: savings made in subsequent years as compared to using only paper delivery.
Breakeven point: defined as the number of years it takes to recoup the initial investment in CCR electronic delivery.
Attachment 6-6
-------
Attachment 6-7: CCR Electronic Delivery Cost Savings Estimates - Approach 2, AWWA Data
Scenario D - CWS has no website, chooses third party mass emailing and active email collection
A
Community Water
System (CWS) Size
Category
B
Average Number of
Customers (Service
Connections) per CWS
C
Total O&M
Cost Per
Report
D=B*C
CCR Paper
Delivery Cost
per CWS
E
Delivery
Approaches
Paper
Electronic
Paper
Electronic
Paper
Electronic
F
% of Customers
Receiving CCRs by
This Method
52.8%
46.5%
52.8%
46.5%
52.8%
46.5%
G
Delivery Method
Mail Paper CCR
Mail Notification on Separate Mailing [5]
Mail Notification Statement on Bill [6]
Email URL for CCR
Email CCR as PDF
Email CCR as embedded image
Mail Paper CCR
Mail Notification on Separate Mailing [5]
Mail Notification Statement on Bill [6]
Email URL for CCR
Email CCR as PDF
Email CCR as embedded image
Mail Paper CCR
Mail Notification on Separate Mailing [5]
Mail Notification Statement on Bill [6]
Email URL for CCR
Email CCR as PDF
Email CCR as embedded image
H=D*F
CCR Mailing
Cost per CWS in
Size Category
$1,707
$1,057
$4,867
$2,922
$20,430
$12,266
I
Website Cost [1]
$2,240
$2,240
$2,240
$2,240
$2,240
$2,240
,"'
$0
$0
$0
J
Third Party
Mass
Emailing
Cost [2]
$50
$50
$50
$100
$100
$100
$150
$150
$150
K
Labor Rate
$32.38
$32.38
$32.38
$32.38
$32.38
$32.38
/
/
/
$32.38
$32.38
$32.38
L
Telephone Calls
per Hour
30
30
30
30
30
30
30
30
30
M
Database
Entries per
Hour
,"'
/
,"'
60
60
60
,"'
/
60
60
60
60
60
60
N=(B*(K/L))+(B*F)*(K/M)
Email Collection Cost
(active)
$9,749
$9,749
$9,749
/
$29,123
$29,123
$29,123
$122,262
$122,262
$122,262
0=H+I+J+N
Total First Year Cost per
CWS [3]
$5,004
$3,947
$13,746
$11,506
$11,506
$10,029
$7,107
$36,330
$34,090
$34,090
/
$32,696
$20,430
$142,842
$142,842
$142,842
P=D-0
First Year Cost
Difference per
CWS
-$1,772
-$715
-$10,514
-$8,274
-$8,274
-$812
$2,110
-$27,113
-$24,873
-$24,873
$5,997
$18,263
-$104,149
-$104,149
-$104,149
Q=I+J+N
Costs to
Recoup per
CWS
$2,240
$2,240
$12,039
$9,799
$9,799
$2,240
$2,240
$31,463
$29,223
$29,223
$0
$0
$122,412
$122,412
$122,412
R=H+J
Total Costs
2nd Year per
CWS [4]
$3,004
$1,947
$1,997
$1,757
$1,757
$8,029
$5,107
$5,207
$4,967
$4,967
$32,696
$20,430
$20,430
$20,430
$20,430
S=D-R
Savings 2nd
Year per
CWS
$228
$1,285
$1,235
$1,475
$1,475
/
$1,188
$4,110
$4,010
$4,250
$4,250
$5,997
$18,263
$18,263
$18,263
$18,263
T=Q/S
Breakeven Point (yrs) per CWS
11
3
11
8
8
3
2
9
8
8
1
1
8
8
8
Notes:
[1] Website cost is assumed to include a development cost and an annual hosting cost from a third party provider. CWSs in the 100,000 and over CWS Size Category are assumed to already have a website.
[2] Electronic Billing System Cost is assumed to be the purchase of a $100,000 electronic billing system.
[3] Total first year cost is the cost to mail a paper CCR to a percentage of customers plus the cost to deliver the rest of the CCRs by the selected electronic delivery method. The annual cost to Mail Notification on Separate Mailing will include the delivery of a postcard - see note [5].
[4] Second and subsequent Year Costs will include a website hosting fee ($240) if website was developed
[5] A separate mailing is assumed to be a postcard with a mailing cost of $0.28 per postcard based on a bulk rate provided by the US Postal Service. The annual cost of the postcard delivery is equal to B*F*($0.28+Standard O&M Cost).
[6] No cost assumed if CWS adds notification to normal bill.
Assumptions:
Community Water System (CWS) Size Category PWSS ICR 2011, Appendix B, Exhibit 2.
Average Number of Customers (Service Connections) per utility: PWSS ICR 2011, Appendix B, Exhibit 1.
Standard O&M Cost: PWSS ICR 2011, Appendix B, Exhibit 3. The Standard O&M cost per report includes the cost of paper, photocopying or printing, folding, and affixing labels. The Standard O&M Cost is $0.03 per mailing for CWSs in the 10,001 to 50,000 Size Category and $0.007 per mailing for a CWS in the larger Size Categories.
Total O&M Cost Per Report: PWSS ICR 2011, Appendix B, Exhibit 3. Total O&M cost per report includes the Standard O&M cost per report (e.g., cost of paper, photocopying or printing, folding, and affixing labels) and the postage per report.
'/o of Customers Receiving CCRs by This Method: 2011 AWWA Survey.
Labor Rate: PWSS ICR 2011, Appendix B, Exhibit 5.
Telephone Calls per Hour: it assumed that each phone call will last two minutes.
Database Entries per Hour: it is assumed that each database entry will take one minute.
Total first year cost: considered to be the cost for an average CWS in the size category to deliver the CCR based on the delivery method chosen.
First Year Cost Difference: considered to be the difference in first year total costs for CWSs to transition to the electronic delivery of a portion of their CCRs. A positive value indicates a savings and a negative value indicates an increased cost.
Costs to Recoup: the estimated initial investment that a CWS would make to transition to the electronic delivery of a portion of their CCRs.
Total cost second year: costs are equal to or lower than the first year costs of switching to CCR electronic delivery as a portion of the initial first year costs do not occur in subsequent years. It is assumed that percentage of customers choosing electronic and paper delivery will stay the same in subsequent years.
Savings second year: savings made in subsequent years as compared to using only paper delivery.
Breakeven point: defined as the number of years it takes to recoup the initial investment in CCR electronic delivery.
Attachment 6-7
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Attachment 6-8: CCR Electronic Delivery Cost Savings Estimates - Approach 2, MDH Data
Scenario D - CWS has no website, chooses third party mass emailing and active email collection
A
Community Water
System (CWS) Size
Category
10,001 to 50, 000
50,001 to 99,999
100, 000 and over
B
Average Number of
Customers (Service
Connections) per CWS
7,328
21,892
91,907
C
Total O&M
Cost Per
Report
$0.441
$0.421
$0.421
D=B*C
CCR Paper
Delivery Cost
per CWS
$3,232
$9,217
$38,693
E
Delivery
Approaches
Paper
Electronic
Paoer
Electronic
Paoer
Electronic
F
% of Customers
Receiving CCRs by
This Method
51.6%
48.4%
51.6%
48.4%
51.6%
48.4%
G
Delivery Method
Mail Paper CCR
Mail Notification on Separate Mailing [5]
Mail Notification Statement on Bill [6]
Email URL for CCR
Email CCR as PDF
Email CCR as embedded image
Mail Paper CCR
Mail Notification on Separate Mailing [5]
Mail Notification Statement on Bill [6]
Email URL for CCR
Email CCR as PDF
Email CCR as embedded image
Mail Paper CCR
Mail Notification on Separate Mailing [5]
Mail Notification Statement on Bill [6]
Email URL for CCR
Email CCR as PDF
Email CCR as embedded image
H=D*F
CCR Mailing Cost
per CWS in Size
Category
$1,668
$1,100
$4,756
$3,041
$19,966
$12,767
I
Website Cost [1]
$2,240
$2,240
$2,240
/
/
,-'
$2,240
$2,240
$2,240
/
/
,-'
$0
$0
$0
/
,/
J
Third Party
Mass
Emailing
Cost [2]
$50
$50
$50
$100
$100
$100
$150
$150
$150
K
Labor Rate
$32.38
$32.38
$32.38
$32.38
$32.38
$32.38
$32.38
$32.38
$32.38
L
Telephone Calls
per Hour
30
30
30
,-'
30
30
30
,-'
30
30
30
M
Database
Entries per
Hour
60
60
60
,"'
60
60
60
,"'
60
60
60
N=(B*(K/L))+(B*F)*(K/M)
Email Collection Cost
(active)
$9,824
$9,824
$9,824
$29,347
$29,347
$29,347
$123,205
$123,205
$123,205
OH+I+J+N
Total First Year Cost per
CWS [3]
$5,008
$3,908
$13,782
$11,542
$11,542
$10,037
$6,996
$36,443
$34,203
$34,203
$32,733
$19,966
$143,321
$143,321
$143,321
P=D-0
First Year Cost
Difference per
CWS
-$1,776
-$676
-$10,550
-$8,310
-$8,310
-$820
$2,221
-$27,226
-$24,986
-$24,986
$5,960
$18,727
-$104,628
-$104,628
-$104,628
Q=I+J+N
Costs to
Recoup per
CWS
$2,240
$2,240
$12,114
$9,874
$9,874
$2,240
$2,240
$31,687
$29,447
$29,447
$0
$0
$123,355
$123,355
$123,355
R=H+J
Total Costs
2nd Year
per CWS [4]
$3,008
$1,908
$1,958
$1,718
$1,718
$8,037
$4,996
$5,096
$4,856
$4,856
$32,733
$19,966
$19,966
$19,966
$19,966
S=D-R
Savings 2nd
Year per
CWS
$224
$1,324
$1,274
$1,514
$1,514
$1,180
$4,221
$4,121
$4,361
$4,361
$5,960
$18,727
$18,727
$18,727
$18,727
T=Q/S
Breakeven Point (yrs) per CWS
11
3
11
8
8
3
2
9
8
8
1
1
8
8
8
Notes:
[1] Website cost is assumed to include a development cost and an annual hosting cost from a third party provider. CWSs in the 100,000 and over CWS Size Category are assumed to already have a website.
[2] Electronic Billing System Cost is assumed to be the purchase of a $100,000 electronic billing system.
[3] Total first year cost is the cost to mail a paper CCR to a percentage of customers plus the cost to deliver the rest of the CCRs by the selected electronic delivery method. The annual cost to Mail Notification on Separate Mailing will include the delivery of a postcard - see note [5].
[4] Second and subsequent Year Costs will include a website hosting fee ($240) if website was developed
[5] A separate mailing is assumed to be a postcard with a mailing cost of $0.28 per postcard based on a bulk rate provided by the US Postal Service. The annual cost of the postcard delivery is equal to B*F*($0.28+Standard O&M Cost).
[6] No cost assumed if CWS adds notification to normal bill.
Assumptions:
Community Water System (CWS) Size Category PWSS ICR 2011, Appendix B, Exhibit 2.
Average Number of Customers (Service Connections) per utility: PWSS ICR 2011, Appendix B, Exhibit 1.
Standard O&M Cost: PWSS ICR 2011, Appendix B, Exhibit 3. The Standard O&M cost per report includes the cost of paper, photocopying or printing, folding, and affixing labels. The Standard O&M Cost is $0.03 per mailing for CWSs in the 10,001 to 50,000 Size Category and $0.007 per mailing for a CWS in the larger Size Categories.
Total O&M Cost Per Report: PWSS ICR 2011, Appendix B, Exhibit 3. Total O&M cost per report includes the Standard O&M cost per report (e.g., cost of paper, photocopying or printing, folding, and affixing labels) and the postage per report.
% Customers Receiving CCRs by This Method: 2012 MDH Survey.
Labor Rate: PWSS ICR 2011, Appendix B, Exhibit 5.
Telephone Calls per Hour: it assumed that each phone call will last two minutes.
Database Entries per Hour: it is assumed that each database entry will take one minute.
Total first year cost: considered to be the cost for an average CWS in the size category to deliver the CCR based on the delivery method chosen.
First Year Cost Difference: considered to be the difference in first year total costs for CWSs to transition to the electronic delivery of a portion of their CCRs. A positive value indicates a savings and a negative value indicates an increased cost.
Costs to Recoup: the estimated initial investment that a CWS would make to transition to the electronic delivery of a portion of their CCRs.
Total cost second year: costs are equal to or lower than the first year costs of switching to CCR electronic delivery as a portion of the initial first year costs do not occur in subsequent years. It is assumed that percentage of customers choosing electronic and paper delivery will stay the same in subsequent years.
Savings second year: savings made in subsequent years as compared to using only paper delivery.
Breakeven point: defined as the number of years it takes to recoup the initial investment in CCR electronic delivery.
Attachment 6-8
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