UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 8 ^^^7 S WASHINGTON, D.C. 20460 JAN 3 2013 MEMORANDUM OFF1CE OF WATER SUBJECT: Safe Drinking Water Act^-Consumer Confidence Report Rule Delivery Options FROM: Peter Grevatt, Ph.D. Director Office of Ground W^ter and Drinking Water (OGWDW) TO: Water Division Directors Regions I-X This memorandum clarifies requirements of the Consumer Confidence Report Rule associated with delivery of the CCR. Specifically, the U.S. Environmental Protection Agency is interpreting the current regulatory language to allow for the electronic delivery of CCRs if the delivery will meet the regulatory requirement to "mail or otherwise directly deliver." The attachment to this memorandum describes the approaches and methods for electronic delivery that are consistent with the current regulatory requirements and presents important considerations that primacy agencies and community water systems should evaluate before pursuing electronic delivery. The EPA Regions should share this information with their primacy agencies and, where the EPA is directly implementing the program, provide the attachment to community water systems. Background The Consumer Confidence Report, or CCR, is an annual water quality report that the Safe Drinking Water Act requires a community water system to provide to its customers. Among other things, the, report lists the regulated contaminants found in the drinking water, as well as health effects information related to violations of the drinking water standards. All CWSs must deliver to their customers annual reports on the quality of water delivered by the system and characterize the risks (if any) from exposure to contaminants detected in the drinking water in an accurate and understandable manner. All CWSs are required to mail or otherwise directly deliver these reports. The Governor of a state, the Governor's designee or Tribal Leader can waive the mailing requirement for CWSs serving fewer than 10,000 persons and allow their reports to be provided by other means specified in the regulation. During the development of the EPA's Retrospective Review Plan in response to Executive Order 13563 in 2011, stakeholders noted that there has been an increase in the number and type of communication tools available since 1998 when the CCR Rule was promulgated. Water systems asked whether the current rule allows electronic delivery of CCRs instead of mailing through the post office, which could reduce mailing fees and at the same time improve readership of CCRs. In October 2011, the EPA began a retrospective review of the CCR Rule to look for opportunities to improve the effectiveness of communicating drinking water information to the public, while lowering the burden on CWSs and primacy agencies by taking advantage of these new forms of communication. To support this review, the Internet Address (URL) • hRpV/Www.epa.gov Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper ------- Office of Ground Water and Drinking Water convened an EPA workgroup to evaluate stakeholder input, held stakeholder outreach meetings and analyzed available information on CCR delivery. CCR Rule Delivery Options The CCR Rule provides that each CWS must "mail or otherwise directly deliver" one copy of the report to each customer, 40 CFR 14l,lS5(a). Each CWS 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. As the rule provides in §141.155(b), 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. Over the last 15 years, there has been a great increase in the communication tools available to CWSs to deliver CCRs to their customers. Specifically, electronic delivery of the CCR is an approach that can promote the open exchange of information between CWSs and consumers consistent with Congressional intent and the 1998 rule. The EPA interprets the existing rule language "mail or otherwise directly deliver" to allow a variety of forms of delivery of the CCR, including electronic, so long as the CWS is providing the report directly to each customer. However, we believe that there are also some forms of communication that would not be consistent with the requirement to "directly deliver" the CCR and, as a result, would not be consistent with current CCR Rule requirements. An analysis of some electronic delivery methods using current technology is discussed below and in the attachment to this memorandum. Another indication that electronic delivery is in alignment with the existing CCR Rule comes from the Conference Report for the \ 996 SDWA amendments (a joint statement from the House and Senate about the bill). The Report states Congressional intent that the EPA may allow the CCR requirement "to be satisfied by a means other than postal delivery, such as personal delivery or electronic mail, if the Administrator determines that the alternative means will provide equivalent notice to individual customers."1 This statement confirms the reading of both the SDWA statute and CCR regulations that "mail" and "directly deliver" is not limited to post office or hand delivery. Electronic Delivery The EPA's CCR Rule Retrospective Review evaluated several electronic delivery methods and discusses in the attachment a framework for electronic delivery methods that meet existing CCR Rule requirements. The EPA has identified two different approaches allowable under the current rule that a CWS could use in providing electronic delivery of CCRs to its bill-paying customers: 1) paper CCR delivery with a customer option to request an electronic CCR, or 2) electronic CCR delivery with a customer option to request a paper CCR. CWSs should consider a combination of delivery methods (described in the memorandum's attachment) for their CCRs based on available technology and the preferences of their customer base. The attachment to this memorandum provides important considerations for CWSs that choose to implement CCR electronic delivery. The EPA recommends that CWSs provide options for their customers that are cost-effective and practicable for the CWS, as well as convenient and understandable for their customers. Because this is a new and rapidly changing environment, the EPA recommends that primacy agencies reach out to their CWSs and provide assistance to ensure that methods of electronic delivery being considered by CWSs meet CCR Rule requirements. Joint Explanatory Statement of the Committee on Conference, Safe Drinking Water Act Amendments of 1996, S. Rep, No. 104-192(1996), at 4. ------- As noted above, the existing rule language requires that each CWS mail or directly deliver the CCR. This language poses some limitations on use of electronic delivery options. Some of these limitations are discussed here, as well as in the attachment. 1. Electronic delivery must provide the CCR in a manner that is "direct." The EPA interprets this rule requirement to mean that CWSs can use paper or electronic communication (e.g., water bill) with URLs to meet their CCR requirement if the URL provides a direct link to the CCR, and if the communication prominently displays the URL and a notice explaining the nature of the link. In addition, the link must take the customer to the entire CCR so that the customer does not have to navigate to another webpage to find any required CCR content. 2. Use of social media (e.g., Twitter or Facebook) directed at bill-paying customers does not meet the requirement to "directly deliver" since these are membership Internet outlets and would require a customer to join the website to read their CCR. 3. The use of automated phone calls (e.g., emergency telephone notification systems) to distribute CCRs is not considered direct delivery, because the entire content of the CCR cannot be provided in the phone call. 4. If a CWS is aware of a customer's inability to receive a CCR by the chosen electronic means, it must provide the CCR by an alternative means allowed by the rule. Conclusion The current rule language provides flexibility for alternative forms of communication. As such, primacy agencies implementing the CCR Rule do not need to submit a primacy revision package to the EPA in order to enable electronic delivery of the CCR. The EPA may revise this memorandum at a future date based on implementation challenges and successes of electronic delivery. OGWDW will hold at least one informational webinar on electronic delivery of the CCR for primacy agencies and CWSs. If you have additional questions about this memorandum, please contact Mindy Eisenberg, Chief of the Protection Branch at 202-566-1290 or Adrienne Harris at 202-250-8793. Attachments: 1. Consumer Confidence Report Delivery Options and Considerations cc: Jim Taft, ASDWA Ann Codrington, DWPD Regional Drinking Water Branch Chiefs Carrie Wehling, OGC Edward Messina, OECA Mark Pollins, OECA ------- ATTACHMENT CONSUMER CONFIDENCE REPORT DELIVERY OPTIONS AND CONSIDERATIONS The purpose of the Consumer Confidence Report (CCR) is to raise customers' awareness of where their drinking water comes from, the quality of their drinking water, what it takes to deliver water to their home and the importance of protecting drinking water sources. The CCR Rule requires each community water system (CWS) to mail or otherwise directly deliver one copy of its CCR to each customer annually. In response to inquiries from water systems, technical assistant providers and primacy agencies about electronic delivery of the CCR, the U.S. Environmental Protection Agency evaluated several electronic delivery methods to determine which forms meet existing CCR Rule requirements as part of its CCR Rule Retrospective Review which was completed in December 2012. This document provides an overview of electronic delivery implementation approaches and methods, and describes ways CWSs can approach electronic delivery of their CCRs to their bill- paying customers, if they so choose, and still meet current regulatory requirements. This document first discusses the different electronic delivery approaches and methods to "mail or otherwise directly deliver" the CCR. Then, it provides a review of additional CCR Rule elements that a CWS must still consider when implementing electronic delivery, such as a "good faith effort" to reach non-bill paying customers, multilingual requirements, small system delivery requirements and delivery certification. It is important to note that this document provides information, recommendations and interpretations of existing rule provisions. It is not a rule and does not add to or replace any existing CCR Rule requirements. It also does not supersede any additional state or tribal primacy requirements for content or delivery of CCRs. CCR Delivery Options and Considerations Attachment ------- CCR DELIVERY METHODS UNDER EXISTING RULE The CCR Rule Retrospective Review revealed a variety of forms of communication available for delivery of the CCR, in addition to paper copies. At the same time, the EPA found some forms of communication were not consistent with the regulatory requirement to "mail or otherwise directly deliver" the CCR and, as a result, would not be consistent with current CCR Rule requirements (see section below). The table below provides a summary of CCR delivery methods that meet existing rule language to "mail or otherwise directly deliver," including electronic, so long as the system is providing the report directly to each customer. CWSs should consider a combination of delivery methods for their CCRs based on available technology and with consideration of the demographic and technology limitations of their customer bases. The methods below take into account future development of new technologies. Each method listed in Table 1 should be considered by the CWS in consultation with its primacy agency in order to ensure that it directly delivers the CCR to its bill-paying customers. Examples of the electronic delivery methods can be found in the Appendix. CCR Delivery Options and Considerations Attachment ------- Table 1. CCR Delivery Methods for Bill-Paying Customers CCR DELIVERY METHOD METHOD DESCRIPTION Mail - paper copy CWS mails a paper copy of the CCR to each bill-paying customer. Mail - notification that CCR is available on website via a direct URL CWS mails to each bill-paying customer a notification that the CCR is available and provides a direct URL to the CCR on a publicly available site on the Internet where it can be viewed. A URL that navigates to a webpage that requires a customer to search for the CCR or enter other information does not meet the "directly deliver" requirement. 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. For an example, see Figure 1 in the Appendix. Email - direct URL to CCR1 CWS emails to each bill-paying customer a notification that the CCR is available and provides a direct URL to the CCR on a publicly available site on the Internet. A URL that navigates to a webpage that requires a customer to search for the CCR or enter other information does not meet the "directly deliver" requirement. For an example, see Figure 2 in the Appendix. Email - CCR sent as an attachment to the email1 CWS emails the CCR as an electronic file email attachment (e.g., portable document format (PDF)). For an example, see Figure 3 in the Appendix. Email - CCR sent as an embedded image in an email1 CWS emails the CCR text and tables inserted into the body of an email (not as an attachment.) For an example, see Figure 4 in the Appendix. Additional electronic delivery that meets "otherwise directly deliver" requirement2 CWS delivers CCR through a method that "otherwise directly delivers" to each bill-paying customer and in coordination with the primacy agency. lrThis method may only be used for customers when a CWS has a valid email address to deliver the CCR electronically. /•) This category is intended to encompass methods or technologies not included above. CWSs and primacy agencies considering new methods or technologies should consult with the EPA to ensure it meets the intent of "otherwise directly deliver." CCR Delivery Options and Considerations Attachment ------- "Directly Deliver" Requirements The EPA interprets the existing rule language so that three elements must be met in order to use electronic delivery to comply with the requirement to "directly deliver" the CCR. 1. Electronic delivery must provide the CCR in a manner that is "direct." The EPA interprets this rule requirement to mean that CWSs can use separate mailings, such as utility bills with a URL, to meet their CCR requirement if the URL provides a direct link to the CCR and if the communication prominently displays the URL and a notice explaining the nature of the link (see the Appendix for examples.) 2. If a CWS is aware of a customer's inability to receive a CCR by the chosen electronic method, it must provide the CCR by an alternative method allowed by the rule. 3. A CWS must prominently display a message and the direct URL in all mail notifications of CCR availability. Examples of how the message could be prominently displayed can be found in the Appendix. Methods That Do Not Meet Existing CCR Rule Requirements The EPA also identified delivery methods that do not meet existing CCR Rule requirements. 1. A URL that does not take the customer to the entire CCR but requires navigation to another webpage(s) to find any required CCR content (e.g., a zipcode search mechanism or webpage with multiple links to view required information) is not an acceptable form of direct delivery. 2. Use of social media (e.g., Twitter or Facebook) directed at bill-paying customers does not meet the requirement to "directly deliver" since these are membership Internet outlets and would require a customer to join the website to read their CCR. 3. The use of automated phone calls (e.g., emergency telephone notification systems) to distribute CCRs is not considered direct delivery, because the entire content of the CCR cannot be provided in the phone call. Important Considerations There are several important considerations that a CWS should evaluate when choosing to deliver CCRs electronically. This list highlights electronic delivery considerations identified as a part of the EPA's CCR Rule Retrospective Review but it is not an exhaustive list: • A CWS needs to ensure delivery to every bill-paying customer, which may require a combination of paper and/or electronic delivery in a service area. For example, a CWS may provide the CCR through an email to electronic bill-paying customers but include a mail notification with a direct URL to customers who receive paper bills or mail those customers a paper CCR. • If a CWS sends the CCR via email and it receives a message that the email failed to reach the customer (i.e., it bounced back) the CWS should send the CCR by an allowable alternative means. In this instance, different than having a paper CCR returned, the CWS has an alternate method of contacting the customer (i.e., a physical address) to ensure that the CCR is delivered. CCR Delivery Options and Considerations A ttachment 4 ------- CWSs should assess their customer bases for specified electronic delivery method capabilities prior to beginning electronic delivery. A CWS should determine which customers do not have access to the Internet and continue delivering a paper CCR. Before providing electronic delivery of CCRs to customers, a CWS should conduct public outreach to provide advance notification of the change in delivery approach. The CWS could send a notification to customers of the upcoming change in delivery method and provide an opportunity to contact the CWS with any concerns or a chance to register a preferred delivery approach (see Appendix Figure 5 for an example.) A CWS mailing a direct URL notification should also consider include a check box on every water bill, similar to a change of address or pay by credit card, in which a customer can elect to receive a paper CCR (see Appendix Figure 1 for an example.) When using a mail notification method with a direct URL, a CWS should display the direct URL on every mailing (e.g., quarterly water bill.) This could increase the customers' access to the information and knowledge of the electronic delivery option if they currently receive a paper CCR. • CWSs sending a direct URL notification or email attachment should include a short message to encourage readership of the CCR. Examples of appropriate messages can be found in the Appendix. • Electronic bill and auto-pay customers may not receive and/or may ignore their billing statements, as found during a state electronic delivery pilot study. Therefore, to ensure that the customer is aware of how to obtain their CCR a CWS should send a dedicated email (with a CCR-related subject line) to inform their customers of the availability of the CCR each year (see Appendix Figure 2 for an example.) • CWSs should manage their email databases regularly to ensure correct emails are being used for electronic delivery to their customers. • Once a customer requests a paper or electronic CCR for one year, a CWS should keep record of this delivery preference for future CCR deliveries. • A CWS may want to prepare its CCR in a format (e.g., pdf version) that can be delivered both electronically and on paper. This decreases the burden of creating two versions for delivery. The format could also provide links to other, non-required information on the Internet that all consumers can visit for more information. These considerations are not required by the existing CCR Rule language but are important in continually promoting consumer awareness and confidence. CCR Delivery Options and Considerations Attachment ------- Delivery Method Advantages and Limitations To further assist CWSs in evaluating which combination of CCR delivery methods is best for their communities, Tables 2 and 3 offer advantages and limitations of each CCR delivery method. These tables are not exhaustive, but rather offer a broad summary of considerations. The last delivery method listed in Table 1, additional electronic delivery that meets the "otherwise directly deliver" requirement, is intended to encompass future and emerging technologies. A CWS should work with its primacy agency and the EPA to determine limitations and advantages of this method. CCR Delivery Options and Considerations Attachment ------- Table 2. Advantages Matrix of CCR Delivery Methods CCR DELIVERY METHODS ADVANTAGES* Customers may have access to more information beyond what is required in the CCR because they are already on the Internet. CWS does not have to invest in new software, additional staff training or other new logistical needs for delivery. CWS has potential printing and mailing cost CWS with e-billing systems can use existing database and other resources. Customer can view or receive CCR with limited or no Internet access. Customer expects the CCR to be delivered by this method based on CCR delivery history. Customer does not have to share a personal email account. CCR is directly available and customer does not have to take a second step to view (e.g., go to website or click link.) Method consumes less of limited natural resources, including paper for production. CWS may be able to use the same method to reach bill-paying and non-bill-paying customers. Method assured to reach customer because it uses a reliable postal address. Use of e-bill customer email addresses to deliver CCR (reduction of inaccurate emails.) Advantages are not in any ranked order. Mail- Notification that CCR is available via direct URL CCR sent as attachment CCR sent as an embedded CCR Delivery Options and Considerations A ttachment 1 ------- Table 3. Limitations Matrix of CCR Delivery Methods CCR DELIVERY METHODS LIMITATIONS* CWS must dedicate staff to manage more than one delivery method, including collecting and updating email addresses. CWS may have to invest in new software and train staff. CWS incurs printing and mailing costs. CWS needs Internet access and adequate bandwidth to distribute large numbers of emails at once. Customer may not receive CCR by email due to lack of software compatibility, spam filtering, firewalls or file size limitations. Customer may be reluctant to download an attachment or click/visit a URL to an unfamiliar website. Customer may be reluctant to open email from an unfamiliar email address. Customer may be reluctant to share personal email address. Responsibility of customer to take the next step to view the CCR (e.g., access website, click URL or download attachment.) Customer needs Internet access to view or receive CCR. Method consumes natural resources, including paper for production. Method uses email addresses, which are less reliable than postal addresses (unless part of e-billing system.) * Limitations are not in any ranked order. Notification that CCR is available via direct URL Email- Email - Email - CCR sent as CCR sent as an an embedded attachment image CCR Delivery Options and Considerations Attachment ------- ELECTRONIC CCR DELIVERY APPROACHES Once a CWS has identified appropriate methods by which it will deliver the CCR that include electronic delivery, the CWS next considers the approach in which to deliver CCRs. With stakeholder input, the EPA has identified two approaches that meet existing CCR Rule requirements to "mail or otherwise directly deliver." The two approaches are: 1) Paper CCR delivery with a customer option to request an electronic CCR, or 2) Electronic CCR delivery with a customer option to request a paper CCR. If a CWS chooses to pursue electronic delivery of CCRs, 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 from paper delivery to an electronic delivery approach. A CWS is required to deliver the CCR to all customers by July 1. Because this is a rapidly changing environment, 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 CWSs meet CCR Rule requirements. Approach #1: Paper CCR Delivery with Customer Option to Request an Electronic CCR One approach to introducing an electronic delivery program is to provide paper CCR delivery but allow customers to choose to receive electronic delivery of CCRs. A CWS would notify customers of the availability of electronic delivery of the CCR in advance of mailing paper copies. This notification could be performed through a variety of mechanisms including through the water bill, separate mailing or CWS's website. Customers would express to the CWS their preference to receive their CCR through electronic delivery. The CWS would catalog its customers' delivery preferences and deliver the CCR according to their specified preference. The CWS has a choice of any of the electronic delivery methods or a combination listed in Table 1. Customers who do not identify a preference for electronic delivery would automatically receive a paper CCR. This approach benefits the customer and CWS by ensuring that customers continue to receive a paper CCR unless they indicate an interest in receiving it electronically. This approach may require additional CWS staff resources to coordinate the logistics of tracking customer delivery preferences. The agency sees this approach as a gradual transition to electronic delivery over time as more customers become comfortable with the electronic delivery methods. This approach offers a CWS the most assurance that they are meeting the intent of the rule as only those customers who have expressed an interest in receiving an electronic CCR will receive one in this manner. CCR Delivery Options and Considerations Attachment ------- Approach #2: Electronic Delivery with Customer Option to Request a Paper CCR A second approach for introducing a CCR electronic delivery program is to provide CCRs electronically to customers with an option for them to request a paper CCR. Under this approach, the CWS establishes an electronic delivery method(s) considering its customers' needs and technology capabilities. These methods could be any of the methods or a combination discussed in Table 1. The CWS would directly deliver the CCR electronically to all customers and would also include the option to all bill-paying customers to request paper CCR delivery. The CWS would provide a paper copy of the CCR to those customers who request a paper CCR. The CWS would also provide a paper copy of the CCR to all known customers who lack access to the Internet. This approach may lead to a higher usage of electronic delivery of the CCR to customers. CWSs using this approach may limit the paper delivery of the CCR only to those customers who prefer that method, but still must directly deliver the CCR to all customers. The burden falls to the customers to request a paper CCR if they prefer paper delivery and/or are unable to participate in electronic delivery. Electronic delivery as a main approach requires a CWS to respond to requests for paper CCRs and mail paper CCRs to customers unable to access electronic CCRs or who prefer paper. For example, a CWS may receive several customer requests for a paper CCR and also have to mail CCRs to a rural housing community that does not have Internet access. A CWS using this approach must fully implement the approach including providing paper CCRs to those who request and those identified as unable to receive an electronic CCR. Using this approach, CWSs must ensure that they are still directly delivering the CCR to all their bill- paying customers. ADDITIONAL RULE ELEMENTS "Good Faith Effort" to Reach Consumers Who Do Not Receive a Water Bill (40 C.F.R. § 141.155(b)) The CCR is meant to serve as a tool to open dialogue between the CWS and its customers about water quality and encourage customers to be more active in the decision making process that affects their health. To ensure that all consumers know about the quality of their drinking water, the CCR Rule requires CWSs to make a "good faith effort" to reach consumers who do not receive a water bill. 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. The delivery methods and approaches discussed throughout this document are not intended to limit the options available to CWSs in meeting this requirement, but instead to present additional opportunities to expand public outreach. The delivery methods and approaches for bill-paying customers may also serve to reach consumers who do not receive a water bill. CCR Delivery Options and Considerations A ttachment 10 ------- A CWS or municipality website can offer a sign-up for electronic delivery to the public, including consumers who do not receive a water bill. Where allowed by the primacy agency, CWSs should also consider increasing outreach and public participation by taking advantage of advancements in new technology, such as increased accessibility of email, mobile phone applications and the use of blogs or social media on the Internet. CWSs opting to use social media will have to promote the availability of these resources and dedicate staff to keep these active. Once established, CWSs would be able to reach many consumers in a single post to social media. Electronic community newsletters and text alerts have become widespread and could offer an easy way to alert consumers that the CCR is available. CWSs should stay apprised of new opportunities to reach all of their consumers as technology advances and consult with their primacy agencies when choosing a mix of appropriate methods. Multilingual Requirement (40 C.F.R. § 141.153 (h) (3)) The CCR is an important communication tool, and a CWS needs to ensure it reaches non-English speaking populations who may comprise a significant portion of its customer base as well. As determined by the primacy agency, CWSs serving communities with a large portion of non- English speaking residents must provide a CCR that contains information in the appropriate language(s) regarding the importance of the report, or a phone number or address in the report where residents may contact them to obtain a translated copy of the CCR or assistance in the appropriate language. The electronic delivery methods and approaches discussed in this document do not alter the CCR content requirements including any required translated statements. CWSs, when providing electronic delivery, should consider adding any translated statements to their electronic delivery methods, including emails and websites. CWSs should also consider including translated contact information in their electronic messaging so that non- English speaking residents may contact the CWS to obtain a translated CCR or receive assistance in the appropriate language. For example, the state of Washington provides more than two dozen translations for informational statements to use on CCRs at the following website: http ://www. doh. wa. gov/CommunityandEnvironment/DrinkingWater/DrinkingWaterEmergencie s/PublicNotification/TranslationsforPublicNotification.aspx. Small System Waiver of Mailing Requirements (40 C.F.R. § 141.155(g)) The delivery methods and approaches discussed in this document do not replace primacy agency regulations regarding the waiving of the requirement to "mail or otherwise directly deliver" the CCR for small CWSs. The current CCR Rule allows the Governor of a state or his/her designee, or a Tribal Leader to waive the CCR "mail or otherwise directly deliver" requirement for CWSs serving fewer than 10,000 persons. Some primacy agencies have made these waivers automatic by incorporating waiver language into state regulations. Others require small CWSs to request waivers. CWSs serving between 501 and 9,999 persons may publish their CCR in a local newspaper if permitted by state regulation or granted a CCR waiver and inform their customers that a CCR report will not be mailed and make reports available upon request. CWSs serving 500 CCR Delivery Options and Considerations A ttachment 11 ------- or fewer persons, if permitted by state regulation or granted a CCR waiver, must provide notice to their customers annually, by door to door delivery or posting notification in an appropriate location that a CCR is available upon request. If allowed by the primacy agency, CWSs serving fewer than 10,000 persons that do not wish to take advantage of a mailing waiver (meaning they are choosing to mail paper copies) may wish to consider using a form of electronic delivery as described above. For example, manufactured housing communities and military bases with known populations may be able to reach all persons served via email. Delivery Certification (40 C.F.R. § 141.155(c)) The CCR Rule requires a CWS to certify that the report 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 within three months of CCR delivery. Many primacy agencies have a certification form template for CWSs to check off the applicable methods used to distribute the CCR. The certification may be submitted to the primacy agency in a variety of ways, including electronically. The primacy agency should ensure that, especially as new communication methods are used, CCRs continue to be "directly delivered" to customers in a manner that is accessible and convenient. Therefore, primacy agencies should amend their certification forms to list allowable combinations of paper and electronic delivery methods by including a space for a direct URL address. Primacy agencies should also verify the URL listed by the CWS to ensure it is a direct URL to meet the requirements to directly deliver the CCR to customers. A CWS may certify to the primacy agency that it has directly delivered the CCR to all of its customers if the CCR has been mailed or otherwise directly delivered according to the methods described in Table 1 by July 1, annually. CCR Delivery Options and Considerations A ttachment 12 ------- APPENDIX. SAMPLE ELECTRONIC CCR MESSAGES ------- [Brackets] indicate information that must be changed to system specific information. [Corchetes] la informacion contenida dentro de los corchetes debe ser sustituida por informacion especifica al sistema/compania. Sample Message 1 - Mail notification (e.g., water bill insert or statement on a water bill) - violations In [2011], [Anytown Water] detected [53] contaminants in the drinking water and [5] of them were above the EPA accepted level for drinking water. Please go to [www.anytownwater.org/2011waterreport.pdf] to view your [2011] annual water quality report and learn more about your drinking water. This report contains important information about the source and quality of your drinking water. For a translation of the water quality report or to speak with someone about the report please call [(555) 555-5555]. If you would like a paper copy of the [2011] Annual Water Quality Report mailed to your home, please call [(555) 555-5555]. Spanish Translation: Durante el ano [2011] [la compania de agua Anytown] detecto [53] contaminantes regulados en el agua potable. [Cinco] de los contaminantes detectados en el agua potable reflejaron niveles que exceden los 11 mites legates establecidos por la EPA. Para acceder al mas reciente reporte anual de calidad de agua y para mas informacion acerca de su agua potable puede visitar [www.anvtownwater.org/2011waterreport.pdf\. El reporte anual contiene valiosa informacion acerca de las fuentes de abasto y calidad de su agua potable. Para obtener una traduccion del reporte de calidad de agua o para preguntas acerca del reporte por favor comuniquese al [(555) 555-5555]. Si desea obtener por correo una cop/a cte su mas reciente reporte de calidad de agua puede solicitar la misma llamando al [(555) 555-5555]. Sample Message 2 - Email direct URL to CCR - no violations Email subject line: IMPORTANT MESSAGE: Your [Anytown Water 2011] Water Quality Report Is Now Available!! Dear [Mr. ABC], 1 (Appendix ------- Your [2011] annual water quality report is now available! In [2011], [Anytown Water] detected [65] contaminants in the drinking water. However, these contaminants were at allowable levels and no health based violations were reported. Please go to \www.anytownwater.org/2011 waterreport.pdf] to view your [2011] annual water quality report and learn more about your drinking water. This report contains important information about the source and quality of your drinking water. For a translation of the water quality report or to speak with someone about the report please call [(555) 555-5555]. If you would like a paper copy of the [2011] Annual Water Quality Report mailed to your home, please call [(555) 555-5555]. For more information about how [Anytown Water] maintains the safety of your drinking water and to view previous year's reports go to [www.anytownwater.org]. [Anytown Water Department] Spanish Translation: Estimado [Sr./Sra. ABC], El mas reciente reporte annual de calidad de su agua potable ya esta disponible! Durante el ano [2011 la compania de agua Anytown] detecto [65] contaminantes regulados en el agua potable. Los contaminates detectados estan dentro de los niveles permitidos por la EPA y por lo tanto no se reporto ninguna violation. Para acceder el mas reciente reporte anual de calidad de agua y para mas information acerca de su agua potable puede visitar [www.anytownwater.org/2011waterreport.pdf1. El reporte anual contiene valiosa information acerca de las fuentes de abasto y calidad de su agua potable. Para obtener una traduccion del reporte de calidad de agua o para preguntas acerca del reporte por favor comuniquese al [(555) 555-5555]. Si desea obtener por correo una cop/a cte su mas reciente reporte de calidad de agua puede solititar la misma comunicandose al [(555) 555-5555]. Sample Message 3 - Email - CCR sent as an attachment to the email - violations Email subject line: IMPORTANT MESSAGE: Your [Anytown Water 2011] Water Quality Report Is Now Available!! 2|Appendix ------- Dear [Mr. ABC], Please download the attached [2011] drinking water quality report. In [2011], [Anytown Water] detected [7] contaminants in the drinking water and [5] of the contaminants were above the EPA accepted level for drinking water. You can also view your annual water quality report at \www.anvtownwater.ora/2011waterreport.pdf\ and learn more about your drinking water. This report contains important information about the source and quality of your drinking water. For a translation of the water quality report or to speak with someone about the report please call [(555) 555-5555]. If you would like a paper copy of the [2011] Annual Water Quality Report mailed to your home, please call [(555) 555-5555]. For more information about how [Anytown Water] maintains the safety of your drinking water and to view previous year's reports go to [www.anytownwater.org]. [Anytown Water Department] Spanish Translation: Estimado [Sr./Sra. ABC], Este mensaje electronlco contlene su mas reclente reporte de calldad de agua potable. Durante el ano [2011] [la compania de agua Anytown] detecto [7] contaminantes regulados en el agua potable. [Cinco] de los contaminantes detectados en el agua potable reflejaron nlveles que exceden los 11 mites legates establecldos porla EPA. Para acceder al mas reciente reporte anual de calidad de agua y para mas informacion acerca de su agua potable puede vlsltar \www.anytownwater.org/2011waterreport.pdf\. El reporte anual contiene valiosa Informacion acerca de las fuentes de abasto y calldad de su agua potable. Para obtener una traducclon del reporte de calldad de agua o para preguntas acerca del reporte por favor comuniquese al [(555) 555-5555]. SI desea obtener por correo una cop/a cte su mas reclente reporte de calldad de agua puede solicitar la misma comunicandose al [(555) 555-5555]. Sample Message 4 - Email - CCR sent as an embedded image in an email - violations 3|Appendix ------- Email subject line: IMPORTANT MESSAGE: Your [Anytown Water 2011] Water Quality Report Is Now Available!! Dear [Mr. ABC], Please review the enclosed [2011] [Anytown Water] annual water quality report. In [2011], [Anytown Water] detected [53] contaminants in the drinking water and [5] of the contaminants were above the EPA accepted level for drinking water. You may also view your annual water quality report at \www.anytownwater.ora/2011waterreport.pdf\ and learn more about your drinking water. This report contains important information about the source and quality of your drinking water. For a translation of the water quality report or to speak with someone about the report please call [(555) 555-5555]. If you would like a paper copy of the [2011] Annual Water Quality Report mailed to your home, please call [(555) 555-5555]. For more information about how [Anytown Water] maintains the safety of your drinking water and to view previous year's reports go to [www.anytownwater.org]. [Anytown Water Department] Spanish Translation: Estimado [Sr./Sra. ABC], Adjunto a este mensaje electronico se encuentra su mas reclente reporte de calldad de agua potable. Durante el ano [2011] [la compania de agua Anytown] detecto [53] contaminantes regulados en el agua potable. [Cinco] de los contaminantes detectados en el agua potable reflejaron niveles que exceden los 11 mites legates establecidos porla EPA. Para acceder al mas reclente reporte anual de calidad de agua y para mas informacion acerca de su agua potable puede visitar \www.anvtownwater.org/2011waterreport.pdf\. El reporte anual contiene valiosa informacion acerca de las fuentes de abasto y calidad de su agua potable. Para obtener una traduccion del reporte de calidad de agua o para preguntas acerca del reporte por favor comuniquese al [(555) 555-5555]. Si desea obtener por correo una cop/a cte su mas reclente reporte de calidad de agua puede solicitar la misma comunicandose al [(555) 555-5555]. 4|Appendix ------- Sample Message 5 - Outreach message on mail notification COMING SOON: Starting [July 1, 2012] you will be able to view the [Anytown Water] annual water quality report on-line at [www.anytownwater.org/2011waterreport.pdf]. This report contains important information about the source and quality of your drinking water. Please call [(555) 555-5555] if you would like a paper report delivered to your home. Spanish Translation: Pronto Disponible: A partir del[1 de Julio del 2012] usted podra accedera traves del internet el reporte anual de calidad de agua potable de [la compania de agua Anytown]. El reporte estara disponible en [www.anytownwater.org/2011waterreport.pdf]. El reporte contiene valiosa informacion acerca de las fuentes de abasto y calidad de su agua potable. Si desea obtener por correo una cop/a cte su mas reciente reporte de calidad de agua puede solicitar la misma comunicandose al [(555) 555-5555]. p e n d i x ------- Figure 1. Sample utility bill with the direct URL to the CCR and check box to opt out of electronic delivery and receive a paper copy of the CCR (items outlined in yellow). QUARTERLY BILL Hater —\*> 8888 Electric Avenue Anytown, USA Bill Date: 06/15/12 Payment Due Date: 07/14/12 00000-258-6666 Amount Due Amount Due If Received After 07/14/12 Amount Enclosed $83.53 $86.10 $ Account Number: Service Address: 00000-258-6666 123 Main St. 4173 22 1 John Doe 123 Main St Anytown, USA iiiiiiiiiiiiiiliiliililliilinHil Anytown Water 8888 Electric Avenue Anytown, USA '•" M'uMI'-MiI'M'l l-i'l I'l I- Please check the box if you would prefer a paper copy of your annual water quality report I delivered to your home. Por favor, haga una marca en el encasillado si prefiere recibir a traves del correo una copia de su iim.. -~"jpnte reporte de calidad de agua. QUARTERLY BILL Kt i UHN TOP PORTION WITH PAYMENT John Doe Water 00000-258-6666 METER READINGS WATER SEWER (BASED ON ACTUAL WATER CONSUMPTION) www.anytownwater.org Correspondence & Office 8888 Electric Avenue Anytown, USA Office Hours 8:00am-4:00pm, M-F Phone & Hours (111)555-5555,711 TTY 8:00am - 6:00pm, M-F After Hours / Emergencies (111)555-5554 Annual Water QuaMf' r.cuort In 2011, Anyti",,i Water detected 53 contaminants in the u.'^king water and 5 of them • .ere above the EPA accepted level for drinking wate, Please go to ww .anytownwater.org/2011waterreport.pdf to view your 20,' annual watr quality report and learn more about your drinking water. This rfc,Nort cc .tains important information about the source and quality of yourdrir, 'ing ' ater. For a translation of the water quality report or to speak with somec >e about the report please call (555) 555-5555. If you would like a paper cop of the 2011 Annual Water Quality Report mailed to your home, please call (555) 555-5555. Durante el ano 2011 la compania de agua Anytown detecto 53 contaminantes regulados en el agua potable. Cinco de los contaminantes detectados en el agua potable reflejaron niveles que exceden los limites legales establecidos por la EPA. Para acceder al mas reciente reporte >nual de calidad de agua y para mas informacion acerca de su agua P table puede visitarwww.anytownwater.org/2011waterreport.pdf. E' re|- ^rte anual contiene valiosa informacion acerca de las fuentes de ai" jsto y cah '^)d de su agua potable. Para obtener una traduccion del repor'j de calidad v'^ agua o para preguntas acerca del reporte por favor co ..uniquese al (555) 5b^ ^555. Si desea obtener a traves del correo una r ,pia de su mas recientb ^norte de calidad de agua puede solir1* .. ia misma comunicandose al (bo^) ^^ SERVICE ADDRESS 123 MaJH St. SERVICETYPE TOWNHOUSE 03/17/12 06/11/12 06/15/12 341 349 CHARGES (SEE REVERSE FOR DESCRIPTIONS) WATER RATES - ESTABLISHED BY ANYTOWN WATER SERVICE CHARGE 8.35 WATER USAGE CHARGE 8X2.16 17.28 SUBTOTALANYTOWN WATER $25.63 SEWER RATES - ESTABLISHED BYHEALTHY COUNTY GOVERNMENT SEWER BASE CHARGE 5.50 SEWER USAGE CHARGE 8 X 6.55 52.40 SUBTOTAL HEALTHY COUNTY TOTAL AMOUNT DUE $57.90 $83.53 I 6 | Appendix ,^ rtiiyiown Water annual water quality report is available on-line at www.anytownwater.org/2011waterreport.pai. Anytown Water visitando la pagina de internet www.anytownwater.org/2011waterreport.pdf. ------- Figure 2. Sample of an email with a direct URL sent to bill-paying customers, including auto-pay and electronic bill-payers. Records' £| New- jil Reply .^Forward- B * }>•" jij Display Q - More* ReportSPAM Report Flushing IMPORTANT MESSAGE: Your Anytown Water 2011 Water Quality Report Is Now Available!! CCRRetiospectiveReview tc CCRRetrospectiveReview Dear Mr. ABC, Your 2011 annual water quality report is now available! In 2011, Anytown Water detected 65 contaminants in the drinking water. However, these contaminants were at allowable levels and no health based violations were reported. Please go to www.anytownwater.orQ/2011 waterreport.pdf _ to view your 2011 annual water quality report and learn more about your drinking water. This report contains important information about the source and quality of your drinking water. For a translation of the water quality report or to speak with someone about the report please call (555) 555-5555. If you would like a paper copy of the 2011 Annual Water Quality Report mailed to your home, please call (555) 555-5555. For more information about how Anytown Water maintains the safety of your drinking water and to view previous year's reports go to www.anytownwater.org. Anytown Water Department Spanish Translation: Estimado Sr./Sra. ABC, Su mas reciente reporte annual de calidad de agua potable ya se encuentra disponible! Durante el aho 2011 la compahia de agua Anytown detecto 65 contaminantes regulados en el agua potable. Los contaminates detectados estan dentro de los niveles permitidos por la EPA y por lo tanto no se reporto ninguna violacion a los estandares de salud publica. Para accede/" al mas reciente reporte anual de calidad de agua y para mas informacion acerca de su agua potable puede visitar www.anytownwater.om/2011waterreport.pdf. El reporte anual contiene valiosa informacion acerca de las fuentes de abasto y calidad de su agua potable. Para obtener una traduccion del reporte de calidad de agua o para preguntas acerca del reporte por favor comuniquese al (555) 555-5555. Si desea obtener a traves del correo una cop/a de su mas reciente reporte de calidad de agua puede solicitar la misma comunicandose al (555) 555-5555. 7|Appendix ------- Figure 3. Sample of a CCR sent in an email to bill-paying customers as an attachment. Records- £) New- $) Reply- 4 Forward- Q- k- jj Display- Q- More- Report SPAM Report Phishing IMPORTANT MESSAGE: Your Anytown Water 2011 Water Quality Report Is Now Available!! CCRRelrospectiveReview ' CCRRetrospediveReview Dear Mr. ABC, Please download the attached 201 1 drinking water quality report. In 201 1 , Anytown Water detected 7 contaminants in the drinking water and 5 of the contaminants were above the EPA accepted level for drinking water. You can also view your annual water quality report at www. any town water, org/20 1 1 waterreport.pdf and learn more about your drinking water. This report contains important information about the source and quality of your drinking water. For a translation of the water quality report or to speak with someone about the report please call (555) 555-5555. If you would like a paper copy of the 2011 Annual Water Quality Report mailed to your home, please call (555) 555-5555. For more information about how Anytown Water maintains the safety of your drinking water and to view previous year's reports go to www.anytownwater.org. Anytown Water Department 2011 Anytown Water_Water Quality Report pdf Spanish Translation: Estimado Sr./Sra. ABC, Este mensaje electronico contiene su mas reciente reporte de calidad de agua potable. Durante el ano 2011 la companla de agua Anytown detecto 7 contaminates regulados en el agua potable. Cinco de los contaminantes detectados en el agua potable reflejaron niveles que exceden los limites legates establecidos por la EPA. Para acceder al mas reciente reporte anual de calidad de agua y para mas informacion acerca de su agua potable puede visitar www.anytownwater.om/2011waterreport.pdf ._ El reporte anual contiene valiosa informacion acerca de las fuentes de abasto y calidad de su agua potable. Para obtener una traduccion del reporte de calidad de agua o para preguntas acerca del reporte por favor comunlquese al (555) 555-5555. Si desea obtener a traves del correo una cop/a de su mas reciente reporte de calidad de agua puede solicitar la misma comunicandose al (555) 555-5555. 8|Appendix ------- Figure 4. Sample of a CCR emailed to bill-paying customers as an embedded image. ReconJs~ °D New- ^\ Reply* .^Forward Display <:,; •• More- ReportSPAM Report Flushing IMPORTANT MESSAGE: Your Anytown Water 2011 Water Quality Report Is Now Available!! CCRReuospectiveReview CCftRetrospectiveReview Dear Mr. ABC, Please review the enclosed 2011 Anytown Water annual water quality report. In 2011, Anytown Water detected 53 contaminants in the drinking water and 5 of the contaminants were above the EPA accepted level for drinking water. You may also view your annual water quality report at www.anytownwater.om/2011waterreport.pclf and learn more about your drinking water. This report contains important information about the source and quality of your drinking water. For a translation of the water quality report or to speak with someone about the report please call (555) 555-5555. If you would like a paper copy of the 2011 Annual Water Quality Report mailed to your home, please call (555) 555-5555. For more information about how Anytown Water maintains the safety of your drinking water and to view previous year's reports go to www.anytownwater.org. Anytown Water Department Spanish Translation: Estimado Sr./Sra. ABC, Adjunto a este mensaje electronico se encuentra su mas reciente reporte de calidad de agua potable. Durante el ano 2011 la compania de agua Anytown detecto 53 contaminantes regulados en el agua potable. Cinco de los contaminantes detectados en el agua potable reflejaron niveles que exceden los limites legates establecidos por la EPA. Para acceder al mas reciente reporte anual de calidad de agua y para mas informacion acerca de su agua potable puede visitar www.anytownwater. org/2011 waterreport.pdf . El reporte anual contiene valiosa informacion acerca de las fuentes de abasto y calidad de su agua potable. Para obtener una traducclon del reporte de calidad de agua o para preguntas acerca del reporte por favor comuniquese al (555) 555-5555. Si desea obtener a traves del correo una cop/a de su mas reciente reporte de calidad de agua puede solicitar la misma comunicandose al (555) 555-5555. Anytown Water I Water Quality Reporting Period: January 1, 2011 to December 31, 2011 INSIDE THIS ISSUE Meter Railing and Billing Statement Improvements Important Health Information p. 1 2011 Water Quality Testing RvMili* Information Anytown's Water Treatment Process How You Can Help Meter Reading and Billing Systems to Undergo Dramatic Improvements 9|Appendix ------- Figure 5. Sample utility bill announcing new electronic delivery program with direct URL to CCR and check box to opt out of electronic delivery and receive a paper copy of the CCR (items outlined in yellow). QUARTERLY BILL L „...,.. Water £8888 Electric Avenue pAnytown, USA Bill Date: 06/15/12 'Payment Due Date: 07/14/12 00000-258-6666 1 \Amount Due \Amount Due If Received After 07/14/12 \Amount Enclosed $83.53 $86.10 $ Account Number: Service Address: 00000-258-6666 123 Main St. 4473 221 John Doe M23MainSt EAnytown, USA V I tlNl^r* • ^i_ i < ..lllllllllllllllllllUllllllllllllltlllllllllllllllllllllllll Anytown Water 18888 Electric Avenue lAnytown, USA I'h'i'ml- Please check the box if you would prefer a paper copy of your annual water qualityi 11—i report delivered to your home. I—I Por favor, haga una marca en el encasillado si prefiere recibir a traves del correo I u. ° oopia de su mas reciente reporte de calidad de agua. I ri_tASfc RETURN TOP PORTION WITH PAYMENT QUARTERLY BILL fJohn Doe L Water www.anytownwater.org (Correspondence & Office 58888 Electric Avenue 'Anytown, USA SERVICE ADDRESS ,123 Main St. SERVICETYPE TOWNHOUSE Office Hours j8:00am-4:00pm, M-F (Phone & Hours '(555)555-5555,711 TTY '8:00am - 6:00pm, M-13 After Hou"'^ / Emergencies (555) Go5-5554 Annual Water Quality Report COMING SOON: Starting July 1, 2012 you will be able to view the Anytown Water annual water quality report on-line at www.anytownwater.org/2011waterreport. pdf. This report contains important information about the source and quality of your drinking water. Please call (555) 555-5555 if you would like a paper report delivered to your home. Apartirdel primero de julio del 2012 usted podra ver en linea el informe anual de la calidad de su agua producida', por Anytown Water visitando la pagina de internet www. anytownwater.org/2011waterreport.pdf. Por favor lla ne c.' (555) 555-5555 si desea una copia del informe. Holit>v Schedule Anytown '/Vater will be closed on Monday, May 28, in honr. of the Memorial Day ^oliday. To report an emergency on th~'. day, call (555) 555-5554 or 711 to, rArrnnwT WIJUHFR PREvi Put > flOCOUNl NUMBER BEADING DATE READING DATE BILLING DATE 00000-258-6666 03/17/12 06/11/12 06/15/12 ^ MFTFR RPflniWnQ PREVIOUS CONSUMPTION WIN! MCI tM HtAUHVlat) READING lonn nil S WATER SEWER (BASED ON ACTUAL WATER CONSUMPTION) 341 349 8\ 8 f CHARGES (SEE REVERSE FOR DESCRIPTIONS) WATER RATES - ESTABLISHED BY ANYTOWN WATER SERVICE CHARGE 8.35 WATER USAGE CHARGE 8X2.16 17.28 SUBTOTALANYTOWN WATER $25.63 SEWER RATES - ESTABLISHED BYHEALTHY COUNTY GOVERNMENT SEWER BASE CHARGE 5.50 SEWER USAGE CHARGE 8 X 6.55 52.40 SUBTOTAL HEALTHY COUNTY $57.90 TOTAL AMOUNT DUE $83.53 10 | Appendix ------- |