This is the Iowa Department of Natural Resources’ Water Supply Listserv for January 23, 2013, plus additional information added per March 15, 2013 Listserv.
Consumer Confidence Report – Electronic Delivery Options
As reported in the January 11th edition of the DNR Water Supply Listserv, EPA released a memorandum on January 3rd that clarifies the requirements of the Consumer Confidence Report (CCR) Rule associated with delivery of the CCR. EPA interprets “… 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.” EPA also held a webinar on January 17th to discuss the options now available as well as limitations to electronic delivery.
The CCR is compiled by July 1st each year for the previous calendar year by every community public water supply system (CWS) in the country. It is required to be mailed or otherwise directly delivered to those people who consume the water in a system – the regular customers who pay a water bill, as well as those people who receive the water but do not receive a water bill, such as apartment residents.
Because the use of Internet and email has expanded so much in our society since the CCR rules were written in 1996, EPA evaluated the rule to determine what types of electronic delivery would be allowed under the current rules. For some systems this is an important decision to provide them more capabilities in distributing their CCRs; for others, it will likely not change their practices at all. In Iowa, we will allow electronic notification as it is described in the memo for the CCR report for the 2012 calendar year. Some systems will soon be printing their 2012 CCR and beginning delivery, so it is important to get this information out as soon as possible. This year, the data and certification form that is normally provided by the DNR in March to each CWS will include the electronic delivery options on the certification form.
EPA recommends that each system consider a combination of delivery methods for its CCR, “… based upon available technology and with consideration of the demographic and technology limitations of its customer base.” Electronic delivery options are additional tools to be used, but it is likely that many CWS will still need to print and provide some copies of their CCR to their customers when so requested.
A. Draft Consumer Confidence Reports (CCRs) – New Format this Year
Draft Consumer Confidence Reports (CCRs) were mailed to all Community Public Water Supplies (CWS) today, Friday, March 15, 2013. This year, the Iowa Department of Natural Resources (DNR) is providing the draft CCR in a format that can be considered “ready”, or “mostly ready” to distribute. In some cases, the DNR does not have all the necessary information to provide a completed CCR, so more information is needed to complete the report. In all cases, the CWS should ensure the data is accurate and correct. If modifications are necessary, an electronic copy of the draft CCR can be sent to the CWS upon request.
These are potential updates that may be necessary:
- Corrective actions taken to address any violations assessed
- Contact information for the CWS
- Fluoride range if the CWS adds Fluoride
- Total organic carbon (TOC) reported as % removed
- Turbidity data (violations and results)
- The Running Annual Average (RAA) for TTHM and HAA5 may not be accurate if the CWS has multiple plants or if the CWS switched from Stage 1 to Stage 2 monitoring after January 1, 2012
- Cryptosporidium sampling per Long Term 2 Enhanced Surface Water Treatment Rule (LT2)
- Chlorine and Chloramine MRDL values will be provided using the data reported with the TCR sample results. These values should be compared to the daily MOR results and modified as appropriate
- Data collected as part of the Unregulated Contaminant Monitoring Rule 2 (only applies to a small number of CWSs participating in the EPA study; UCMR3 data is not included until next year)
As stated, an electronic copy will be sent upon request. Please submit your request to this e-mail address, firstname.lastname@example.org, and provide your CWS name and PWSID in the subject line. The draft CCR will be sent as a Word document, allowing changes and updates to be easily made if necessary.
If you have questions, contact the person listed in the letter accompanying the CCR data.
B. Electronic Delivery of the CCR
Electronic delivery of the CCR is now an acceptable method of delivery of the CCR. Listed below are the CCR E-Delivery Methods. We’d sent this article out in an earlier WS Listserv, but are repeating it today. The one new piece of information in the article below is that any URL that is created must remain active for 3 years.
1. Mail: paper copy
CWS mails a paper copy of the CCR to each bill-paying customer.
2. 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 the CCR 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 notification may be, but is not limited to, a water bill insert, a statement on the water bill, or a statement in a community newsletter.
3. Email: email a direct URL to the CCR to each customer
CWS emails a notification to each bill-paying customer that the CCR is available and provides a direct URL to the CCR on a public 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. This method may only be used for customers for whom the CWS has a valid email address.
4. Email: CCR sent as an attachment to the email
CWS emails the CCR as an electronic file email attachment (such as a portable document format or .pdf). This method may only be used for customers for whom the CWS has a valid email address.
5. Email: 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. This method may only be used for customers for whom the CWS has a valid email address.
6. Additional electronic delivery that meets “otherwise directly deliver” requirement
CWS delivers CCR through a method that “otherwise directly delivers” to each bill-paying customer and in coordination with IDNR. This category is intended to encompass new methods or technologies in the future that aren’t addressed in the first 5 categories.
“Directly Deliver” Requirements
Three elements must be met in order to use the electronic delivery to comply with the “directly deliver” requirement.
1. Electronic delivery must provide the CCR in a manner that is “direct.” A CWS can use separate mailings to meet its CCR requirement, such as utility bills with a printed URL, 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.
2. If a CWS is aware of a customer’s inability to receive a CCR by the chosen electronic method, the system 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 the CCR availability.
Methods that do not meet the CCR Delivery Requirements
1. A URL that does not take the customer to the entire CCR, but requires navigation to another webpage to find CCR content.
2. Use of social media directed at bill-paying customers, such as Facebook or Twitter, since those are membership Internet outlets and would require a customer to join the website to read the CCR. However, use of social media can be an appropriate additional ‘good faith’ distribution method.
3. Use of automated phone calls, such as the emergency telephone notification or bill payment systems, because the entire content of the CCR cannot be provided in the phone call.
These are some of the important considerations that a CWS must evaluate when choosing to deliver the CCR by electronic means.
1. A CWS needs to ensure delivery to every bill-paying customer, which may require a combination of paper and electronic delivery options.
2. If a CWS sends the CCR via email and it receives a message that the email failed to reach the customer (a bounce back note), the CWS should send the CCR by an allowable alternative means.
3. The CWS should conduct a public outreach to provide advance notification of the change in the delivery approach.
4. A CWS using a direct URL notification should consider a check box on the return portion of the water bill, similar to a change of address or pay by credit card, in which the customer can elect to receive a paper CCR. A notice on the bill with a phone number where a customer can call to receive a paper CCR is also a method to ensure that those people who don’t have computer access can still receive the CCR if they so choose.
5. The direct URL notification should be displayed in a typeface that is large and easily readable on the statement. A short, easy to type, direct link is best, such as www.yourCWS.com/ccr/2012.pdf or www.mytown.org/ccr/2012.html.
The EPA Memorandum lists the advantages and limitations of the various delivery methods, as well as several examples of the different electronic notification methods. It is available at this website: http://water.epa.gov/lawsregs/rulesregs/sdwa/ccr/upload/ccrdeliveryoptionsmemo.pdf (26 pages, 4.5 MB)
Questions we anticipate systems may ask in Iowa:
Q. Do I have to use electronic delivery?
A. No. It is a new option that is allowed, but it is not required to be used. You may still use the delivery methods you’ve used in the past.
Q. Will I have to include electronic notification in my CCR certification?
A. Yes, if you use electronic notification, it will need to be included in the certification that you submit by October 1st that describes how the CCR was delivered in your system. The certification form will be updated to include electronic notification.
Q. I have a mailing waiver this year and I serve fewer than 10,000 people. How does this affect me?
A. The mailing waiver criteria for delivery still apply: publish the reports in one or more local newspapers serving the area in which the system is located; inform the customers that the reports will not be mailed; and make the reports available to the public upon request.
Q. I have a mailing waiver this year and I serve fewer than 500 people. How does this affect me?
A. The mailing waiver criteria for delivery at systems serving fewer than 500 people still apply: provide a notice that the CCR that is available upon request to customers, either by mail, door-to-door delivery, or posting in a conspicuous location.
Q. I don’t get the mailing waiver this year because I had a violation. How does this affect me?
A. The same criteria applies for providing the CCR as before, in that the report must be mailed or otherwise directly delivered to the customer. You may use the electronic delivery as one of the methods to accomplish the delivery.
Q. I operate a small homeowner’s association with 30 customers, all of whom receive their water bills and association information via e-mail. Can I use e-mail to provide the CCR?
A. Yes, this is an ideal application for electronic delivery. The CCR could be attached to the email as a .pdf, embedded in the e-mail, or a URL is provided to the association’s website as a direct link to the CCR.
For questions, contact the Environmental Specialist listed in your operation permit, or Anne Lynam at 515/725-0280 (email@example.com) or Becky Schwiete at 515/725-0295 (firstname.lastname@example.org).