The guiding principle behind consumer confidence reports (CCRs) is that all people have the right to know what is in their drinking water and where it comes from. The CCR provides an opportunity for water suppliers to educate consumers about the sources and quality of their drinking water and to involve them in decisions about it. U.S. EPA has revised its public notification requirements to speed up notification of serious health threats, and simplify notification of other violations. Consumers who are familiar with the basic drinking water information in CCRs will be able to participate more effectively in these processes. The reports will not only help consumers to make informed choices that affect the health of themselves and their families, they will encourage consumers to consider the challenges of delivering safe drinking water. Educated consumers are more likely to help protect drinking water sources and to be more understanding of the need to upgrade the treatment facilities that makes their drinking water safe. Even before generation and distribution of a CCR was required, many water suppliers saw the benefits associated with educating consumers and were distributing some form of a CCR voluntarily.
In 1996, the U.S. Congress and the President amended the Safe Drinking Water Act. They added a provision requiring that all community water systems deliver to their customers an annual water quality report. The law specifies certain content for the reports, and requires water systems to distribute these reports to all of their customers. CCRs summarize information that water systems already collect. The report includes basic information on the source(s) of water, the levels of any contaminants detected in the water, and compliance with other drinking water rules, as well as some brief educational material. U.S. EPA expects that most reports will fit on one or two sheets of paper. A report that contains too much information, or is full of technical jargon, will discourage consumers from learning the basics about their drinking water.
Every community water system that serves at least 25 residents year round or that has at least 15 service connections must prepare and distribute a consumer confidence report. These systems typically include cities, towns, homeowners associations, and mobile home parks. A community water system that sells water (parent supply) to another community water system (satellite supply) must provide monitoring data and other information that will enable the satellite to produce a CCR.
The reports are based on calendar year data. The first report included sample data collected from January 1, 1998, through December 31, 1998, and was distributed to consumers by October 19, 1999. Beginning in the year 2000, systems must deliver reports for the previous year by July 1. Parent supplies must deliver information to their satellites by April 19, 1999, and annually thereafter. The two systems may enter a contractual agreement that could result in an alternate delivery date of sample data to the satellite. A new community water system must deliver its first report by July 1 of the year following its first full calendar year in operation, and annually thereafter.
Each year community water supplies must “mail or otherwise directly deliver” the Consumer Confidence Report (CCR) to bill-paying customers and make a good faith effort to reach consumers who do not receive a bill. The U.S. EPA interprets “direct delivery” to include electronic delivery so long as the water supply provides a direct URL to the CCR (aka Annual Water Quality Report). However, if the water supply is aware of a customer's inability to receive a CCR electronically, it must continue providing a paper CCR according to an U.S. EPA interpretive memo that was finalized January 3, 2013.
Other acceptable e-delivery methods include attaching the CCR to an email and embedding the CCR in the text of an email. An e-delivery method that is NOT considered “direct delivery” is providing an indirect URL to the CCR. That requires the customer to search on a website and possibly not find the CCR. Another unacceptable method for “direct delivery” is using social media (e.g., Twitter or Facebook) because it requires a customer to join a website to read the CCR. All these methods are great to supplement the direct delivery methods, but cannot be the sole method to deliver to bill-paying customers.
Only the water supplier knows how best to communicate with consumers. Supplies could use a combination of paper and/or e-delivery depending on the demographic of the customer base. Before changing to e-delivery, a supply might consider mailing a “we're about to change the way we communicate with you” notice to customers. Many water supplies already supplement their mail delivery method with an email to e-bill customers and mail notification with a direct URL to customers who receive paper bills. Including the direct URL on each water bill and in newsletters could increase customer access to the CCR and knowledge of the e-delivery option. Some e-bill and auto-pay customers may ignore their monthly billing statements. A dedicated email (with a CCR-related subject line) would inform e-bill customers of the CCR.
The regulatory requirement to directly deliver the CCR remains unchanged. However the U.S. EPA realizes that utilities communicate with their customers differently than when the CCR Rule was originally drafted. The interpretative memo from the U.S. EPA was signed January 3, 2013. It describes ways water supplies can approach electronic delivery to bill paying customers and still meet current regulatory requirements.