EPA Hosts CCR Electronic Delivery Webinar

On Thursday, January 17th, EPA’s Office of Ground Water and Drinking Water hosted a two hour webinar to go over the new flexibilities in how CCRs (Consumer Confidence Reports) can be delivered electronically and how those flexibilities should be considered within the context of the original Consumer Confidence Report rule.

State drinking water programs may now offer new delivery methods to their water systems that still meet the requirements of the CCR rule.  In additional to traditional paper delivery, utilities may now offer an electronic delivery option.  Utilities may notify bill paying customers that they can access their annual CCR via a direct URL; send the CCR as an email attachment; or embed the CCR in an email sent to those customers for whom the utility has an active email address.  There are some caveats to this new delivery approach:

• The URL must be a direct link to the CCR — a customer should not have to navigate to another webpage to find any required CCR content;
• Social media such as YouTube or Twitter is not an allowable delivery mechanism to reach customers — however, it can be an appropriate additional ‘good faith’ distribution method; and
• Automated phone calls are not considered as a ‘direct delivery’ mechanism since the entire content of the CCR cannot be provided in one phone call.

In planning a new delivery strategy, drinking water utilities should:

• Check first with their primacy agency to make sure that the approach meets both state and Federal requirements;
• Research their customers’ access to electronic technologies and their interest in receiving their CCR electronically (be sure to include an opt out message with all notices about the change);
• Make sure that their electronic strategy still reaches all bill paying customers and includes appropriate ‘good faith’ efforts.
• Don’t forget about appropriate certification and record keeping requirements — these also apply to electronic distribution.

ASDWA has posted a copy of the new CCR guidelines as well as a copy of Thursday’s webinar presentation.  Go to www.asdwa.org to view the presentation.