EPA CONFIRMS ELECTRONIC DELIVERY OPTION FOR WATER UTILITY CONSUMER CONFIDENCE REPORT REQUIREMENTS

The U.S. Environmental Protection Agency (EPA) released a memorandum earlier this month interpreting its current rule related to the delivery of a water utility’s Consumer Confidence Report (CCR). The EPA clarified that electronic delivery of CCRs is an acceptable way of complying with its requirement to “mail or otherwise directly deliver” CCRs, provided that certain conditions are met.

The EPA has identified two allowable approaches that a water system could use to provide electronic delivery: (1) a paper CCR delivery with a customer option to request an electronic CCR; or (2) electronic CCR delivery (e.g., e-mail) with a customer option to request a paper CCR. 

The EPA found that use of social media (e.g., Twitter or Facebook) directed at customers does not meet the requirement to “directly deliver.”  Additionally, if a water system sends the CCR via e-mail and it receives a message that the e-mail failed to reach the customer, the water system would need to send a paper CCR to the customer. 

Any city considering electronic delivery should carefully review the EPA requirements.  The EPA memorandum is available at
http://water.epa.gov/lawsregs/rulesregs/sdwa/ccr/upload/ccrdeliveryoptionsmemo.pdf.

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