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SOURCE - Spring 2013 13 heads up News and Views on Issues, Legislation and Regulations USEPA has released a memorandum explaining ways utilities can distribute their annual Consumer Confidence Reports (CCRs), including sending such reports electronically. Paper CCRs must still be sent to customers who request them, or if a utility is aware of a customer’s inability to receive that CCR electronically. According to the memo, acceptable delivery methods include: • Traditional land mailing a hard copy of the CCR to each bill-paying customer. • Traditional land mailing a notice that the CCR is available on a website, which can be in the customer’s regular bill, but must have a clearly marked URL that goes directly to the complete CCR. • Utility emailing a web address for the CCR to each bill-paying customer. This must be a notice that the CCR is available and provide a URF that goes directly to the CCR on a publicly available website. A URL that goes to a site where a customer has to search for the CCR or enter additional information is not acceptable. • Emailing the CCR as an attachment. For example, the utility may email the CCR as an electronic file attachment in pdf. • Emailing the CCR as an embedded image or text. For example, a utility can send the CCR text and tables inside the body of an email. • Additional electronic delivery that meets the “otherwise directly deliver” requirement of the Safe Drinking Water Act. (This category is set out to encompass different or new methods or technologies not listed above. Utilities should consult with their primacy agencies when considering new tools to make sure they meet the SDWA’s requirement that the CCR is delivered directly to customers.) The EPA memo also discusses other important considerations that utilities and primacy agencies must take into account, such as how to organize opt-in and op-out lists. In all instances, paper copies must be provided to those who request them, and a phone number must be provided to facilitate such requests. Since regulatory oversight of electronic delivery will occur at the primacy agency level, utilities should contact their primacy agencies for information on how they will be implementing this interpretative memo, as there may be variability from state to state. Small system waivers and good faith requirements to reach consumers who do not receive a bill are not affected by this memo, although it’s possible that primacy agencies may modify their use of these tools as electronic delivery is implemented. The full memorandum is available at regs/sdwa/ccr/regulations.cfm. S EPA OKs Electronic CCRs

SOURCE - Spring 2013
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