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
According to the memo, acceptable delivery
• 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
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
EPA OKs Electronic CCRs