Listening Session Summary 1 Horsley Witten Group, Inc.
March 30 , 2012 

### Idea/Question Comme nt Summary U.S. EPA Consumer Confidence Report (CCR) Retrospective Review Listening Session

Introduction

In August of 2011, the U.S. Environmental Protection Agency (EPA) issued Improving Our Regulations: Final Plan for Periodic Retrospective Reviews of Existing Regulations (the “Plan”) . One item included in this Plan and subject to retrospective review is the Consumer Confidence Report or CCR. The CCR is an annual water quality report that a community water system is required to provide to its customers. The report lists the regulated contaminants found in drinking water, levels of these contaminants in the community water system (CWS) compared to allowed limits, a s well as health effects information related to violations of the drinking water stand ards. Currently, CWSs serving more than 10,000 persons are required by the Safe Drinking Water Act to mail or otherwise directly deliver these reports. States may allow CWSs serving fewer than 10,000 persons to provide these reports by other means.

Stakeholders have noted that there has been a major increase and diversity in communication tools since 1998 when the CCR rule was first promulgated. Pursuant to the Plan, EPA is reviewing the CCR Rule to identify opportunities to improve the effectiveness of communicating drinking water information to the public, while lowering the burden on water systems and states. An important part of the CCR re trospective review proce ss consist s of gathering stakeholder input . This promote s greater transparency and public participation in protecting the nation's drinking water . It also promote s participation and the open exchange of information. To gather this input, EPA
created htt p://ccrretrospectivereview.ideascale.com /, an online crowd sourcing portal where states, tribes, territories, drinking water utilities, and consumers can respond to questions, react to each other’s comments, and post new ideas. This site was active from
F ebruary 23 to March 9, 2012.

This summary describes comments and responses p osted to the portal for the six categories and 37 ideas/que stions listed below. As of the closing date, the portal had 697
created accounts as described in the table below.

Comm enter Type Number of Participants Percent of Total Participants Federal Regulator 24 3.4 State Regulator 101 14

. 5 Public Water System 509 73.0
Customer 63 9.0

Of the 697 members who created accounts

, 185 of those member s submitted comments (about a 2 7 % participation rate). In total, approximately 630 comments were received,

rea d

, and analyzed for this summary.Listening Session Summary 2 Horsley Witten Group, Inc.
March 30 , 2012 

# Category 1 : CCR Delivery
Community Water Systems (CWSs) serving more than 10,000 persons are required by the Safe Drinking Water Act (SDWA) to mail or otherwise directly deliver CCR reports to their customers. States may allow CWSs serving fewer than 10,000 persons to provide these reports by other means. Stakeholders have noted that there has been a major increase and diversity in co mmunication tools since 1998 when the CCR rule was first promulgated. Under the CCR Delivery category, five subcategories were created and seventeen ideas or questions/sets of questions were created under the subcategories to capture the thoughts of the c onsuming public, drinking water systems, and primacy agencies. In all, approximately 320 responses were captured under this category. Commenters in this category provided their views on the current and alternativ e delivery methods, the advantages and dis advantages of the alternative delivery methods, CCR variances, CCR true costs, and state agencies transferring CCRs to water systems via email. These comments are summarized below by commenter subcategory.

**Subcategory Alternative Delivery** 

**– Customers/Public Comments** 

Question/Idea: If you could receive your CCR in any format, what would be your preferred delivery method? Some methods to
consider are: hard

- copy mailed to my home; e

- mail with a PDF of the report; e

- mail with an Internet URL; paper bill or a bill insert with an Internet URL; a postcard with an Internet URL.

Fifty

- six (56) total commenters. The number of comments is shown in parentheses below.

Those who commented on this idea offered different suggestions as to what the pre ferred option is for delivering the CCR is in their community. Some commenters stated that they would be interested in several options including:

• Customer Bill

– each bill that a customer receives would notify the customer that they can visit a specific website to view their CCR or provide contact information (e.g., phone number, email address, postal address) as to how they can request a copy of the CCR. (20)

• Postcard

– the water system could print a postcard which could be delivered to each customer as an insert in their bill or as a separate mailing. The postcard would have a website that a customer could visit to view and download their CCR as well as contact information (e.g., phone number, email address, postal address) for a customer to request a hard copy of the CCR. (11)

• Email

– customers who have registered their email address with their water system would receive an email with a website that they could visit to view and download their CCR or the CCR could be attached to the email itself. (10)

• Hard Copy

– continue to provide the CCR in the mail to each customer or post it in public places for customers to access (e.g., government offices, water system offices, library). (7)

The majority of commenters believe that the way forward is to allow u tilities to have multiple options available to them to choose from. The exact combination of options used will vary from water system to water system, but the commenters state that they believe that their water system will provide the options to their cus tomers which will work best in their community.Listening Session Summary 3 Horsley Witten Group, Inc.
March 30 , 2012 The commenters also offered additional suggestions to consider as ways to enhance a customer’s understanding of
the CCR:

• Utilities should add more explanatory information to the CCR. (2)

• Utilities should hold annual local Q&A sessions in their communities regarding the CCR. (4)

• Utilities should create videos which further explain the health language. (1)

• For communities with non

- English speaking populations, statements in appropriate foreign languages
sh ould be included in the CCR which advise them how to have the CCR translated. (1)

• State Primacy agencies should post all their water system CCRs on their websites for all to view. (1)

Question/Idea: If given an option for electronic delivery of your CCR, would you choose to take advantage of this option?

Thirty

- one (31) commenters responded to this idea.

The majority of commenters stated that they would take advantage of the option to deliver the CCR electronically for reasons including:

• Multiple options, including electronic delivery, will meet the “best faith effort” requirement to communicate the information to their customer base. (11)

• This would save most water systems the time and money it costs to print and mail the CCR in hard copy
format . (5)

• This would result in reduced customer complaints of wasting money. (2)

• This would result in reduced environmental impact. (2)

• Their water system already posts the CCR on their website. (1)

• Their water system has already instituted an electronic billing system. (2)

The commenters who would choose not to take advantage of an electronic option stated that:

• Their water system does not use electronic billing. (1)

• Their internet is too slow to send emails with file attachments. (1)

• Email addresses change too frequently to keep track of them. (1)

• They would rather receive a hard copy of the CCR because of their personal preference. (2)

• They do not regularly use email because the internet not available in their area. (1)

A state agency commenter from the Florida Department of Environmental Protection noted that since the rule already says “mail or otherwise directly deliver,” EPA could define “directly deliver” to include email. Therefore, any changes could be made through a guidance document rat her than through rulemaking.

Overall, the consensus is that most customers prefer to have multiple options, rather than a one size fits all approach, available for receiving their CCR (e.g., hard copy, email with a URL, postcard or bill insert with URL).Listening Session Summary 4 Horsley Witten Group, Inc.
March 30 , 2012 Question/Idea: If you don’t receive a water bill (e.g. you reside in an apartment building where water charges are included in your rent), do you recall receiving a CCR? How did you receive your CCR? What would be your future preferred delivery me thod? Some methods to consider are: hard

- copy mailed to my home; e

- mail with a PDF of the report; e

mail with an Internet URL; paper bill or a bill insert with an Internet URL; a postcard with an Internet URL.

Five (5) commenters responded to this idea, but they were not “customers” per se.

Commenters from water systems note that they make a “good faith effort” to reach as many customers as possible, but every water system approaches this differently. The commenters would appreciate further clarification of what CCR delivery methods are acceptable. One water system commenter stated that they mail their CCR to every address in the zip codes they serve so all residents receive it. However, this means that some non

- wat er system customers (e.g., customer on private well) receive the CCR as well.

Four of the commenters believe that a notification in a local newsletter (e.g., neighborhood, municipality) that the CCR was available to view, either as a hard copy or online, would be a good way to reach those individuals who do
not receive a water bill.

Question/Idea: Would you have any concerns about receiving your CCR as an email attachment (e.g., attachment file size, spam controls, and/or internet bandwidth)?

Four (4) commenters responded to this idea.

The commenters noted several concerns with sending and/or receiving a CCR as an email attachment:

• A customer may not be able to view the attachment because it is not compatible with their software or their computer is not up

- to

- date.

• Many individuals are wary of downloading attachments that they were not expecting, as i t is very common for spam, virus attacks, and so forth to masquerade as a legitimate email from a bank or other popular institution, and for attachme nts to contain viruses.

• Many email services have a limited total inbox capacity, which means that attachments may cause emails to "bounce" back more than they would without attachment.

• Many water systems would find it difficult or impossible to email thous ands of copies of their email with an
attachment due to limited bandwidth.

• There is no mechanism to know whether the email was delivered to their inbox or to their junk mail.

Alternatively, all of the commenters believe that it is much cleaner and effect ive to send a customer an email that provides an internet URL to visit to view their CCR.Listening Session Summary 5 Horsley Witten Group, Inc.
March 30 , 2012 Question/Idea: Have you viewed your water system’s CCR on a website; how did you learn about the web posting?

Four (4) commenters responded to this idea, but only one appears to be from the general public.

The commenters each offered a different way that customers have learned about the ability to access their water system’s CCR online:

• They received a notification in their bill telling them where to look online to learn more about their water quality.

• People who want to learn more about their water quality will naturally access their water system’s website
to find out more information.

• Their municipality’s website has a link to their local water provider’s CCR.

• Some employers, health care providers, or housing associations provide this information to their

constituents.



### Subcategory **Alternative Delivery**

**– Drinking Water**  **System Comments** 

Question/Idea: What problems or issues have you had with production and delivery of consumer confidence reports?

Thirty

- four (34) commenters responded to this idea.

Those who commented on this idea mentioned many different types of problems or issues arising with the production a nd delivery of the CCR, and in many cases their comments covered several of these items:

• Production and postage costs are expensive for many water systems so they do not include much information beyond the mandatory language required under the regulation. (15)

• Water systems question the benefit of providing every customer with this informati on when they believe that their customers either do not understand the information contained in the CCR nor do they read the CCR. (7)

• Many staff members at each water system are involved in the process and some commenters believe that
their time could be better spent doing other tasks. (3)

• Some water systems serve multiple systems which require individual CCRs and while many use a standard template, each individual CCR must be personalized for that system. (4)

• Gathering contact information in the “good faith effort” to reach non

- bill paying customers requires a lot of staff time. (4)

• There is the belief that customers would rather be notified only if their water is not safe and that they are confused by all the information they receive in the CCR. (3)

• The competitive bid process that water systems who use third party vendors to prepare the CCR must undertake each year to get the best price is expensive and time consuming. (2)

• For utilities that send out quarterly bills, the July 1 st deadline does not a llow the water systems to have enough preparation time to gather the required information before they must start printing it. (2)

• Their state a takes a very long time to approve their CCR before they can print it. (2)

• An error found at even the earliest stages of the CCR printing process may result in thousands of reports being thrown out which increases the overall expense of the process. (1)Listening Session Summary 6 Horsley Witten Group, Inc.
March 30 , 2012 • The provision requiring that CCRs be put into the newspaper is not always a burden reduction, and in many

cases the cost of putting the entire CCR in the paper costs more than printing and mailing to customers. (1)

Question/Idea: There are many potential methods to deliver a consumer confidence report electronically. What method(s) (e.g., e

mailing a PDF of the report, supplying a URL via e

- mail, including a URL on a paper bill or a bill insert, including a URL on a postcard, etc.) would you recommend be available as options ? What are the advantages and challenges associated with each of these methods?

Thirty

- two (32) commenters responded to this question to recommend alternative methods for CCR delivery.

Most commenters (14) recommended that a URL, directing customers to an online version of a CCR, be included on customer bills or in a separate bill insert. Mailing a postcard with the URL was the second most (7) recommended option. Other recommendations for alternative delivery of a CCR include:

• Mailing a CCR upon request only. (6)

• Sending an email to customers with a PDF of the CCR. (1)

• Sending a CCR URL to customers via email. (5)

• Posting a CCR to a website. (3)

• Utilizing social media, including Facebook, Twitter, etc. (1)

• Allowing customers to “opt

- out” of receiving a hard copy CCR, if electronic delivery methods are available. (2)

• Issuing a nation

- wide notification to all media outlets each July 1 st , stating that CCRs are available on

- line. (1)

Publishing the CCR in a local newspaper and including the URL. (2) Commenters also mentioned advantages of alternative methods for CCR delivery. T hose advantages include:

• Reaching a greater percentage of the public in a variety of environments though diversifying methods of CCR delivery.

• Reaching electronic billing customers easily with a URL sent via email. (2)

• Sending a URL via email would be substantially easier than emailing a PDF of a CCR, as the total size of the email is much smaller, reducing bandwidth constraints and reducing the chances that the emails will be
returned due to their size.

Advantages of mailing a postcard with the URL include:

• Reducing graphic design, printing, and postage costs by sending a postcard with the URL compared to printing and mailing CCRs themselves. A postcard could contain instructions on how to receive a paper copy
of the CCR should the recipient not have access to the Internet (for example, by mail or through a local library).

• Reducing returned or bounced emails by sending the URL on a bill or postcard

. This method would bypass many of the potential technological problem s and improve communication with customers and reduce

costs.

• Ensuring that anyone who drinks the water (not just billed customers), would receive notice about the CCR through a URL on a postcard.

Commenters also mentioned potential challenges associated with alternative methods for CCR delivery. Most commonly, responders (5) indicated that some water systems may not maintain email addresses as part of their
customers’ contact information.Listening Session Summary 7 Horsley Witten Group, Inc.
March 30 , 2012 Other challenges mentioned include:

• Lack of internet access

– M any people still lack internet access. As such, mailing hard copies of CCRs is still the best way to reach the largest number of people with this information. (4)

• Spam classification

– An email with a URL or PDF report may be classified as spam and filed accordingly. (2)

• Email and inbox size restrictions

– A customer’s email inbox might be near capacity and reject a large PDF. In addition, there may be internal bandwidth issues related to e

- mailing too many PDFs to water systems with a large amount of c ustomers. (3)

• Consumers may avoid opening a PDF in their email that they are not expecting out of fears that the email may not be legitimate and the file may infect their computer.

• Since a PDF is a static format, updates and corrections after the docume nt has been sent out cannot be accomplished, whereas CCRs can be updated on a website.

One commenter stated that the Direct Marketing Association has published data on response rates for bill stuffers, post cards, etc., and those rates are dismally low. For instance, this research concluded that less than 1 percent of people respond to information included with bill stuffers; while post cards are slightly better with a 2 percent
response rate.

Question/Idea: What do you see as the advantages, if any, of electronic delivery of consumer confidence reports?

Thirty

- two (32) commenters responded to this idea.

The commenters shared many reasons why they believed that there is an advantage to electronically delivering the CCR, and some listed multiple ad vantages:

• There is a cost savings in not having to mail and print the CCRs. (19)

• There will be a reduced environmental impact as less paper and ink will end up in a landfill. (10)

• Electronic delivery allows water systems to improve their communications with their customers. (4)

• Many customers have a view that the water system is wasting taxpayer money by mailing the CCR to customers. (4)

• The CCR is available online for a customer at all times for a customer to read when it is convenient for them. (4)

• Electronic Delivery is faster than mailing the CCR. (3)

• The CCR can be posted on a water system’s website where customers can also find other valuable information. (3)

• Those who receive their bills electronically also would prefer to receive their CCR electronically. (1)

Overall, the majority of those who commented on this idea think that allowing the electronic delivery of the CCR is a
“win win situation” for all customers.Listening Session Summary 8 Horsley Witten Group, Inc.
March 30 , 2012 Question/Idea: What kind of feedback have you received from your customers on their preferred method of receiving a CCR?

Thirty

- two (32) commenters responded to this idea.

The majority of commenters stated that they received:

• Feedback from their customers who feel that it is wasteful for the water system to print and mail the CCR as it is not a good use of customer and taxpayer money. (19)

• Feedback that the majority of customers prefer to receive the CCR in the mail or they li ke to be able to pick up a copy of the CCR at a public place in their community. (4)

• No feedback at all. (4)

• Feedback that their customers would prefer to receive the CCR by email. (3)

Additionally, a commenter from the American Water Works Associatio n (AWWA) sums up the view of most commenters by stating that “how customers wish to receive CCRs is likely to vary both from individual to individual but also from community to community. To allow water systems to meet the needs of their customers, it wou ld be best if multiple CCR delivery options were available, including paper and several electronic delivery methods.”

Question/Idea: What do you see as the challenges, if any, of electronic delivery of consumer confidence reports?

Twenty

- three (23) commenters responded to this idea.

The commenters shared many challenges to the electronic delivery of a CCR and some commenters listed multiple challenges:

• Collecting emails from all of their customers. (9)

• Making sure the emails that customers prov ide are up

- to

- date. (9)

• Many customers are reluctant to share their information (e.g., in some states their personal information is part of the public record). (4)

• Initial implementation of the IT systems to support a transition towards electronic deli very. (3)

• The logistics of tracking the way each customer receives their CCR for future delivery (e.g., hard copy, electronic delivery). (3)

• Customers who do not own computers or have access to the internet. (2)

Commenters who didn’t anticipate any ch allenges stated that they are using third party vendors who are able to adapt their delivery methods based on the water systems instructions.

Many commenters stated that they would use electronic delivery for those customers who requested that option
and continue mailing hard copies to those customers who preferred the current method.Listening Session Summary 9 Horsley Witten Group, Inc.
March 30 , 2012 Question/Idea: If electronic delivery of consumer confidence reports were to be authorized, would you see any roadblocks to implementation?

Twenty (20) commenters responded to this question.

Commenters provided feedback on potential roadblocks to implementing electronic delivery of CCRs. The most commonly mentioned roadblock (8) was the difficulty associated with obtaining email addresses and maintaini ng current email addresses.

Other roadblocks include:

• Email spam restrictions

– The CCR may not go into a customer’s mailbox; rather it may be sent to the spam or junk folder. (3)

• Costs

– There are high costs associated with switching to an electronic d elivery system for CCRs. (2)

• Lack of personal email accounts

– Although most people could gain access to the internet (e.g., access through public libraries), not everyone has an email account.

• File size

– Sending an email with an attached PDF of the CCR may present technological barriers, such as not being received by the intended recipient due to file size. Including a URL on a bill (so long as it was valid whether the bill is delivered electronically or by mail) presents fewer barriers. (2)

Commenters also provided supportive comments for electronic delivery of CCRs through various methods including:

• Including the URL on the customer bill

– This is an electronic delivery option that doesn’t require customer email addresses. (9)

• Sending a pos tcard with the URL

– This is an electronic delivery option that doesn’t require customer email addresses. (2)

• Emailing a PDF of the CCR.

Two commenters mentioned that water systems should have paper copies on hand and deliver them, only upon
request.

Another commenter suggested publishing a notice of the CCR availability in local newspapers.

Question/Idea: Do you maintain email addresses for your customers? How did you obtain your customers’ email addresses? What percentage of customers do you have emails for and what have been your experiences with keeping email
addresses current?

Fifteen (15) commenters responded to this question.

Commenters responded as to whether or not email addresses are maintained as part of their customers’ contact

i nformation.

• Yes, all customers. (0)

• Yes, some customers. (8)

• Yes, 50 percent of customers. (1)

• No, none. (5)Listening Session Summary 10 Horsley Witten Group, Inc.
March 30 , 2012 Some commenters indicated how email addresses are obtained from customers. Methods to obtain customer
email addresses include:

• Electronic billing. (7)

• During initial signup for service. (2)

• When customers register their accounts on the water system’s website for leak notification and AMR
related information.

• Through advertisements to join a listserv on the water system website, in paper bi lls, and in the newspaper.

One commenter responded to indicate that his/her experience in maintaining current customer email addresses has been very difficult. A few commenters indicated the percentage of total customers for which they maintain email
add resses. These percentages are included below.

• Very small amount. (1)

• Around 20 percent. (3)

One commenter mentioned a 2010 survey conducted by AWWA, which surveyed 213 utilities. The following distribution of percentage of customers with an email addr esses on file is taken from that survey.

• 31%: No Customers have an e

- mail address on file;

• 39%: Less than 10% of customers have an email address on file;

• 18%: About 10

- 25% of customers have an email address on file; and

• 14%: More than 25% of customers have an email address on file.

Additionally, the survey indicated the percentage of the water system’s customers that currently receive some or all of the system’s information electronically:

• 46%: No Customers receive information electronically;

• 35%: Less th an 10% of customers receive information electronically;

• 10%: About 10

- 25% of customers receive information electronically; and

• 9%: More than 25% of customers receive information electronically.

Question/Idea: If you currently display your CCR on the Internet and collect web statistics, please share your results (i.e., number of CCR downloads, percentage of customers viewing CCR webpage, etc.).

Seven (7) commenters responded to this idea.

Three commenters (listed below) provided web statistics as their comments:

City of Tampa Water Department:

• Between May 2011 and February 20, 2012, the 2010 CCR was downloaded 11,524 times. There were 3,013 visits to the portal page there is an archive for the last five CCRs. The CCR is also available from mul tiple links throughout the website.

AWWA:

• A pilot electronic CCR project in York, PA in 2010 (which serves approximately 180,000 individuals) sent 5,194 emails containing a link to the online CCR at a small fraction of the cost and effort of mailing them . Of the 5,194 delivered emails, 1,822 (35%) clicked on the link.

• In a 2004 study by the Water Research Foundation, 38% of customers surveyed remembered receiving aListening Session Summary 11 Horsley Witten Group, Inc.
March 30 , 2012 mailed CCR in the past year. Of that number, only about half (less than 21% of custome rs) even skimmed through the CCR, which may be equivalent to clicking on and opening the CCR electronically. Only about 17% of customers actually read the paper CCR. Therefore, from this information, it appears that consumers may be equally likely or ev en more likely to read or at least skim the CCR when it is provided electronically
than when mailed.

American Water:

• Customers are able to access their water quality information (both their CCR and Basic Water Quality Summary) by entering either their City/State or their zip code at ht tp://www.amwater.com/ensuring

- water

quality/water

- quality

- reports.html . On average, customers are accessing this part of the American Water web site about 5,000 times per month. This equates to over 60,000 times a year that customers were able
to search for the information they wanted when they wanted, not just the one time a year we sent them a report in the mail.

In addition, two water systems (Hillsborough County in Florida and Colorado Springs Utilities in Colorado) stated that they did not have th eir statistics available; but in their experience, their customers are going to the water systems’ websites to view the CCR. A commenter from the Association of State Drinking Water Administrators (ASDWA) noted that some states can provide this information to the EPA as some states track this information when a water system provides it to them.

Question/Idea: Do you have any experience with electronic systems that have distributed bills or other water

- related information to consumers? If so, what are t he benefits you have seen from these systems and what are the difficulties that you have encountered? Have you had any difficulties with including attachments or other supplemental information?

Seven (7) commenters responded to this question.

Those who commented responded to indicate whether or not they have experience with electronic bill distribution for water system consumers.

• Electronic billing upon request. (5)

• No electronic billing available. (1)

• Plans to implement electronic billing in the future. (1)

Some commenters mentioned benefits associated with electronic billing. Benefits mentioned include:

• Cost savings related to postage and printing costs normally associated with a paper bill. (2)

• Email addresses

– Email addresses are p rovided by e

- billing customers. This allows the water system to notify customers of new initiatives or other issues related to their accounts. (2)

One commenter indicated that substantial upfront costs would be a major difficulty associated with implemen ting electronic billing systems. This commenter added that electronic billing systems require substantial IT resources and customer outreach upfront to get the programs started, and many water systems may not have the resources immediately available to st art such a program.

Another commenter stated that email attachments for customer bills are generally not used, for security reasons, but files, such as the customer’s bill, are made available for download on the water system’s website.Listening Session Summary 12 Horsley Witten Group, Inc.
March 30 , 2012 

### Subcategory
CCR True Costs Comments

Question/Idea: The original estimates for delivery cost according to Final CCR Rule appeared very low. What are the actual savings for alternative CCR delivery methods?

Six (6) commenters responded to this question.

Cost and savings estimates were provided by three commenters. These estimates are indicated below.

• Costs for CCR printing & mailing in 2011 were $180,000, and 1.3 million people were served. Electronic delivery would reduce this cost by 50%.

• For a water system wi th 67,000 meters and a population of 190,000, the costs for CCR are over $60,000. Distributing electronically would save over more than 65% of that cost.

• A small drinking and wastewater system that prints 23,000 annual CCRs which are inserted into bills a nd mailed to all customers, including apartment dwellers (who are not direct customers). If this system could utilize the electronic delivery method, and avoid printing, postage, and mail house charges, savings would be approximately $5,000.

One commente r indicated that each water system’s labor and delivery costs should be part of the rule and should be required to be printed on each CCR to inform customers about the costs associated with providing this
information.

One commenter noted that they do not maintain cost figures for each of their North Carolina water systems, but CCR production and delivery costs are financially burdensome for every system in this economy.

Another commenter estimated that the total annual cost for all systems is, based on a very conservative estimation of fixed costs, over $100,000,000 per year. This is higher than the $20,000,000 noted in the CCR Final Rule. The commenter suggested that th is discrepancy should be investigated to ensure that the true cost of the CCR is made available to the public.



### Subcategory
CCR Variances Comments

Question/Idea: Have any systems utilized the variances for report delivery allowed under the CCR regulations which allows a governor (or his rep) of a state to waive the mailing requirement of the CCR for systems <10,000? Should this waiver process be improved?

Twelve (12) commenters responded to this question.

Five commenters responded to indica te that they utilized the variances for report delivery allowed under the CCR regulations which allow a governor (or his rep) of a state to waive the mailing requirement of the CCR for systems
<10,000.Listening Session Summary 13 Horsley Witten Group, Inc.
March 30 , 2012 Some commenters offered suggestions for improvements to the waiver process, which include:

• Some states, including TX, MO, FL, implement a procedure whereby small systems are granted use of the mailing waivers, as long as the systems had no violations in the previous year.

• States should be encouraged to allo w on

- bill notification of CCR availability rather than requiring: 1) a separate mailing of notification of the CCR availability (North Carolina) and 2) paper mail review of the CCR by the state (Virginia).

• Any improvements to implement new delivery option s could be accomplished via special primacy conditions instead of a governor's waiver.

• Some electronic delivery options, such as including a web address on a customer's bill or sending a postcard with a web address and instructions on how to request a pape r copy would reach at least as many people, but with a small fraction of the total paper use and at greatly reduced cost.

• Commenters stated that there are still significant financial costs (printing, changing to electronic delivery systems, etc.) associate d with this regulation. (5)

One particular public water system in Maine saved thousands of dollars by printing an announcement of the CCR availability in the newspaper, rather than mail delivery of the CCR.



### Subcategory State Agencies Transferring CCRs to Water Systems via Email Comments

Question/Idea: In addition to sending the CCR template from the state agency to systems via U S Postal Service, may the state transfer the template electronically to the systems via a Word Doc. to systems that request it? This allows systems to tailor the CCR easily with their own "Who to contact with questions" information, add charts, photos, etc.

Five (5) commenters responded to this question.

Commenters responded to indicate their use of a state CCR template for water systems.

Commenters indicated that they:

• Post a CCR template on the state website for use by water systems. (2)

• Post a CCR template on the state website and send an email to wa ter systems to notify them of the template’s availability. (2)

• Send CCR guidance on the required information from each water system, but do not provide a CCR template document. (1)Listening Session Summary 14 Horsley Witten Group, Inc.
March 30 , 2012 

# Category 2 : CCR Clarity and Understandability
Under this category, three subcategories were created and five ideas or questions/sets of questions were created under the subcategories to capture the thoughts of the consuming public, water systems, and primacy agencies. In all, approximately 120 responses were captured und er this category.

**Subcategory CCR Clarity Comments** 

Question/Idea: I would like for EPA to create demo video that CCR creators could look at on the iWriter site. I think this will help if a user can watch a video of someone creating a CCR, then they will have a better understanding on how to use
the CCR iWriter.

One (1) state agency commenter responded to this idea.

The commenter supports the idea of a v ideo that includes “help” buttons on each page to clarify questions and give instructions. In New Mexico, trainings are provided prior the CCR due date using CCRiWriter and walking the systems through each step. The video, if developed, could benefit both the State and the consumer.

• Utilities should hold annual local Q&A sessions in their communities regarding the CCR. (4)

• Utilities should create videos which further explain the health language. (1)

• For communities with non

- English speaking populations, s tatements in appropriate foreign languages should be included in the CCR which advise them how to have the CCR translated. (1)

• State Primacy agencies should post all their water system CCRs on their websites for all to view. (1)



### Subcategory
CCR Clarity and Understandability

– Customers/Public Comments

Question/Idea: Do you find specific parts of your CCR difficult to understand ? [Parts of the CCR

- source water information; definitions; table of detected contaminants; informational statement about lead in drinking water; information about Cryptosporidium sample results and the significance of these results (this may not apply to your water supply); explanation of the reasons for measuring turbidity (this may not apply to your water supply); w ater treatment description; other.]

Sixty

- five (65) commenters responded to this question.

Basically, commenters agree that the information given in the CCR is confusing, misleading and alarming to most readers. Comments in this regard include:

• Including all the analytics is too overwhelming for the general public if there is not an easy to understand interpretation of the results that explains what is in the water and how it can affect their health.

• Some believe that shorter and easier to read language will be helpful, as the current format, especially on mandatory language, presents the information in a negative tone for the general public. (4)Listening Session Summary 15 Horsley Witten Group, Inc.
March 30 , 2012 • There is a suggestion to eliminate all the detected results in the table unless the MCL is exceed ed. (1)

• Group the contaminants into categories that allows the reader understand the sources and representativeness of the data. (2)

• The table that lists all the contaminants and concentration results is confusing. (4)

• The language should include resul ts of analysis when contaminant levels approach or exceed the MCL, but not when levels are much below MCL. Too much unnecessary data and analysis are alarming to the
common reader.

• People just want to know if the water is safe to drink, which according to a couple of commenters, water system providers are discouraged to do. (2)

• Improve the use of language that educates consumers. (3)

• The CCRs should explain in clear language whether waters met or exceeded state and federal regulations
without excessiv e analytics and data. (2)

On the other hand, the water system providers are constrained by the requirement of following the language mandated by EPA and the states. They think that giving some flexibility in this aspect would allow the report to be

more cost

- effective and consumers would be more likely to open the document and read it, rather than discarding

it.

Some commenters strongly object to the idea that the report should be shortened. These commenters want to know the details and are interested in reading the specifics of the analyses and how their drinking water meets the standards. (8)

One commenter from Pennsylvania states that there are no drinking standards for contaminants frequently found from drilling activities and demands that standards should be set before pe rmitting drilling.

A commenter from the Environmental Working Group offered some suggestions to fulfill the purpose of the report as a tool for educating the community:

• Reduce the “marketing” language which is at the introduction of the CCRs.

• Bolster the usefulness of CCRs for consumers to understand the challenges facing water systems; tips for water conservation; ways to be involved in water quality protection efforts; and, awareness of possible sources of pollution.

• Include all detected chemicals, incl uding unregulated compounds monitored by the water system provider, in order to provide a big picture of water quality and the efforts made by water system providers to monitor and protect water.Listening Session Summary 16 Horsley Witten Group, Inc.
March 30 , 2012 Question/Idea: Do you find your CCR to be clear and understandable? Why or why not?

Twenty

- seven (27) commenters responded to this question.

Most commenters concur that the CCRs are difficult to understand, thus losing the interest of the public and hindering the sole purpose of the document: communicat ing to the community about the quality of their drinking water. The most representative comments are summarized below:

• The purpose of the CCR needs to be reconsidered in order to foster community receptiveness to the report. (5)

• In general, CCRs are r ather wordy and too technical, making it unlikely that the reports are being read by the general public. The terminology is confusing. The use of the word “contaminant” causes undue alarm, even when water is safe to drink. (12)

• There is a belief that man y may not understand the language utilized in the CCRs, language which is driven by EPA and state agencies. CCRs need to be more user

- friendly to bolster readership and interest. (3)

• There are many acronyms that are not clearly explained for the average reader. (1)

• It is important to improve communication between the water system provider and the community by providing the public with more information. The hope is that customers will start thinking of their water system as a vital community service, rat her than just another bill collector. (1)

• Customers have the right to know the details of what is in the water. (3)

A couple commenters consider the CCR report to be clear. However, they note that they are in the industry and that helps them to understand the language and allows them to be able to explain the content to others.

Two commenters from water systems both support providing a more meaningful report with information on the educational aspects of water conservation and more reader friendly content. However, doing so would be more costly and is not within their respective budgets.

Some commenters (3) point o ut that the definition of MCL and MCLG can cause confusion for readers without an understanding of the representativeness of the data. These same commenters agree engaging discussion about the
results will be more beneficial.

For States where some activi ties such as gas drilling pose potential additional risks for drinking water contamination, at least two commenters believe the CCR should include information regarding contaminants associated with drilling. In these situations, the commenters argue, ther e is increased community interest as to whether drilling activities are leading to drinking water quality problems.Listening Session Summary 17 Horsley Witten Group, Inc.
March 30 , 2012 Question/Idea: When a system reports a maximum contaminant level (MCL) violation, it must include potential health effects language. While reading your CCR in the past did you understand the health effects language?

Eight (8) commenters responded to this question.

Most of the commenters agree that the language currently used in the CCRs is disconcerting and frightening for the general public’s perception of health risks. One commenter suggests focusing on contaminants that exceed a health
based standard rather than including other contaminants that are marginally or not detected. Consumers tend to get overwhelmed with names and values that are more frightening than informative. A checklist that enables water system providers to ensure that the health effects langua ge is included and clear is recommended for interpreting the CCR requirements and results.

On the other hand, commenters (3) suggest modifying the language in the following two ways:

• Information on health effects due to long term exposure.



### • Highlight th e positive aspects of water systems and the water provided, rather than focusing only on the negative connotations of contaminant health risks and past violations.



### Subcategory
Central Website for Consumers Comments

Question/Idea:
Could EPA have a beautifully

- designed, interactive website that we could link customers to with detailed explanations of what to look for in their local CCR (in multiple languages?) And could EPA develop a shortcut URL for that awful long website: http://water.epa.gov/inf rastructure/drinkingwater/pws/index.dfm? Maybe “.gov/DrinkingWater?"

Sixteen (16) commenters responded to this question.

All the commenters strongly support the idea of an interactive website for finding detailed information on their
local CCRs. While this will be helpful to the public, three commenters prefer to continue receiving the report by regular mailing in addition to an interactive website. One commenter states that this format for delivering the CCR
will be cost

- effective and lessen the hard copy distribution burden. Also, for the web

- design, a commenter suggests that employing a web

- designer that is sensitive to the end

- user can ensure that the information as well as the structure of the site is straightforward. On the other hand, two commenters are concerned that an exclusively web

based report will not reach people without computers and/or internet access. However, one commenter disagrees with this statement arguing that not having internet access should not be the driving force not to have electronic information as a primary communication option.Listening Session Summary 18 Horsley Witten Group, Inc.
March 30 , 2012 

# Category 3 : CCR Units for Reporting Detected Contaminants

The CCR rule requires water systems to list detected contaminants and to show corresponding Maximum Contaminant Levels (MCLs) and the level detected. The MCL must be expressed as a number greater than or equal to 1.0 and the level detected must be expressed in the sam e units [40 C.F.R. 141.153(d)(4)]. Under this category, three subcategories were created and five ideas or questions/sets of questions were created under the subcategories to capture the thoughts of the consuming public, drinking water systems, and primac y agencies. In all, approximately 90 responses were captured under this category.

**Subcategory** Units for Reporting Detected Contaminants

– Customers/Public Comments

Question/Idea: When looking at the Table of Detected Contaminants in the CCR would you find it difficult to understand, for example, an arsenic result of 0.029 mg/L (ppm) if the arsenic maximum contaminant level is listed as 0.010 ppm? Or would you prefer the conversion and the arsenic result reported as 29 ppb and the arsenic maximum contaminant level as 10 ppb?

Sixteen (16) commenters responded to these questions.

Most commenters (8) whole

- heartedly support reporting both MCLs and monitoring results in whole numbers, stating that it is much easier to understand whole numbers when quickly glancing through a document. The only caveat brought up was that whole numbers might give the false impression that there is a larger quantity of a
contaminant in the drinkin g water (4). For example, 29 ppb of arsenic seems like a larger amount of arsenic than 0.029 ppm of arsenic. One commenter suggested defining ppm as “1 drop in 100 gallons” and ppb as “1 drop in 100,000 gallons” so that people would understand that ppb i s a very small amount.

Two commenters were against reporting in whole numbers. These commenters felt that MCLs are typically presented in many information sources as either ppm or ppb, and that these units should be adhered to when reporting monitoring r esults in a CCR. These commenters were concerned that inconsistency in units across the various information sources could be just as confusing for consumers.

Other comments included:

• The numbers should be reported in the most commonly referred to units, because when customers receive the CCR they often start to research the contaminant on their own. If readily available materials discuss the contaminant in terms of one unit, this can create confusion if the CCR uses a different unit. The Rule should
al low for freedom in choosing appropriate units based on particular contaminants. (1)

• We should take this opportunity to standardize units and table formats so that CCR data can be electronically compared across water systems and states. This would serve o ur consumers and also be a significant research tool for the water industry. (1)

One consumer summed it up as: “As long as I see what the measurement was for my water along with a statement of the normal range and what is beyond the normal range, I don' t really care if the numbers are whole numbers or
not.”Listening Session Summary 19 Horsley Witten Group, Inc.
March 30 , 2012 Question/Idea: A water system measures total trihalomethanes (TTHMs) as 0.067 mg/L (ppm). The water system converts this number to appear as 67 ppb in your CCR or water quality report. The TTHM maximum contaminant level (MCL) is 0.080 mg/L (ppm). Does reporting the TTHM measurement as 67 ppb and comparing it to an MCL of 80 ppb provide more clarity than reporting the TTHM measurement as 0.067 mg/L and comparing it to an MCL of 0.080 mg/L?

Seven (7) people responded to this question.

Three commenters stated that CCR results should be reported in the same units as MCLs. Three commenters stated that reporting results in whole numbers leads the public to believe that there is actually more of a pa rticular contaminant in their water. One commenter stated that EPA is missing the mark by focusing on reporting units, since most people do not even know what the contaminants themselves are and how or why they are in their drinking water.



### Subcategory Units for Reporting Detected Contaminants

– Drinking Water System Comments

Question/Idea: Do you find the conversion process for certain contaminants to CCR units difficult? If yes, please elaborate what challenges you encounter.

Twenty

- six (26) commenters responded to this question.

One commenter mentioned that some of their smaller wholesale customers have needed assistance with conversions; however, most commenters (14) stated that conversions are not the problem, but that the conversions
do l ead to consistency issues. These include:

• Labs report results in inconsistent units that then have to be converted. (1)

• Conversions themselves are inconsistent (e.g., barium, copper, and aluminum must be reported in ppm, but all other metals must be repo rted in ppb). (1)

• Reporting for lead and copper is problematic since these are reported in different units. (2)

• Reporting results to consumers in more than one unit confuses them (i.e., 10 ppb of one contaminant appears to be more than 0.1 ppm of another contaminant). (8)

One commenter wished that states required reporting results to be in the same units as needed for the CCR, and that labs be required to report their results in those same units as well.

Another commenter stated that they were more co ncerned with how chemical names are reported and how inconsistent nomenclature can be very confusing for the public. One example this commenter gave was “nitrate,” which can be reported as N or as NO 3 . If reported as N, the MCL is 10 ppm; but, if nitrate is reported as NO 3 , the MCL is 45 ppm. Another example given was the use of “trichloroethene” versus “trichloroethylene.”

Ultimately, most commenters were more concerned with consistency rather than conversions. Another commenter
mentioned that the CCRi Writer is helpful with conversions, but expressed that CCR units should match MCL units. As one commenter summed it up: “Consistency is king.”Listening Session Summary 20 Horsley Witten Group, Inc.
March 30 , 2012 Question/Idea: Have you experienced problems with the current CCR unit conversion process? Do you receive calls from your customers regarding the CCR reporting units? Do customers have difficulty understanding the current CCR units?
Please elaborate.

Nineteen (19) commenters responded to these questions. Commenters are split in their opinions whether unit conversions are confusing to customers (6) or not (11). Of those receiving customer phone calls, issues included:

• The term “detected contaminant” causes alarm, even though it may only be a trace amount and well below an MCL. (1)

• Converting u nits to ppb in order to show a whole number leads many customers to believe that there is more of that contaminant versus if the result was reported in ppm. (5)

• Units of measurement are sometimes confusing for radionuclides. For gross beta (always report ed in pCi/L for an MCL of 4 millirems), this commenter provides an explanatory note in the table referencing 50 pCi/L as a regulatory level of concern. For combined uranium, this commenter prefers to report data and the MCL in ppb. This commenter also exp resses that some states (particularly NC) prefer or require reporting in pCi/L using an equivalent MCL of 20.1 pCi/L. This commenter adds a footnote to explain the equivalency of 20.1 pCi/L to the MCL of 30 ppb. (1)

Overall, of those experiencing custome r calls, commenters lament that there is not some easier way to enable the public to understand the difference between ppm and ppb. At least one commenter mentioned that using mg/L and ug/L (vs. ppm and ppb) in state regulations further confuses the publi c.



### Subcategory Units for Reporting Detected Contaminants

– State Drinking Water Program Comments

Question/Idea: We have been told anecdotally that the use of CCR units causes many conversion errors. Have you observed this in your state? If so, please provide us with further details. In addition, please provide any information regarding focus groups you have conducted within your state regarding CCR units.

Twenty

- four (24) commenters responded to this question.

Commenters had mixed views regarding this idea. Most (12) said that they had seen many conversion problems, especially among smaller sys tems. One commenter stated that in some cases, systems simply use the “traditional” units with no attempt at conversion. Only one commenter specifically stated that they did not have conversion problems in their state. Another commenter stated that EPA’ s convention of requiring all MCLs to be reported in state rules as mg/L is most likely the root cause of the problem. Other comments include:

• Choose a standard unit for use throughout the CCR. (2)

• Use the actual data that comes from the lab (which is reported in mg/L and ug/L). (2)

• CCR units should match MCL units. (4)

• Simplifying the numbers for the public through unit conversion is a good idea despite conversion problems. (5)

One commenter sugg ested two options to fix the perceived problem:Listening Session Summary 21 Horsley Witten Group, Inc.
March 30 , 2012 “1) Standardize MCL and CCR units to be the same unit of measure and such that the reporting level would be expressed as a number greater than or equal to 1.

2) Standardize the CCR units such that they are all expressed in parts per billion to allow the public to gauge the relative difference between contaminants commonly expressed in ppm and ppb.”

Still, others stated that CCRs should not be “dumbed down” and that they should be “consistent with the very

p rominent MCLs, sample results etc.” In addition to conversion errors, one commenter noted that calculating and reporting averages also seemed to be a problem, especially for TTHMs/HAA5s.

In reference to focus studies, the New Jersey Department of Environ mental Protection (NJDEP) responded that NJ conducted a series of studies about the time the CCR rule was being discussed and adopted. In one of those studies, a survey was conducted of 269 water system customers to gauge their reaction to whole versus de cimal numbers. Overall, there was little difference, although the whole

- number respondents were more likely to report
“This is information I can use”.Listening Session Summary 22 Horsley Witten Group, Inc.
March 30 , 2012 

# Category 4 : CCR and Tier 3 PN Relationships

Community water systems may use the CCR to meet Tier 3 public notice requirements (both initial and repeat notices) as long as it is provided to customers no later than 12 months after the system learns of the violation [40 C.F.R. § 141.204(d)]. Under this category, two subcategories were created
and four i deas or questions/sets of questions were created under the subcategories to capture the thoughts of drinking water systems and primacy agencies. In all, approximately 60 responses were captured under this category.

Subcategory
Use of CCR to Meet Tier 3 PN

– Drinking Water System Comments

Question/Idea: Do you include Tier 3 PNs in your CCR? What are some challenges you encounter with including a Tier 3 PN in your CCR? What recommendations would you make to allow for your system to take better advantage of this option (e.g., change in Tier 3 PN delivery time requirement length to longer than 12 months)? If you don’t include Tier 3 PNs in your CCR, why?

Twenty

- six (26) commenters responded to these questions.

Many commenters (20) expressed that they appreciated being able to report Tier 3 violations within the CCR. However, many (11) wished that the delivery timeframe for a PN could be extended such that all Tier 3 violations within one calendar year could be captured in the CCR; one commenter suggested a reporting window of 18 months. Another sugg ested instituting a “Monitoring and Testing Violation” section of the CCR and eliminating the Tier 3 PN requirement all together.

Comments include:

• Minor monitoring and reporting violations probably aren't worthy of a separate PN. Therefore, integrating them into a CCR section is an excellent idea. (1)

• Having the flexibility to include Tier 3 PNs on the CCR is an excellent way to distribute that information without adding to costs. The timeline of delivering the Tier 3 PN should reflect the due date of the CCR so that all Tier 3 PNs required since the previous CCR can be included on the next CCR. (1)

• Tier 3 PNs relate to situations that are determined to have minimal potential public health impacts. The CCR is a good way to provide this type of informa tion without unduly alarming customers. (1)

• I feel the current PN distribution timeline for a Tier 3 notification is a joke. What is the point of informing your customers of an incurred violation up to 12 months after it happened? I think the PN distrib ution timeline for Tier 3 Violations needs to be more in line with that of a Tier 2, or maybe 60 days at the most, so that the folks get the information in a timely manner. In the 3 years I have been in charge of the CCR Rule, I have not had any community use the CCR to distribute their Tier 3 PN. (1)

One commenter mentioned that their water system will be including a Tier 3 PN in their CCR because a system that they purchased water from failed to collect a well sample when another water system customer reported a positive coliform result to the water seller. The commenter noted that this would be a challenge to explain to customers since their own water system was not affected (i.e., no positive coliform results).Listening Session Summary 23 Horsley Witten Group, Inc.
March 30 , 2012 Question/Idea: Systems may only use the CCR to meet a Tier 3 PN requirement if the CCR is provided to persons served no later than 12 months after the system learns of the violation or situation. Have you experienced not being able to include a Tier 3 PN in a CCR? If yes, please explain fu rther.

Five (5) commenters provided feedback on this topic.

Most (3) noted that the 12

- month reporting window is the biggest obstacle in reporting all Tier 3 PNs in the CCR. However, most (3) wanted this reporting option to remain for varying reasons. One commenter stated that they do
not use the CCR as the sole distribution mechanism for a Tier 3 PN.



### Subcategory
Use of CCR to Meet Tier 3 PN

– State Drinking Water Program Comments

Question/Idea: When a system elects to use their CCR to meet a Tier 3 PN requirement the entire notice should be included in the CCR no later than 12 months after the system learns of the violation. Please describe any situations you’ve observed where Tier 3 PNs are not being implemented correctly in relation to the C CR?

Fifteen (15) commenters provided feedback on this topic.

It appears that the main challenge states are seeing is that not all water systems understand the different distribution and content requirements in the CCR Rule versus the PN Rule. For exa mple, one state notes that water systems describe the violation briefly in the violations section of the CCR, but do not necessarily include all of the necessary PN information. In this situation, the state calls the systems and relays the problem and the systems must redo their CCRs to include the necessary language. Although it is not clear from the comment, it is assumed that in this state one can use the CCR to report a Tier 3 violation and not issue a separate PN.

Another commenter notes that water systems face a “dilemma zone” when a violation occurs late in the Spring. In this situation, it is too late for the system to include the Tier 3 PN in the soon

- to

- be

- issued CCR, yet the system will
not meet the 12

- month reporting requirement if it includes the PN in next year’s CCR. However, at least one state allows water systems to report Tier 3 monitoring and reporting violations in the CCR so long as they occurred in the same calendar year of that particular CCR. Th is state is not concerned whether these violations are reported within 12 months or less. In their words “Are we going to require them to do a PN for a PN violation on a M/R violation that occurred over a year ago...I don't think so!”

To alleviate these issues, states suggest a variety of approaches:

• Attach the Tier 3 PN to the CCR or include all information required for a Tier 3 PN in the CCR as well. (3)

• Allow posting of a Tier 3 PN in the very next CCR, regardless of the 12

- month requirement. (3)

• Eli minate Tier 3 PN requirements and instead integrate a monitoring and reporting violation section into the CCR. (1)

This topic also brought up another issue for some states, that of reporting significant deficiencies that are still
uncorrected as of the e nd of the calendar year covered by the CCR. One state already requires such reporting and agrees that this should be clearly noted in CCR guidance.Listening Session Summary 24 Horsley Witten Group, Inc.
March 30 , 2012 Question/Idea: Please describe state resources used to track Tier 3 PNs as separate notices in comparison to Tier 3 notices reported in CCRs.

Twelve (12) commenters provided feedback on this topic.

More than one state (4) mentioned that they use the same resources and procedures to track PNs, regardless of whether the PN is distributed separately or as part of the CCR. One commenter mentioned that some states require CWSs to notify their consumers twice, once at the time of the violation and again in the CCR. Howe ver, this makes some states feel that they then have twice the work to track the reporting of this single violation. One state specifically commented that “We just have to remember to check the CCR for any possible PNs. This is very time consuming as we have one person that handles the CCRs unless there is a GWR violation or Significant Deficiency. There is a second person that handles that portion”.

A variety of tracking methods were mentioned, including:

• Manually checking CCRs for PNs (3)

• SDWIS Compli ance Decision Support (CDS) module (1)

More than one state noted the resource burden of manually checking CCRs for Tier 3 PNs, and the state using SDWIS CDS noted a burden in terms of issuing violations. Another state mentioned that tracking whether a Ti er 3 PN deadline was met is problematic, and that it was essentially too much work to both track and issue “retro
violations”.Listening Session Summary 25 Horsley Witten Group, Inc.
March 30 , 2012 

# Category 5 : CCR Certification Requirements
The CCR Rule requires systems to submit a certification that the CCR has been distributed to customers, and that the information is correct and consistent with the compliance monitoring data previously submitted to the primacy agency by three months following the date the system is required to distribute the report [40 C.F.R. 141.15 5(c)]. Under this category, one subcategory was created and three ideas or questions/sets of questions were created under the subcategory to capture the thoughts of primacy agencies. In all, approximately 50 responses were captured under this category.

Subcategory
CCR Distribution Certification

– State Drinking Water Program Comments

Question/Idea: Please list suggestions to streamline the CCR distribution certification process and meet the oversight function.

Twenty

- three (23) commenters provided feedback on this topic.

The issue raised most often by commenters was the submission deadlines for both the CCR and the CCR delivery
certification.

• Some states require delivery of the certification by July 1 st or July 10 th instead of October 1 st (presumably making tracking of the certification easier as it occurs coincidental with the state receiving the water system’s CCR). (3)

• Some water systems (under requirement or voluntarily) deliver both the CCR and the CCR certification together for a July 1 st deadline, which makes the tracking process easier for the state. (7)

• Many mention that a 90

- day timeframe for the certification delivery is too long, causing water systems to forget and therefore receive violation notices. (7)

• A few commenters support the idea mentioned during the webinar that retaining a copy of the CCR certification form on file at the water system for review at the Sanitary Survey Records Review (or upon request) satisfies the certification process and reduces the cost and bu rden to both the water systems and the state drinking water program staff. (3)

Other specific suggestions include:

• Coordinate the deadline with the 10th of some month so that the certification could be received at the time of other monthly reporting.

• It would be helpful if the submittal deadlines for both the CCR and the certification were the same.

It would be very helpful if EPA would develop an application for Drinking Water Watch that would generate a fully compliant CCR for systems, along with an op tion to certify that the report was delivered to the customers, and have that information imported into SDWIS, thereby closing the compliance schedule for the certification requirement.Listening Session Summary 26 Horsley Witten Group, Inc.
March 30 , 2012 Question/Idea: Please describe your state’s certification process.

Sixteen (16) commenters responded to this question. Commenters from different states offer their opinions of the certification process with mixed feelings about timing and effort for submitting and delivering both the CCR and the CCR certification, these are the comments:

• The process is simple which in most cases requires physical mailing or emailing a filled form or copy of the CCR to agencies for review. Some assure the system is easy to maintain. (4)

• The process is rather time consuming and there is a duplication of effort of tracking the CCR submission and the certification which can be a burden for staff labor and taxpayers. (2)

• Some States encourage waters systems to submit certification at the same time as the CCR is submit ted to the State. (4)

• It would be beneficial to change timeline for submittal of the CCR and certification, allowing water systems track the delivering once.

• Online reporting is supported by some states. (2)

Question/Idea:
Please describe the state resources required to implement the delivery certification requirement.

Seven (7) commenters provided feedback on this topic.

Those who offer comments for this question provide different explanations on how the resources are used to implement the delivery certification requirement and suggest ideas on ways to improve the process.

• While the CCR Rule only requires a certification that the report was distributed to customers and that the information is correct, Michigan adopted and edited the EPA certification template. This includes the method and date of delivery to the different recipients, internet address, and the efforts to r each non

- bill paying consumers. This tracking process is maintained in a database. (2)

• Having a separate certification requirement increases the workload.

• In Washington, D.C., one person is responsible for issuing annual guidance and tracking the recei pt of the CCR submissions, whereas the technical review is the duty of a second person.

• Washington relies on a database to log the CCRs as they come in. The CCRs are reviewed and logged, then
are accessible for the staff. A follow

- up is conducted for sys tems that do not comply with deadlines.

• In Iowa, a sheet is mailed in March by the primacy agency indicating the probable contaminants that should be listed in the CCR. A required return sheet is included with some questions for the community, which
unfo rtunately does not receive responses very often (according to the commenter).

• One commenter describes the process as an administrative burden that has very limited value.Listening Session Summary 27 Horsley Witten Group, Inc.
March 30 , 2012 

# Category 6 : Other
In addition to the five categories above, a new category was created to capture “other” responses. Three ideas/questions were entered by users as part of the “Other” category. In addition to these three ideas/questions, a total of eight responses were captured under this category. Commenters provided their views on simplifying CCR detect tables, including the location of water sources in the CCR, and using the CCR for non

- transient non

- community (NTNC) water systems to satisfy the Lead and Copper Rule Short

- Term Revisions (LCR

- STR) public awareness reg ulations.

Subcategory
CCR Detect Table Recommendations Comments

Question/Idea: We believe consumers do not understand the various “detect” table elements (MCLG, level detected, range of detections, and 90th percentile value). They do not understand how compliance is determined and why it is determined differently for each parameter. It’s difficult for a consumer to understand why a system is in compliance when a range number exceeds the MCL.

We suggest that EPA consider either of our two following options:

Option 1: Eliminate all detected results tables and require the water supplier to complete one of the following

statements: 1. Our water meets all of the drinking water standards. Here’s a list of the substances that are meeting the
d rinking water standards. (Insert a list all contaminants that met drinking water standards) 2. Our water did not meet all of the drinking water standards. We failed to meet the standard for (insert contaminant name). (Insert health effects language for c ontaminants that exceeded MCL, MRDL, or TT). We are taking the following corrective actions to meet this standard. (Insert corrective actions) If you have questions about drinking water standards, please call us at XXX

- XXX

- XXXX or send us an e

- mail at: (i nsert website address).

Option 2: Simplifying the Detect Table Elements in the following ways: 1. Remove the requirement to convert units and associated values to numbers greater than 1. Instead, report detected results, MCLs, MRDLS, and action levels w ith the values and units that are reported by the lab. 2. Eliminate the MCLG reporting requirement. 3. Define the range of values as the range of compliance values not individual results. For instance, if a running annual average value is the “level detec ted”, the range should be the lowest and highest running annual average too. A range should never include a higher value of an individual sample result than the value used to determine compliance with the standard. 4. Eliminate the requirement to report r aw source water detects since it can mislead the consumers because these contaminants are removed or inactivated by treatment. The detect tables represent finished water that is consumed not raw water that requires treatment. We recommend eliminating all raw water contaminant reporting requirements such as positive source water total coliform results, Cryptosporidium, and total organic
carbon.

One (1) commenter provided the above options for simplifying CCR detect tables. Three additional commenters provided suggestions on the above options.

Suggestions on Option 1 include:Listening Session Summary 28 Horsley Witten Group, Inc.
March 30 , 2012 • Simplify reporting

– For example, water systems could note how many substanc es were tested for (possibly by category) for each contaminant and reporting how many met drinking water standards.

• Do not provide a list of all contaminants for which a system is in compliance. That would be excessive.

Suggestions on Option 2 include:

• C onvert reporting limits to be greater than one

– This makes the magnitude of the detection appear greater than it is. For example, if the amount detected is .00032 ppm, that's a pretty small number and should be explained to be such.

• Simplify the CCR to m ake it more meaningful. The current requirement of reporting all detects is confusing, as most consumers assume any detect is a health hazard. (2)



### Subcategory: Location of Source Comments

Question/Idea: With all the recent emphasis put on keeping our water systems secure why are we putting the location of our
sources in our CCR.

Two (2) commenters responded to this question.

• One commenter stated that systems are able to give general location for a water source. For example, some states, such as North Carolina, do not require that GPS locations for water sources be included on a
CCR. This same commenter also noted that benefi ts of notifying people about the location of their water sources outweigh the risks of actions which threaten those sources.

• Another commenter noted that it is important to know the location of water sources to protect aquifers and also have that knowledg e if natural gas drillers are looking to drill in vulnerable areas of the watershed.



### Subcategory
NTNC CCR Comments

Question/Idea: Has anyone used a CCR for non

- transient non

- community (NTNC) public water supplies to satisfy the LCR

- STR public education/consumer awareness regulations?

Three (3) commenters responded to this question.

One commenter responded to indicate whether or not a CCR was used for NTNC public water supplies to satisfy the

LCR

- STR public education/consumer awareness regulations. This response is included below.

• Yes. We received CCRs submitted from the NTNC systems and filed those with all other CCRs, but are not required to do so in North Carolina. One commenter noted that the translation of a CCR into other language s can be challenging for water systems.

Another commented suggested a requirement change whereby the CCR would include a list of primaries above the detection limit to mean the reportable detection limit, rather than listing the laboratory detection limi t.