Listening Session Summary 1 Horsley Witten Group, Inc.

March 30, 2012

Idea/Question Comment 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, as well as health effects 

information related to violations of the drinking water standards. 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 retrospective 

review process consists of gathering stakeholder input. This promotes greater 

transparency and public participation in protecting the nation's drinking water. It also

promotes participation and the open exchange of information. To gather this input, EPA 

created http://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 

February 23 to March 9, 2012.

This summary describes comments and responses posted to the portal for the six 

categories and 37 ideas/questions listed below. As of the closing date, the portal had 697 

created accounts as described in the table below.

Commenter 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 members submitted comments 

(about a 27% participation rate). In total, approximately 630 comments were received, 

read, 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 communication 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 consuming 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 alternative delivery methods, 

the advantages and disadvantages 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 preferred 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 utilities 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 customers 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 

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)

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 rather 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).
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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 method? Some methods to consider are: hard-copy mailed to my home; e-mail with a PDF of the report; email 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-water 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 it 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 attachments 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 thousands 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 effective 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 and 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 information 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 1st deadline does not allow 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)
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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., emailing 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 1st, 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. Those 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 problems 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. 
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March 30, 2012

Other challenges mentioned include: 

• Lack of internet access – Many 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 customers. (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 document 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 advantages:

• 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 like 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 Association (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 would 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 provide 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 delivery. (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 challenges 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 maintaining 

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 delivery 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 postcard 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 

information.

• Yes, all customers. (0)

• Yes, some customers. (8)

• Yes, 50 percent of customers. (1)

• No, none. (5)
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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 bills, 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 

addresses. 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 addresses 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 than 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 multiple 

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 a 
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March 30, 2012

mailed CCR in the past year. Of that number, only about half (less than 21% of customers) 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 even 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 http://www.amwater.com/ensuring-waterquality/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 their 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 the 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 provided 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 implementing 

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 start 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.
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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 with 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 and 

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 commenter 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 this 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 indicate 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.
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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 allow 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 options 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 paper 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.) associated 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 water 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 under 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 video 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, statements 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); water 

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 exceeded. (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 results 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 excessive 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 permitting 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, including 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: communicating 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 rather 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 many 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, rather 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 out 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 activities 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, there 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 language 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 the 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/infrastructure/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 webbased 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 same 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 primacy 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 drinking 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 is 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 results 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 

allow 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 our 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 particular 

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 lead 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 reported 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 concerned 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 NO3. If reported as N, the MCL is 10 ppm; but, if nitrate is reported as NO3, 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 units 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 reported 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 expresses 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 customer 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 public.

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 systems. 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 suggested 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 

prominent 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 Environmental 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 decimal 

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 ideas 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 suggested 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 information 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 distribution 

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 further.

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 CCR?

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 example, 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. This 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)

• Eliminate 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 end 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. However, 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 Compliance 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 Tier 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. 141.155(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 1st or July 10th instead of October 1st (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 1st 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 burden 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 option 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 submitted 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 reach 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 receipt 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 systems 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 

unfortunately 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 regulations.

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 

drinking 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 contaminants 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: 

(insert 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 with 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 detected”, 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 raw 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 substances 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:

• Convert 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 make 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 benefits 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 knowledge 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 languages 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 limit.