Market Research for the Retrospective Review of the 

Consumer Confidence Report (CCR) Rule

Table of Contents

1.0 INTRODUCTION .............................................................................................................. 1

1.1 Retrospective Review of the CCR Rule.................................................................. 1

1.2 Purpose of this Paper .............................................................................................. 2

2.0 CURRENT METHODS OF ELECTRONIC DELIVERY IN THE WATER INDUSTRY ............. 3

2.1 Case Study: The York Water Company................................................................. 3

2.2 Case Study: North Wales Water Authority............................................................ 5

2.3 Case Study: Iowa State University – Ames, Iowa ................................................. 6

2.4 Case Study: Military Installations – Washington, D.C.......................................... 7

2.5 Case Study: DC Water – Washington, D.C. .......................................................... 7

2.6 Case Study: American Water – Voorhees, NJ....................................................... 8

3.0 ELECTRONIC DELIVERY IN SIMILAR INDISTRIES.......................................................... 9

3.1 Case Study: Stormwater......................................................................................... 9

3.2 Case Study: Wastewater ...................................................................................... 11

3.3 Case Study: Public Safety and Community Right-to-Know................................ 12

3.4 Case Study: Energy.............................................................................................. 13

3.5 Case Study: Additional Industries ....................................................................... 14

4.0 ELECTRONIC DELIVERY IN THE WATER SECTOR IN OTHER COUNTRIES................. 15

4.1 Case Study: United Kingdom .............................................................................. 15

4.2 Case Study: Australia........................................................................................... 15

5.0 RECOMMENDATIONS FOR TRANSITION TO E-DELIVERY............................................ 16

6.0 SUMMARY ..................................................................................................................... 17

7.0 REFERENCES ................................................................................................................ 19
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1.0 INTRODUCTION

The Consumer Confidence Report (CCR) rule, which was promulgated by the U.S. 

Environmental Protection Agency (EPA) in 1998, requires community water systems to prepare 

and provide annual CCRs to their customers which detail the quality of the water delivered by 

the systems. These reports provide valuable information to customers of community water 

systems and allow them to make personal health-based decisions regarding their drinking water 

consumption. The regulation requires each community water system to mail a CCR to each 

customer of that system at least once annually by July 1st.

These reports are the centerpiece of the public right-to-know regulation in the Safe Drinking 

Water Act (SDWA). The purpose of the information contained in CCRs is to raise consumers' 

awareness of where their water comes from, help them understand the process by which safe 

drinking water is delivered to their homes, and educate them about the importance of 

preventative measures, such as source water protection, that ensure a safe drinking water supply. 

CCRs can promote dialogue between consumers and their drinking water utilities, and can 

encourage consumers to become more involved in decisions which may affect their health. The 

information in the reports can be used by consumers, especially those with special health needs, 

to make informed decisions regarding their drinking water. Finally, CCRs are a key that can be 

used to unlock more drinking water information. They provide access, through references and 

telephone numbers, to source water assessments, health effects data, and additional information 

about the water system. The regulations specify specific language which must be included in 

every CCR and additional regulations are applied to community water systems of different sizes. 

1.1 Retrospective Review of the CCR Rule

As part of Executive Order 13563, Improving Regulation and Regulatory Review, signed by 

President Barack Obama on January 18, 2011, EPA is exploring new ways to promote greater 

transparency and public participation in protecting the Nation’s drinking water. It can be 

burdensome and costly to water systems and states to mail out and otherwise post the CCR. As a 

result, there have been several congressional bills introduced which aim to reduce the paperwork 

requirement of the CCR. The U.S. Senate introduced the S. 1578: End Unnecessary Mailers Act 

of 2011 and the U.S. House of Representatives introduced the H.R. 1340: End Unnecessary Costs 

Caused by Report Mailing Act of 2011. Both bills would amend the SDWA to give community 

water systems (for which there were no violations of the maximum contaminant level for any 

regulated contaminant during the year) the option to: 

• Mail the annual CCR to each customer (as required under current law); or 

• Make such report available on the system's website and, upon request, by mail. 
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If the latter option was chosen, the system would have to notify the customers that the report is 

available to view and that the system has remained in compliance. Bill S. 1578 includes 

additional draft language which states that the notification can be made in the same way that the 

customer pays their bill (e.g., customers who pay their bill electronically would receive an email, whereas customers who pay their bill by mail would receive a notice in the mail).

During the development of EPA’s Retrospective Review Plan (2011), stakeholders noted that 

there has been a major increase and diversity in communication tools since 1998 when the CCR 

rule was promulgated. EPA is reviewing the CCR rule to look for opportunities to improve the 

effectiveness of communicating drinking water information to the public, while lowering the 

burden to water systems and states. One method suggested by water systems would allow 

electronic delivery of the CCR through e-mail, thereby reducing mail fees and possibly 

improving the readership of CCRs. The CCR retrospective review will consist of a process of 

stakeholder input on all identified issues and analysis of industry surveys and studies on 

electronic delivery mechanisms. 

1.2 Purpose of this Paper

The purpose of this paper is to provide a synopsis of market research conducted on the process of 

electronic delivery of product(s) similar to a CCR report in similar industries. The report will 

explore methods of electronic delivery that are currently being utilized in the water industry, 

discuss electronic delivery in similar industries, electronic delivery in the water industry in other 

countries, and provide recommendations for the potential transition to electronic delivery of a 

CCR. A series of case studies and examples will be described based on an assessment of the 

following characteristics:

• Size and type of utilities involved;

• Communication methods;

• Utility benefits of electronic delivery;

• Program successes and lessons learned; and

• Ideas to consider for CCR e-delivery.

Overall, the goal of this document is to determine what components of various industry programs 

could be utilized in a transition towards electronic delivery in the water sector taking into 

account successes and drawbacks in other programs. A summary is provided that includes initial 

recommendations on potential transition strategies developed from this assessment. This 

analysis will form the foundation for the development of a strategy for a potential transition to 

the electronic delivery of a CCR.
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2.0 CURRENT METHODS OF ELECTRONIC DELIVERY IN THE WATER 

INDUSTRY

As the number of available communication options has increased since the CCR rule was 

promulgated in 1998, water utilities across the nation are currently utilizing electronic 

correspondence to keep their customers better informed about their drinking water. The main 

goals of a utility with regards to a CCR are to ensure that customers understand where their 

drinking water comes from and to ensure that customers have access to their CCR. The 

following section will describe how some states have already begun the electronic delivery of 

CCRs and ways that water utilities have transitioned towards the electronic delivery of other 

information to their customers (e.g., billing, public outreach).

In 2010, the Pennsylvania Department of Environmental Protection (PADEP) began allowing

water suppliers to use e-mail as a form of direct delivery for public notices and also subsequently 

allowed water suppliers to e-mail their CCRs to customers who have provided the utility with a 

valid e-mail address. In the event that a customer has not provided the utility with an e-mail

address, then the CCR must still be mailed through the U.S. Postal Service to the customer.

The PADEP guidance on CCRs, which includes references to email delivery, can be found at the 

following websites:

• Groundwater systems: http://www.elibrary.dep.state.pa.us/dsweb/View/Collection-8852

• Surface water systems: http://www.elibrary.dep.state.pa.us/dsweb/View/Collection-8851

Since the change in CCR guidance, several utilities in Pennsylvania now distribute CCRs to 

customers who have registered their e-mail address with the utility. The following subsections 

are case studies which describe how water systems are utilizing electronic delivery to 

communicate with their customers.

2.1 Case Study: The York Water Company 

The York Water Company (YWC) provides drinking water to 180,000 customers (65,000 

accounts) in York and Adams Counties in Pennsylvania. Approximately three years ago, YWC 

began the transition towards electronic billing, phone billing, and paperless billing. At the same 

time, they were looking for ways to cut costs but still achieve their goal of having an informed 

customer base (J.T. Hand, personal communication, January 20, 2012).

In April 2010, YWC started collecting e-mail addresses through its “Tap Tip” Campaign. This 

campaign involves sending out a bill stuffer with various public messages or “tap tips” (e.g., 

conservation information, frozen pipe prevention) and includes a section where customers can

provide emergency contact information as well as their e-mail addresses. This initiative 
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collected over 6,000 e-mail addresses, which covers about 10% of their customer accounts. As a 

result of the decision by PADEP to allow water utilities to send out CCRs by e-mail to customers

with a valid e-mail address, a pilot study was undertaken in 2011 which utilized the e-mail

addresses collected through the “Tap Tip” Campaign to distribute the 2010 CCR electronically. 

Customers who receive their CCR electronically either receive their bills electronically or have 

provided their email addresses to the utility to receive communications electronically (J.T. Hand, 

personal communication, January 20, 2012).

YWC typically sends out their CCRs for the previous year in early February, with a goal of 

distributing the CCR not later than February 15th of each calendar year. To ensure that all 

customers received the CCR on the same day, the CCR was mailed to customers the day before 

the e-mail was sent to the remaining customers. In February 2011, approximately 6,000 

customers were sent their CCR by e-mail rather than by regular mail, using the e-mails collected 

through the “Tap Tip” campaign. YWC hired a third party vendor to send the e-mails as their 

computer systems could not manage sending out this volume of e-mails at one time. The 

company’s internal Information Technology (IT) Department estimated that it would have taken 

14 hours to send approximately 6,000 emails. Each e-mail contained a link that the customer 

could click on to access the CCR on the YWC website (www.yorkwater.com), since it was 

decided that the e-mail would be too large to send if the CCR was attached as an electronic 

document. The selected third party vendor tracked who received the e-mail, who opened it, and 

who clicked through to the CCR on the website (J.T. Hand, personal communication, January 20, 

2012).

On Friday, February 4, 2011 at 6:00 pm, the third party vendor sent 5,922 e-mails. Of those, 

5,194 (or 87.7%) were delivered and the balance of the e-mails (728 or 12.3%) “bounced.” Of 

the 5,194 e-mails delivered, 35% or 1,822 customers opened the e-mail. Of those 1,822 

customers, only 11% or 207 unique customers clicked through the links to access the CCR. 

Therefore, the actual penetration rate for the e-mail delivery of the CCR is 207 unique views out 

of 5,194 e-mails or about 4%. This initially was a disappointment to YWC, but it is believed that 

the paper version likely achieves the same penetration rate. Of the 728 e-mails that bounced, 

most occurred because the customer e-mail account blocked the delivery of the message, the email address was no longer active, or the e-mail address was invalid. In the event of a bounced 

email, a paper copy was sent to the customer upon request. Also, a percentage of email 

addresses were listed incorrectly in the system and after they were corrected, the CCR was resent 

electronically (J.T. Hand, personal communication, January 20, 2012).

According to the Direct Marketing Association’s (DMA) 2010 Response Rate Trend Report, 

which is released yearly to detail the typical response to a direct marketing campaign, an email to 

a house list (a list of buyers and prospects maintained by a company) averaged a 19.47% open 

rate, a 6.64% click-through rate, and a bounce-back rate of 3.72%. These numbers are 

comparable to those seen by YWC as shown in the following table: 
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YWC Statistics DMA Statistics

Email Open Rate 35% 19.47%

Click Through Rate 11% 6.64%

Bounce-Back Rate 12.3% 3.72%

Response rates for direct mail are on the same order of magnitude. For example, letter-sized 

envelopes had a response rate in 2010 of 3.42 % for a house list. While it is not a direct 

comparison (mailed hard copy CCRs do not require a response and therefore a response rate 

cannot be determined), YWC’s assumption that a paper CCR achieves about the same 

penetration rate as an e-delivered CCR appears reasonable. 

YWC’s e-delivery process took the third party vendor less than ten minutes to complete at a cost 

of approximately $0.0155 per e-mail. The cost of mailing a CCR is approximately $0.75 per 

CCR, so this represents a very substantial savings to YWC (approximately $4,350). Overall, this 

first year of using e-mail delivery benefitted the customers, the company, and the environment 

through the reduction of paper, reduced production and postage costs, and ensured timely 

delivery to those customers who received the CCR by e-mail (J.T. Hand, personal 

communication, January 20, 2012).

In preparation for e-mailing the CCRs in 2012, YWC has taken steps to increase the number of 

e-mail addresses that they have on file for customers. The “Tap Tip” campaign is continuing,

and whenever a customer contacts customer service, one of the first things they are asked for is a 

valid e-mail address and if they would like to receive information electronically. YWC 

anticipates distributing approximately 8,000 CCRs by e-mail on Friday, February 10, 2012

through the third party vendor and will be collecting the same statistics as the previous year (J.T. 

Hand, personal communication, January 20, 2012).

2.2 Case Study: North Wales Water Authority

The North Wales Water Authority (NWWA) serves over 25,000 customers in seven 

municipalities in two counties in southeastern Pennsylvania. The NWWA has established a 

contract with a third party vendor to contact all customers via telephone during required public 

notification situations. Using this service to notify customers for public notification

requirements has been successful and NWWA began to initiate additional customer contacts. 

For example, when water main flushing is scheduled, advertisements are placed in several 

newspapers, but sometimes schedules need to be adjusted and require re-advertising. NWWA

uses the vendor to notify those customers in the area of the main (T. Bradbury, personal 

communication, January 19, 2012).
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The service is also used to deliver CCRs by e-mail to the approximately 8,300 customers (1/3 of 

the customer base) that receive e-mail delivery of their water bills. The collection of customer emails has been accomplished in several ways. NWWA includes a form with water bills that 

requests a customer’s e-mail address if they have one, customers can register their e-mail online,

or they can send e-mail delivery requests directly to NWWA. CCRs are distributed 

electronically to the customers via an email attachment in Adobe Portable Document Format 

(PDF) as NWWA believes it is more convenient for their customers to be able to open the CCR 

immediately without instructions, as opposed to directing them to a website. The Adobe PDF is 

approximately 1 MB in size. The delivery rates of 2010 and 2011 CCR are shown in the table 

below:

Year of CCR Date Sent Emails Delivered Emails Percent Delivered

2009 6/03/2010 7,981 7,031 88%

2010 5/20/2011 8,250 7,237 88%

As the CCR is attached directly to the email, the NWWA can assume that 88% of their 

customers are receiving the CCR, and NWWA has received positive feedback from customers 

(T. Bradbury, personal communication, January 19, 2012).

NWWA has found that the use of e-mail to distribute the CCR has been financially beneficial as 

the costs associated with producing the hard copy of the CCR (e.g., printing, processing and 

mailing) are just over $1.00 per CCR. The vendor also provides a confirmation log to NWWA 

with information regarding how many e-mails are sent and how many of them are delivered. 

Initially, there were a few e-mails stating the CCR attachment could not be read, but issues have 

been resolved when they occur. The NWWA customer base has been described as educated and 

tech-savvy (T. Bradbury, personal communication, January 19, 2012).

2.3 Case Study: Iowa State University – Ames, Iowa

The City of Ames Water and Pollution Control Department serves almost 60,000 customers in 

Ames, Iowa, including Iowa State University (ISU). Only a very small percentage of their

customers have registered for electronic billing. As a service to the students at ISU, the City of 

Ames provides copies of the CCR and has received permission from the Iowa Department of 

Natural Resources (IDNR) to provide copies of the CCR to students by e-mail. The e-mail

provides a link to the City of Ames website where the CCR is posted at 

www.cityofames.org/water. The e-mail addresses for the students are provided by the ISU 

Registrars office free of charge. The City has not received negative feedback from the students 

as a result of distributing the CCR electronically. However, they receive a number of complaints 

each year, some from students, about how wasteful it is to print and mail the CCR (J.A. 

Roberson, 2011).
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One main benefit realized by the City to performing an electronic distribution of the CCR is that 

it is seen as a much "greener" alternative by their customers. Several customers who live in 

group housing (e.g., fraternities, sororities) and receive multiple CCR hard copies bring them 

back because they did not want them, but they also did not want to simply dispose of them. 

From a waste reduction stand point, distributing more CCRs electronically is seen as the best 

path forward for the City of Ames (J.A. Roberson, 2011).

2.4 Case Study: Military Installations – Washington, D.C.

EPA Region 3 has primacy over the Navy and Air Force bases in Washington, D.C. and allows 

the electronic delivery of CCRs at those bases. Every individual who lives and works on the 

bases in Washington, D.C. has a military e-mail address. This is considered a controlled 

variable, knowing that each e-mail address is valid and everyone will receive delivery. 

Therefore, EPA Region 3 allows e-mail as one of the approved methods for sending out the CCR 

and delivering other public notifications. The CCR is emailed as an Adobe PDF attachment to a 

memorandum from the commanding officer to the tenant organizations and residents. Paper 

copies of the CCR must also be available for those requesting them as well as for those visiting 

the base. As all personnel who live and work at the military installations are provided with an email address, it is assumed that the majority of those who consume the drinking water will 

receive the CCR (P.K. Wisniewski, personal communication, January 18, 2012).

2.5 Case Study: DC Water – Washington, D.C.

DC Water distributes drinking water to more than 600,000 residents in the District of Columbia.

DC Water customers have the option to set up an online account where they can access the 

following free services:

• Lead Service Line information – this includes electronic copies of letters that are mailed 

to customers following their household lead sampling;

• Online Billing – customers can pay their bill online and view their payment history; and

• Water Usage History – a unique feature of this section is that a customer can view their 

water usage and receive alerts if usage is above average. Alerts can be in the form of a 

phone call, email, or text message. 

It is estimated that out of 134,000 total customer accounts, approximately 14,986 unique users

(11%) have accessed their online account in December 2011, and similar trends in site visits 

occurred in the preceding months (S. Neiderer, personal communication, December 19, 2011).

With regards to the CCR, DC Water mails the document to all District postal addresses, 

including customers and non-customers. This represents a very large mailing and printing cost.
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The “My Account” feature that is available on DC Water’s website is one way the utility can

share the CCR with individuals. In addition, “My Account” users provide an email address 

when creating an online account, which could be used for electronic delivery of the CCR. While

only 11% of customers access the “My Account” feature, it may serve as an alternative to 

mailing the CCR and potentially reduce postage and printing costs. The “My Account” feature 

may also serve as a secondary delivery method for the CCR (S. Neiderer, personal 

communication, December 19, 2011).

DC Water is also actively using social media (e.g., Facebook, Twitter, LinkedIn) to communicate 

with customers as well. Those who are members or follow DC Water receive messages which 

encourage them to view water quality data among other items. A recent survey completed by 

Pike Research (2012) showed that almost 2/3 of respondents use social media, but only 11% of 

respondents who use social media regularly interact with their utility by this means. The number 

of customers using social media is expected to grow significantly and this is a communication 

medium that utilities may benefit from using in the future (S. Neiderer, personal communication, 

December 19, 2011).

2.6 Case Study: American Water – Voorhees, NJ

American Water provides drinking water, wastewater, and other related services to 

approximately 15 million people in more than 30 states, as well as parts of Canada. Each year, 

American Water sends out more than 3.25 million CCRs.

For the majority of their customers, the CCR is currently delivered as an insert into their bill as 

the report is light enough that it does not require extra postage. However, to keep the insert to 

the size needed to meet the weight restriction, American Water is not able to include much 

information beyond the mandatory language required under the regulation. This means that 

American Water is not able to include information related to water conservation, emerging 

contaminants research, and source water protection activities. American Water feels that this is a 

missed opportunity to instill confidence in the company and the water it provides (M. Corson, 

personal communication, January 17, 2012).

To increase customer access to water quality information, American Water posts all of their

CCRs to the Internet at http://www.amwater.com/ensuring-water-quality/water-qualityreports.html. They also created a “Basic Water Quality Summary” for each of their water 

systems that contains the water quality information for which customers most frequently contact

the Customer Service Center. Customers are able to access this information by entering either 

their city/state or their zip code online at American Water’s website listed above. Since these 

data are online, the information in the Basic Water Quality Summary can be updated quickly and 

easily as needed. 
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Given the space constraints and production costs (American Water spends over $250,000 a year 

in printing and mailing CCRs), American Water’s preferred approach for delivering CCRs would 

be to use the current online posting method and include a message and URL on the customer’s 

bill that indicates that the annual water quality report is available on the Internet. The company

would still provide hard copies of the CCR upon request, and would also likely develop a 

specific insert on water quality and the availability of the annual water quality reports, which is 

another opportunity for American Water to instill confidence (M. Corson, personal 

communication, January 17, 2012).

3.0 ELECTRONIC DELIVERY IN SIMILAR INDUSTRIES

Many similar industries also use varied electronic delivery methods to communicate information 

to their customers. The following case studies examine how other industries are utilizing 

electronic delivery.

3.1 Case Study: Stormwater

A combined sewer is a type of sewer system that collects sanitary sewage and stormwater runoff 

in a single pipe system. This type of sewer design is no longer used in building new 

communities, but many older cities continue to operate combined sewers. The greatest impact of 

discharges from a combined sewer overflow (CSO) is the health risks associated with bacteria in 

the untreated sewage and stormwater run-off. Bacteria levels in a river can rise for several days 

following a CSO discharge. In May 1995, the EPA Office of Water released a guidance 

document entitled “Combined Sewer Overflows: Guidance for Nine Minimum Controls.” It

describes the minimum technology based controls that can be used for CSO problems prior to the 

implementation of long-term control measures without extensive engineering studies or 

significant construction costs. 

The eighth minimum control is public notification. As described in the guidance, the measures 

selected to communicate with the public should be the most cost effective measures that provide

reasonable assurance that the affected public is informed in a timely manner. In addition to 

normal methods of notification (e.g., signage, letters, newspaper notices, phone calls), many 

municipalities are using their own websites and e-mail as a notification method as well. In 

several states, there are very robust CSO notification requirements and many locations have 

established customer opt-in systems where an interested party can sign up to receive alerts by email. Most utilities surveyed offer e-mail alerts in their jurisdictions as a service to interested 

parties and consulted with those stakeholders during the development of their notification 

systems. Therefore, the majority of those interested are receiving notifications of CSO 

overflows.
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The following describe the various ways that utilities across the country are incorporating 

electronic delivery into their CSO notifications. 

• Indiana Law (327 IAC 5-2.1) requires communities with CSOs to offer public 

notification when they are discharging. Over 100 communities in Indiana are now 

offering e-mail notification and the following are examples of how various communities 

use electronic delivery to notify their customers.

o Mishawaka is a city with a population of over 46,000 residents in Northern Indiana 

located next to South Bend. Customers can receive e-mail notification of a CSO into 

the St. Joseph River by the Mishawaka Utilities Company by registering their e-mail

address at the following site: http://mishawaka.csoalert.com/

o Speedway is a town of almost 13,000 residents located near Indianapolis in Marion 

County, Indiana. A customer can receive notification of a CSO discharge by sending 

a request to wastewater@speedwayutilities.org. 

o Hammond is a city with a population of over 80,000 residents located in the Chicago 

Metropolitan area. There are CSOs which occasionally discharge into the Grand 

Calumet River or Little Calumet River. Interested persons may request e-mail 

notification when CSOs are discharging by sending their e-mail address to the 

Hammond Sanitary District. 

• The Metropolitan Water Reclamation District (MWRD) of Greater Chicago includes 

approximately 160 municipalities and townships which are totally or partially within the 

boundaries of Cook County, an area which includes over 5 million residents. A website 

created as part of their CSO Notification Plan includes an option for interested parties to

register their e-mail address and cell phone number to receive an e-mail or text alert in 

the event of a CSO or diversion into a waterway. The alert contains a link to a system 

map which shows the impacted segment. Stakeholder meetings were held during the 

website development process and the majority of interested stakeholders were consulted 

and automatically added to the distribution list. Additional interested parties can register 

their information by visiting the website:

http://www.mwrd.org/irj/portal/anonymous/overview (A. Gronski, personal 

communication, March 28, 2012).

• Joliet, Illinois is a city of 146,000 people in Will and Kendall counties, located 40 miles 

southwest of Chicago. The City is developing an electronic “Address Book” containing a 

list of e-mail addresses of interested members of the public who will be able to sign up to 

receive e-mail notification of CSO events. More information can be found by visiting 

http://www.cityofjoliet.info/public-utilities/cso.htm.
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• SD1 is a sanitary and storm sewer utility with a service area that covers more than 220 

square miles and serves more than 100,000 customers in more than 30 municipalities and 

unincorporated portions of Boone, Campbell and Kenton counties in northern Kentucky. 

The utility started a watershed group to notify stakeholders in their service area of CSO 

overflow alerts and to provide newsletters. This group has grown to include many city 

organizations and mayors in the utility’s service area. Additional interested parties can 

register their personal information including their e-mail address to receive an e-mail

alert in the event of wet conditions which may cause a CSO overflow by visiting the 

following website: 

http://www.sd1.org/ProjectsandPrograms/WetWeatherOverflowPublicNotificationProgra

m.aspx (M. Scott, personal communication, March 26, 2012).

• Richmond, Virginia is a city of over 200,000 people where customers can receive e-mail

advisories when CSOs are discharging into the James River by subscribing to the free 

CSO PN mailing list at 

http://www.richmondgov.com/PublicUtilities/projectCombinedSewerOverflow.aspx

Jurisdictions have been able to choose which methods are the most appropriate for 

communicating with their consumers. The option for signing up for electronic delivery improves 

the timeliness of notifications and allows the utilities to reach more stakeholders including the 

ones who are most interested in receiving the information.

3.2 Case Study: Wastewater

The North Carolina Clean Water Act of 1999 (House Bill 1160) requires the owner and operator 

of any wastewater collection or treatment works to provide an annual report similar to the CCR 

to its customers no later than 60 days after the end of the calendar or fiscal year. The report must 

detail how a system operates, how well it performed during the year, what violations occurred, 

and other information. The alternate methods for distributing the report in addition to mail 

include: 

• Post a link to the annual report on the owner’s website in a easily accessible location.

• Include within the billing statement a notice of the annual report and how to obtain it (via 

website or phone number).

o The notice should be separate from the billing statement and stand out (different 

color).

• Publish a notice in all local papers of circulation advertising the annual report and how to 

obtain it.

o The published notice is to be provided to the Department of Water Quality (DWQ).

• Provide a copy of the report to the DWQ to be placed in the collection system’s permit 

file.
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Many wastewater utilities in North Carolina choose to post the annual report on their websites 

where anyone can access the information. An example of this is the City of Greensboro 

http://www.greensboro-nc.gov/index.aspx?page=2310. 

In addition, many wastewater utilities provide a Wastewater CCR as a public service to their 

customers. An example of this is the City of Ontario in New York.

3.3 Case Study: Public Safety and Community Right-to-Know

The Emergency Planning and Community Right-to-Know Act (EPCRA) of 1986, enacted as 

Title III of the Superfund Amendments and Reauthorization Act (SARA), was passed in the 

wake of the Bhopal disaster in India, where more than 2,000 people died as a result of an 

accidental release of a hazardous chemical. In order to prevent similar occurrences in the United 

States, EPCRA established a national framework to mobilize local government officials, 

businesses, and other citizens to plan for chemical accidents in their communities and required 

each state to create a State Emergency Response Commission (SERC). SERCs were charged 

with establishing Local Emergency Planning Committees (LEPCs), which provide a forum for 

first responders, state and local elected officials, emergency managers, industry representatives, 

hospital and public health officials, the news media, and the general community to work together 

and achieve local solutions. 

LEPCs use an “all hazards” approach by developing and maintaining emergency plans in case of 

an accidental release, and encourage continuous attention to chemical safety, risk reduction, and 

accident prevention in their communities. Because of their broad-based membership, LEPCs are 

able to foster a valuable dialogue within the community to prevent and prepare for accidental 

(and terrorist-related) releases of hazardous chemicals. According to a 2008 Nationwide Survey 

of LEPCs conducted by the EPA Office of Emergency Management, less than one-quarter 

(23.6%) of responding LEPCs have a website, with LEPCs that serve large urban populations 

with a greater history of accidents more likely to have a website. LEPCs most often report that 

radio/TV announcements (88.3%), fire/police departments going door-to-door (82.4%), and an 

emergency broadcast system (62.7%) are the mechanisms used to notify the public of a release 

requiring evacuation or shelter-in-place. Increasingly, many state and local emergency 

management agencies are utilizing e-mail and text messages to keep citizens informed.

In many states, local and state emergency management agencies have created a section on their 

website where members of the public can sign up to receive alerts of incidents and events in their 

community. 

• San Diego County Emergency Services, California has developed “AlertSanDiego” and 

residents can register their cell phone number, VoIP phone number, and e-mail addresses.

The county already has listed and unlisted landline phone numbers included in the 
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database. “AlertSanDiego” will be used by emergency response personnel to notify those 

homes and businesses at risk during an emergency with information on the event and/or 

actions (such as evacuation) officials are asking them to take. More information can be 

found at http://www.readysandiego.org/alertsandiego/.

• Wood County, West Virginia citizens can register their e-mail addresses at 

http://www.woodcounty911.com/ to receive information in the event of an emergency 

from the county’s Wide Area Rapid Notification (W.A.R.N.) system. 

• To improve information sharing in the National Capital Region, Capital Alert 

(www.capitalalert.gov) was created to distribute emergency alerts to the public in the 

Washington, D.C. area. From the website, people can sign up to receive emergency text 

message, email, or Really Simple Syndication (RSS) feed alerts from their local city or 

county governments.

Electronic Delivery provides another method of communicating with the public during an 

incident and may reach those who are not able to access alternate methods (e.g., landline phone, 

television, radio). Additionally, the EPA provides a host of websites that citizens can access to 

learn about toxic substances and hazardous waste in their community, including 

http://www.epa.gov/epahome/r2k.htm.

3.4 Case Study: Energy

Many energy companies are utilizing electronic delivery as a way to communicate with their 

customers. Depending on their supplier, customers can choose to access their account online and 

receive the information about their historical energy use as well. Many energy companies are 

utilizing the e-mail alerts to contact their customers in the event of power outages.

• National Grid provides gas and electricity services to customers throughout the Northeast

and customers can register their personal information including their e-mail address at the 

website http://www.myenergypages.com/national-grid-keep-informed-during-the-storm/

to receive alerts with safety tips, phone numbers, and outage and restoration information 

during a storm or other power outage.

• San Diego Gas and Electric (SDG&E) is a regulated public utility which provides energy 

services to 3.5 million people in San Diego and southern Orange counties in California. 

Customers can sign up for the Power Emergency Notification System (PENS) to receive 

warning in case of power emergencies, notification of system conditions and stage 

emergencies by e-mail or pager; see http://sdge.com/safety/outages/power-emergencynotification-system.
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Electronic delivery provides this industry with another method of communicating with the public 

during an incident and may reach those who are not able to access alternate methods (e.g., 

landline phone, television, radio) and keep them apprised of developments and expected service 

resumption.

3.5 Case Study: Additional Industries

There are additional industries which also encourage their customer base to use online services. 

• The banking industry is required by the Comptroller of the Currency Administrator of 

National Banks, a department in the US Department of Treasury to provide periodic 

statements for each monthly cycle in which an electronic fund transfer (EFT) has 

occurred. If no recent electronic fund transfers have occurred, the bank should send a 

periodic statement at least quarterly. 

To help meet these requirements, the majority of banks allow customers to sign up for 

online access to their accounts, and in some cases reward a customer for “going green.” 

Online banking also provides a number of other benefits for consumers:

o Convenience – customers can view, save and print their statements, without waiting

for them to arrive in the mail;

o E-mail Alerts – customers can receive notification automatically when their 

statements are ready to view; and

o Security – this option reduces the possibility of mail fraud through secure access to a 

customer’s account.

• Employer Retirement Savings Plans are governed by the Employee Retirement Income 

Security Act (ERISA) of 1974 which is a federal law that sets standards of protection for 

individuals in most voluntarily established, private-sector retirement plans. The plan 

must automatically provide a statement to customers detailing their account balance and 

vested benefits. Depending on the type of plan, the statement may also include the value 

of the investments in the account and information describing the right to direct 

investments at specified intervals. Many plans allow their members to provide an email 

address and opt into receiving their statements electronically.

• Customer Loyalty Programs allow a customer to have the option to register and manage 

their account online. This includes grocery stores, hotels, and frequent flyer programs,

among others.

• News Outlets allow individuals to register their e-mail address or cell phone numbers so 

that they can be informed of breaking news stories.
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4.0 ELECTRONIC DELIVERY IN THE WATER SECTOR IN OTHER COUNTRIES

Water utilities in some other countries are required to provide their customers with reports which 

detail their drinking water quality in much the same manner as the CCR. The following section 

describes what steps have been taken to inform the public in the United Kingdom (UK) and 

Australia. 

4.1 Case Study: United Kingdom

There has been a shift from providing water supply information in hard copy format to electronic 

formats.

The Water Supply (Water Quality) Regulations 2000 requires all water suppliers, under 

Regulation 36: Publication of Information, to publish an annual report which details their water 

system. The report is to be made public and provided to all local authorities that the water 

supplier serves for the public to review. 

According to the Drinking Water Inspectorate (DWI) Guidance on the Implementation of the 

Water Supply (Water Quality) Regulations 2000 (as amended) in England published in 

September 2010, the requirement for utilities to publish an annual report had been revoked, but 

an additional clause was added to Regulation 35, Provision of Information, that requires a 

company to send any person a copy of their water supply zone record within seven days of 

receipt of such a request. This amendment also enables a company to provide the public record 

information either by post, e-mail or through their website. In effect, this is a CCR in an “on 

demand” context that allows for multiple delivery mechanisms.

4.2 Case Study: Australia

Water utilities in Australia are required to provide free access to their annual report to any 

member of the public requesting a copy in a timely and practicable way. Annual reports are to

contain sufficient information to enable individuals or groups to make informed judgments about 

the quality of drinking water and provide a basis for discussions about the priorities that will be 

given to improving drinking water quality. The annual report represents an opportunity to gather

feedback, and it should therefore encourage consumers and stakeholders to provide comment. 

There is no specific required delivery method for the annual report, and the majority of the 

utilities post a copy of it on their website. As an example, SA Water in South Australia does a 

small print run of their annual report and distributes it via mail to key stakeholders at the time it 

is published. A copy is also mailed to customers who request a hard copy through the SA Water 

call center, but SA Water does not receive a large number of requests from their customers for 
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this report. The report is also published online and is free for anyone to download (K. Spehr, 

personal communication, March 5, 2012).

5.0 RECOMMENDATIONS FOR TRANSITION TO E-DELIVERY

A review of the water industry as well as similar industry’s transitions to electronic delivery 

provides multiple options and lessons learned for the water sector. Utilities collect a vast amount 

of information from their customers and many utilities already have or are in the process of 

transitioning to electronic billing. The majority of the case studies presented involved collecting 

e-mail addresses as a part of normal business practice through the following methods:

• Requesting customers (through bill inserts) to update their emergency contact 

information with the utility to include an e-mail address;

• Registering customers for electronic billing;

• Collecting information from other local departments; and

• Registering customers to receive their CCR by e-mail.

In 2011, the Water Industry Technical Action Fund (WITAF) conducted a survey of over 2,300 

targeted homeowners (J.A. Roberson, 2011). When asked how they would want to access their 

CCR, the homeowners chose the following mechanisms:

• Online at water utility website – 13.9%

• A postcard or other mailing – 12.5%

• Mailed to my residence – 49.2%

• Full CCR in a major newspaper – 3.6%

• Newspaper notice reporting whether my water met all of the regulations – 3.5%

• Posted notice at water utility’s office – 1.1%

• Don’t want or don’t need – 15.5%

About half of the respondents preferred to have their CCR mailed to their home, but others were 

interested in receiving the information via an email or a postcard notifying them to visit the 

utilities website. The latter presents an interesting option, as it uses the U.S. Postal Service and 

includes all customers, but all that is sent is an easy to produce and inexpensive to mail post card. 

Then, the customer can decide how they would like to receive their CCR based on the options 

presented on the postcard (e.g., website, visit the library, call to have copy mailed, etc.). The 

post card may be one way to continue a 100% mailing to customers, but still save on producing 

and mailing the full CCR. This option includes similar methods as suggested by M. Corson 

(personal communication, January 17, 2012) at American Water and it allows the customer to 

choose the medium in which they receive their drinking water information. 
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The PADEP program allows for e-delivery of a CCR if an e-mail address can be verified and 

validated. Those customers who routinely conduct their business via electronic delivery now can 

receive their CCR electronically, and those customers who receive their bills by mail will still 

receive their CCR in the same manner. However, the use of e-mail supplements the established 

method of mailing CCRs and paves the way for utilities to increasingly use the technologies 

available to them while recognizing that a portion their customers will still prefer to receive a 

hard copy of their CCR. A model for the drinking water industry may be the “opt in” method 

whereby individual customers can choose when they are ready to receive their CCR 

electronically. This method accounts for both those who prefer hard copy delivery via the U.S. 

Postal Service as well as those who do not have access to an electronic delivery mechanism. 

Through time, it can be expected that more and more of a utility’s customers will opt for 

electronic delivery of their CCR (as they have for their bills).

6.0 SUMMARY

A review of similar industries shows that the annual drinking water quality CCR is unique in its 

current specific delivery requirements; however, this reflects the importance the EPA places on

keeping the public informed and aware of their drinking water source and quality. Nonetheless, 

electronic means of communication are becoming more and more common and are much greener 

for the environment and put less strain on a utility’s budget. Some options to consider include:

1. Mail a post card to notify customers that the CCR is ready for viewing and give multiple 

viewing options, including electronic.

2. During the normal billing process, those utilities with electronic billing systems could ask 

customers to “opt in” for electronic delivery of their CCR.

Other sub-options and option combinations can be derived from these two basic options. For 

example, a utility without electronic billing could still collect email addresses through the hard 

copy billing process and then email the CCR to those who provide addresses.

The next steps are to develop guidance as to how primacy agencies and the utilities they regulate 

can effectively integrate newer electronic dissemination methods as options for delivering CCRs 

to the public. The public meetings scheduled by EPA will further identify approaches to:

• Raise awareness of the CCR Retrospective Review;

• Engage stakeholders in the identification, development, and acceptance of e-delivery of 

the CCR;

• Define the role of EPA, EPA Regions, state primacy agencies, and industry partners in 

outreach and communication activities;

• Disseminate guidance, tools, and training in a timely and effective manner; and

• Solicit feedback on the efficacy of electronic communication methods.
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Ultimately, through this process, EPA and the water sector hope to build greater transparency 

and public participation in protecting the Nation’s drinking water. 
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7.0 REFERENCES

Documents and Information Sources Consulted as part of this Project

American Water. Water Quality Reports. Retrieved January 17, 2012, from 

http://www.amwater.com/ensuring-water-quality/water-quality-reports.html

City of Ames, Iowa. 2010 Consumer Confidence Report. Retrieved from 

www.cityofames.org/water

City of Greensboro, North Carolina. Sewage Collection and Water Reclamation Plant Report 

for 2010. Retrieved from http://www.greensboronc.gov/modules/showdocument.aspx?documentid=3701

City of Joliet, Illinois. CSO Email Alerts. Retrieved January 11, 2012, from 

http://www.cityofjoliet.info/public-utilities/cso.htm

City of Mishawaka Utilities Company, Indiana. Combined Sewer Overflow Notification 

Registration. Retrieved January 11, 2012, from http://mishawaka.csoalert.com/

City of Richmond, Virginia. Combined Sewer Overflow (CSO) Project. Retrieved January 11, 

2012, from 

http://www.richmondgov.com/PublicUtilities/projectCombinedSewerOverflow.aspx

County of San Diego, Office of Emergency Services. Alert San Diego. Retrieved January 12, 

2012, from http://www.readysandiego.org/alertsandiego/

Direct Marketing Association. 2010 Response Rate Trend Report. Retrieved February 3, 2012 

from http://www.the-dma.org/cgi/dispannouncements?article=1451

District of Columbia Water and Sewer Authority. 2010 Annual Report. Retrieved from 

www.dcwater.com

Drinking Water Inspectorate. Guidance on the Implementation of the Water Supply (Water 

Quality) Regulations 2000 (as amended) in England. Retrieved from 

http://dwi.defra.gov.uk/stakeholders/guidance-and-codes-ofpractice/WS%28WQ%29%20Regulations%20England2010.pdf

General Assembly of North Carolina. Clean Water Act of 1999. Retrieved from 

http://www.ncga.state.nc.us/enactedlegislation/sessionlaws/pdf/1999-2000/sl1999-

329.pdf 

Iowa Department of Administrative Services. Iowa School Alerts. Retrieved January 12, 2012, 

from https://schoolalerts.iowa.gov/about.jsp
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Lincoln County School District, Mississippi. Alert! Notification System. Retrieved January 12, 

2012, from http://lcsd.k12.ms.us/?page_id=8

Metropolitan Washington Council of Governments (COG). CapitalAlert. Retrieved January 31, 

2012, from www.capitalalert.gov

Metropolitan Water Reclamation District of Greater Chicago. CSO Public Notification Plan. 

Retrieved January 11, 2012, from http://www.mwrd.org/irj/portal/anonymous/overview

National Grid. Keep Informed During a Storm. Retrieved January 13, 2012, from 

http://www.myenergypages.com/national-grid-keep-informed-during-the-storm/

North Wales Water Authority. NWWA 2010 Water Quality Report. Retrieved from 

http://www.nwwater.com/

Pennsylvania Department of Environmental Protection. Consumer Confidence Reports. 

Retrieved from

http://www.portal.state.pa.us/portal/server.pt/community/public_drinking_water/10549/c

onsumer_confidence_reports/553926

Pennsylvania Department of Environmental Protection. Consumer Confidence Report (CCR) 

Template and Instructions for Systems Using Only Groundwater Sources. Retrieved 

from http://www.elibrary.dep.state.pa.us/dsweb/View/Collection-8852

Pennsylvania Department of Environmental Protection. Consumer Confidence Report (CCR) 

Template and Instructions for Systems Using Surface Water Sources. Retrieved from

http://www.elibrary.dep.state.pa.us/dsweb/View/Collection-8851

Pike Research. Social Media in the Utility Industry Consumer Survey. Retrieved from 

http://www.pikeresearch.com/wordpress/wp-content/uploads/2012/01/SMUS-12-PikeResearch.pdf

Roberson, J.A. (2011, October 18). The Results from AWWA’s Surveys and Pilot Tests on 

Electronic Delivery of Consumer Confidence Reports. Presented at the Association of 

State Drinking Water Administrator (ASDWA) Annual Conference in Minneapolis, MN.

SD1. Wet Weather Overflow Public Notification Program. Retrieved January 11, 2012, from 

http://www.sd1.org/ProjectsandPrograms/WetWeatherOverflowPublicNotificationProgra

m.aspx

San Diego Gas and Electric. Power Emergency Notification System (PENS). Retrieved January 

13, 2012, from http://sdge.com/safety/outages/power-emergency-notification-system
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Sanitary District of Hammond, Indiana. Combined Sewer Overflow Public Notification. 

Retrieved January 11, 2012, from 

http://www.hammondsd.com/html/cso_notification.html

State of Indiana. Rule 2.1. Combined Sewer Overflow Public Notification. Retrieved from

www.in.gov/legislative/iac/T03270/A00050.PDF

Town of Ontario, New York. 2010 Wastewater Consumer Confidence Report. Retrieved from

http://www.ontariotown.org/water%20dept/2010%20Wastewater%20Consumer%20Conf

idence%20Report.pdf 

Town of Speedway, Indiana. CSO Public Notifications. Retrieved January 11, 2012, from 

http://www.townofspeedway.org/department/division.php?fDD=7-73

United Kingdom Ministry of Justice, National Archives. The Water Supply (Water Quality) 

Regulations 2000. Retrieved from 

http://www.legislation.gov.uk/uksi/2000/3184/pdfs/uksi_20003184_en.pdf

United States Department of Labor. What You Should Know About Your Retirement Plan. 

Retrieved from http://www.dol.gov/ebsa/pdf/wyskgreenbook.pdf

United States Department of the Treasury, Comptroller of the Currency Administrator of 

National Banks. Answers About Bank Accounts. Retrieved January 17, 2012, from 

http://helpwithmybank.gov/get-answers/bank-accounts/general-account-questions/faqbank-accounts-gen-account-01.html

United States Environmental Protection Agency (EPA). 2008 Nationwide Survey of Local 

Emergency Planning Committees (LEPCs). Retrieved from

http://www.epa.gov/osweroe1/docs/chem/2008_lepcsurv.pdf

United States Environmental Protection Agency (EPA). Improving Our Regulations: Final Plan 

for Periodic Retrospective Reviews of Existing Regulations. Retrieved from

http://www.epa.gov/improvingregulations/documents/eparetroreviewplan-aug2011.pdf

United States Environmental Protection Agency (EPA). Combined Sewer Overflows: Guidance 

for Nine Minimum Controls. Retrieved from

http://www.epa.gov/npdes/pubs/owm0030.pdf

United States Environmental Protection Agency (EPA). Safe Drinking Water Act. 

Retrieved from http://water.epa.gov/lawsregs/rulesregs/sdwa/ 

United States Environmental Protection Agency (EPA). Consumer Confidence Report Rule. 

Retrieved from http://water.epa.gov/lawsregs/rulesregs/sdwa/ccr/index.cfm
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United States Environmental Protection Agency (EPA). Emergency Planning and Community 

Right-to-Know Act (EPCRA) Requirements. Retrieved from

http://www.epa.gov/oem/content/epcra/

United States Government Printing Office. April 1, 2011. H.R. 1340: End Unnecessary Costs 

Caused by Report Mailing Act of 2011. Retrieved from

http://www.gpo.gov/fdsys/pkg/BILLS-112hr1340ih/pdf/BILLS-112hr1340ih.pdf

United States Government Printing Office. September 19, 2011. S. 1578: End Unnecessary 

Mailers Act of 2011. Retrieved from http://www.gpo.gov/fdsys/pkg/BILLS112s1578is/pdf/BILLS-112s1578is.pdf

United States Government Printing Office. January 18, 2011. Executive Order 13563: 

Improving Regulation and Regulatory Review. Retrieved from

http://www.gpo.gov/fdsys/pkg/FR-2011-01-21/pdf/2011-1385.pdf

Virginia Tech University. VT Alerts. Retrieved January 12, 2012, from 

http://www.alerts.vt.edu/

Water Services Association of Australia. Australian Drinking Water Guidelines 6 2011. 

Retrieved from 

http://www.awa.asn.au/uploadedFiles/NHMRC_aust_drinking_water_guidelines.pdf

Wood County, West Virginia Office of Emergency Management. Wide Area Rapid Notification 

(W.A.R.N.). Retrieved January 12, 2012, from http://www.woodcounty911.com/

York Water Company. 2010 Annual Drinking Water Quality Report. Retrieved from

http://www.yorkwater.com/

Individuals Contacted as part of this Project

Tom Bradbury, Regulatory Affairs Director, North Wales Water Authority

Matthew Corson, Regulatory Compliance and Environmental Stewardship Manager, American 

Water

Peter Gee, Program Manager Performance Improvement, Water Services Association of 

Australia

Adam Gronski, Metropolitan Water Reclamation District of Chicago

Michael Leggett, Pretreatment, North Carolina Division of Water Quality

JT Hand, Chief Operating Officer, York Water Company

Sarah Neiderer, Water Communications and Marketing Coordinator, DC Water

Rodney Peets, Superintendent of Water Utilities, Town of Ontario

J. Alan Roberson, Director of Federal Regulations, American Water Works Association

Mindy Scott, SD1

Kirra Spehr, Communications Adviser, SA Water

Geoff Tute, Asset Manager (Water Non-Infrastructure), Southern Water

Patti-Kay Wisniewski, Drinking Water Security Coordinator, EPA Region 3