Market Research for the Retrospective Review of the Consumer Confidence Report (CCR) Rule

Table of Contents

1.0 I NTRODUCTION

................................ ................................ ................................ .............. 1

1.1 Retrospective Review of the CCR Rule

................................ ................................ .. 1 1.2 Purpose of this Paper

................................ ................................ .............................. 2

2.0 C URRENT M ETHODS OF E LECTRONIC D ELIVERY IN THE W ATER I NDUSTRY

............. 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 E LECTRONIC D ELIVERY IN S IMILAR I NDISTRIES

................................ .......................... 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 E LECTRONIC D ELIVERY IN THE W ATER S ECTOR IN O THER C OUNTRIES

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

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

................................ ................................ ........................... 15

5.0 R ECOMMENDATIONS FOR T RANSITION TO E

- D ELIVERY

................................ ............ 16

6.0 S UMMARY

................................ ................................ ................................ ..................... 17

7.0 R EFERENCES

................................ ................................ ................................ ................ 19EPA OGWDW WA No. 3

- 30.1 1 Horsley Witten Group, In c. Market Research Report April 20 , 2012 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 cus tomers 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. T he regulati on requires each community water system to mail a CCR to each customer of that system at least once annually by July 1 st

.

These reports are the centerpiece of the public right

- to

- know regulation in the Safe Drinking Water Act ( SDWA )

. The purpo se of the information contained in CCR s 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 measu res, 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 pro vide 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 regula tions 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 e xploring new ways to promote greater transparency and public participation in protecting the Nation’s drinking water

. It can be
burdensome and cost ly 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
Cau sed by Report Mailing Act of 2011 . B oth 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:

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

• M ake such report available on the system's website and, upon request, by mail.EPA OGWDW WA No. 3

- 30.1 2 Horsley Witten Group, In c. Market Research Report April 20 , 2012 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 e

mail, 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 1 998 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 publ ic, while lowering the
burden to water systems and states. One method sugge sted 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

e lectronic 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) simila r 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 recommen dations 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 t ype of u tilities i nvolved ;

• Com munication m ethods ;

• Utility b enefits of e lectronic d elivery ;

• Program s uccesses and l essons l earned ; and

• Ideas to c onsider for CCR e

- d elivery

.

Overall, the goal of this document is to determine what components of various industry programs
could be utili zed 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 d evelopment of a strategy for a potential transition to the electronic delivery of a CCR.EPA OGWDW WA No. 3

- 30.1 3 Horsley Witten Group, In c. Market Research Report April 20 , 2012 2.0 CURRENT METHODS OF ELECTRONIC DELIVERY IN THE WATER INDUSTRY

As the number of available communication opti ons 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 en sure that customers understand where their drinking water comes from and to en sure that customers have access to their CCR. The following section will describe how some states have already begun the electronic delivery of
CCRs a nd 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 ( PA DEP) began allowing water supplier s to use e

- mail as a form of dir ect delivery fo r 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 ut ility with an e

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

Th e 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.d ep.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 sub sections
are case studies which d escribe 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 dr inking water to 180,000 customers ( 65,000

accounts ) in York and Adams Count ies 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 inform ed
customer base (J.T. Hand, personal communication, January 20, 2012)

.

In April 2010, YWC start ed 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 c an provide emergency contact information as well as their e

- mail addresses. This initiativeEPA OGWDW WA No. 3

- 30.1 4 Horsley Witten Group, In c. Market Research Report April 20 , 2012 collected over 6,000 e

- mail addresses

, which covers about 10% of the ir customer accounts

. As a result of the decision by PA DEP to allow water utilities to send out CCRs by e

- mail to customer s with a valid e

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

- mail addresses collected through t he “ Tap Ti p ” Campaign to distribute the 2010 CCR electronically

. Customers who receive their CCR electronically either receive their bills electronicall y or have provided their email addresses to the utility to receive communications electronically (J.T. Hand,

pers onal 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 15 th of each calendar year

. To ensure that all
customers received the CCR on th e 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

- mail s collected through the “ Tap Tip” campaign. YWC hired a third party vendor to send the e

- mail s as their computer systems could not manage sending out this volume of e

- mail s at one time. The

c ompany’s internal Information Technology (IT) Department estimated that it would have ta ken
14 hours to send approximate ly 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 i t was decided that the e

- mail would be t oo large to send if the CCR was attached as an electronic
document. The selected third party vendor track ed who received the e

- mail

, who ope ned it, and
who clicked through to the CCR on the website (J.T. Hand, personal communication, January 20, 2012)

.

O n Friday, February 4, 2011 a t 6:00 pm, the third party vendo r sent 5

, 922 e

- mail s. Of those,
5

, 194 (or 87.7%) were delivered and the balance of the e

- mail s (728 or 12.3%) “bounced.” Of
the 5

, 194 e

- mail s 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

- mail s or about 4 %. This initially was a disappointment to YWC , but it is believed that the paper version likely achieve s 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 e

mail 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 li st (a l ist 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:EPA OGWDW WA No. 3

- 30.1 5 Horsley Witten Group, In c. Market Research Report April 20 , 2012 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 m ail are on the same order of magnitude. For example, l etter

- 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

- delive red CCR appears reasonable.

YWC’s e

- delivery pr ocess took the third party vendo r 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 substa ntial savings to YWC (approximately $4,350)

. Overall, this first year of using e

- mail delivery benefitted the customers, the c ompany , 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 ask ed for is a valid e

- mail address and if they would like to receive information electronically

. YWC anticipates distributing approximat ely 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. T he NWW A has established a
contract with a third party vendor to contact all customers via telephone duri ng require d public
notification situations. Using this service to notify customers for public notification requirements has been successful and NWW A began to initiate additional customer contacts

. For example, w hen water main flushing is scheduled , advertisements a re placed in several newspapers, but s ometimes schedules need to be adjusted and require re

- advertising. NWW A

uses the vendor to notify those cu stomers in the area of the main (T. Bradbury, personal communication, January 19, 2012)

.EPA OGWDW WA No. 3

- 30.1 6 Horsley Witten Group, In c. Market Research Report April 20 , 2012 The service is also used to deliver CCRs by e

- mail to the a pproximately 8,300 customers (1/3 of the customer base) that receive e

- mail delivery of their water bills

. The c ollection of customer e

mail s has been accomplished in several ways. NWWA includes a form with water b ills 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 request s directly to NWW A

. 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 ra tes 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, t he 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)

.

NWW A has found that the use of e

- mail to distribute the CCR has been financially beneficial as
t he c osts associated with producing the hard copy of the CCR ( e.g., printing, processin g and mailing) are just over $1 .00 per CCR

. The vendor a lso provides a confirmation log to NWWA
with information regarding how many e

- mail s are sent and how many of them are delivered

. Initially, t here were a few e

- mail s 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, Ja nuary 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 the ir

customers have registered for electronic billing. As a service to the students at ISU, t he City of
Ames pro vides copies of the CCR and has received permission from the Iowa Department of Natural Resources (IDNR) to provide copies of the CCR to students b y 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 ch arge. 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.
R oberson, 2011)

.EPA OGWDW WA No. 3

- 30.1 7 Horsley Witten Group, In c. Market Research Report April 20 , 2012 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 the ir customers. S everal 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

. F rom a waste reduction stand point, distributing more CCRs electronically is seen as the best path forward for the C ity of Ames (J.A. Roberson, 2011)

.

2.4 Case Study: Military Installations

– Washington, D.C.

EPA Region 3 has primacy over the N avy and A ir F orce bases in Washington, D.C. and allows the electronic delivery of CCRs at those bases . Every individua l 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 c ommanding o fficer to the t enant organization s and r esidents. 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 e

mail address, it is assumed that th e majority of those who consume the drinking water w ill
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 c ustomers have t he 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

– cust omers 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 cal l , email, or text message.

It is estimated tha t out of 134,000 total customer accounts

, approximately 14,986 unique users ( 1 1%) have accessed their online account in December 2011, and similar trends in site visits occurred in the preceding months (S. N eiderer, 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.EPA OGWDW WA No. 3

- 30.1 8 Horsley Witten Group, In c. Market Research Report April 20 , 2012 The “My Account” f eature 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. Wh ile only 1 1% 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, Linked In) to communicate with customers as well. Those who are members or follow DC Water receive messages which encourage them to view w ater 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 numbe r 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

– Vo orhees, NJ

American Water provide s drinking water, wastewater

, and other related services to

a pproximately 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 maj ority of their customers, t he CCR is currently delivered as an insert into their bil l 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 no t 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 w ater conservation, emerging
contaminants research

, and source water protection ac tivities . American Water feels that this is a missed opportunity to instill confidence i n the company and the water it provide s (M. Corson, personal communication, January 17, 2012)

.

To in crease customer access to water quality information, American Wate r posts all of the ir
CCRs to the Internet at http://www.amwater.com/ensuring

- water

- quality/water

- quality

reports.html . They also created a “ Basic Water Quality Summar y ” for e ach of their water systems that contains the water quality information for which customers most frequently contact

t he Customer Service Center

. Customers are able to access this information by entering either their city/s tate or their zip code onl ine at American Water’s website listed above . Since these data are online, t he information in the Basic Water Quali ty Summary can be updated quickly and easily as needed.EPA OGWDW WA No. 3

- 30.1 9 Horsley Witten Group, In c. Market Research Report April 20 , 2012 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 includ e 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 h ard copies of the CCR upon request
, and would also likely develop a specific in sert on water quality and the availability of the annual water quality reports

, which is another opportunity for Am erican 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 customer s. 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 untr eated 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 g uidance
d ocument entitled “Combined Sewer Overflows: Guidance for Nine Minimum Controls

. ” It describe s 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 publi c notification . As described in the guidance, the measures
selected to communicate with the public should be the most cost effective measure s that provide reasonable assurance that the affected publ i c 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 man y locations have
established customer opt

- in systems where an interested party can sign up to receive alerts by e

mail

. Most utilities surveyed offer e

- mail alerts in their jurisdictions as a service to interested parties and consulted with those stakehol ders during the development of their notification systems. Therefore, the majority of those interested are receiving notifications of CSO
overflows.EPA OGWDW WA No. 3

- 30.1 10 Horsley Witten Group, In c. Market Research Report April 20 , 2012 The following describe the various ways that utilities across the country are incorporating
electronic de livery 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 o f 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. Jo seph 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 i n 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 resident s located in the Chicago Metropolitan area. There are CSOs which occasionally discharge in to the Grand
Calumet River or Little Calumet River

. Interested persons may request e

- mail
notific ation 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 munic i palities 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 o f their CSO Notification Plan includes an option for i nterested 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 wa terway. The alert contains a link to a system map which shows the impacted segment. S takeholder meetings were held during the website development process and the majority of interested stakeholders were consulted
and automatically added to the distributi on 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 wi ll 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

.EPA OGWDW WA No. 3

- 30.1 11 Horsley Witten Group, In c. Market Research Report April 20 , 2012 • 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 star ted a watershed group to notify stakeholders in their service area of CSO
overflow alerts and to provide newsletters . T his group has grown to include many city organizations and mayors in the utility’s service area. Additional i nterested parties can regi ster 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 P N mailing list at http://www.richmondgov.com/PublicUtilities/projectCom binedSewerOverflow.aspx

Jurisdictions have been able to choose which methods are the most appropriate for communicating wit h their consumers. The option for signing up for electronic delivery improves
the timeliness of notifications and allows the utili ties to reach more stakehol ders 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 coll ection 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 violati ons 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 ob tain 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.EPA OGWDW WA No. 3

- 30.1 12 Horsley Witten Group, In c. Market Research Report April 20 , 2012 Many wastewater utilities in North Carolina choose to post the annual re port on their websites
where a nyone 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 (E PCRA) 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 orde r 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 Sta te Emergency Response Commission (SERC). SERCs were charged with establishing Local Emergency Planning Committees (LEPCs), which provide a forum for first responders, s tate and local elected officials, emergency managers, industry representatives, hospita l 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 develop ing and maintain ing emergency plans in case of an accidental release, and encourage cont inuous 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 terror ist

- 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 populatio ns 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 not ify 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 ha s developed “ AlertSanDiego ” and residents can registe r their cell phone number, VoIP phon e number, and e

- mail addresses

. The county already has l isted and unlisted landline phone numbers included in theEPA OGWDW WA No. 3

- 30.1 13 Horsley Witten Group, In c. Market Research Report April 20 , 2012 database. “ AlertSanDiego ” will be used by emergency response personnel to notify those
homes and busines ses 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/ale rtsandiego/

.

• 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 count y’s Wide Area Rapid Notifi cation (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

. are a. 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 dur ing 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 t heir 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 c ommunicate with their

customers. Dependin g on their supplier, customers can choose to access their account online and
receive the information about their historical energy use as well

. Many e nergy 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 powe r emergencies, notification of system conditions and stage emergencies by e

- mail or pager; see http://sdge.com/safety/outages/power

- emergency

notification

- system

.EPA OGWDW WA No. 3

- 30.1 14 Horsley Witten Group, In c. Market Research Report April 20 , 2012 Electronic d elivery 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 ex pected 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 perio dic statement at least quarterly.

To help meet these requirements, t he 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 othe r benefits for consumers :

o Convenience

– customers can v iew, 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 Secur ity

– this option r educe s the possibility of mail fraud through s ecure 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 f ederal law that sets standards of protection for individuals in most voluntarily established, private

- sector retirement plans. The plan must automatically provide a s tatement to customers detailing their account balance and vested benefits. Depend ing on the type of plan , the statement may also include the value
of the investments in the acco unt and information describing the right to direct
investments at specified intervals . M any plans allow their members to provide an email address and opt i nto receiving their sta tements electronical ly

.

• 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 addres s or cell phone number s so that they can be informed of breaking news stories.EPA OGWDW WA No. 3

- 30.1 15 Horsley Witten Group, In c. Market Research Report April 20 , 2012 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 Qu ality) Regulations 2000 requires all water suppliers , under
R egulation 36: Publication of Information

, to publish an annual report which detail s thei r water system. The report i s to be made public and provided to all local authorities that the water suppli er 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

compan y 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 t imely 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 i mproving 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 t he majority of the utilities pos t 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 t o customers who request a hard copy through the SA Water call center, but SA Water do es not receive a large number of requests from their customers forEPA OGWDW WA No. 3

- 30.1 16 Horsley Witten Group, In c. Market Research Report April 20 , 2012 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 l earned for the water sector . Ut ilities 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 no rmal 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 ;

• R egistering customers for electronic billing ;

• Collecting informa tion from other local departments ; and

• R egistering customers to receive the ir CCR by e

- mail

.

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

t argeted homeowners (J.A. Roberson, 2011) . W hen asked how they would w ant 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 w ater 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 receiv ing the information via an email or a postcard notifying them to visit the
utilities website. The latter presents a n interesting option

, as it uses the U.S. Postal Service and
includes all c ustomers, but all that is sent is an easy to produce and inexpensive to mail post car d. 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 custom ers, 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 th eir drinking water information.EPA OGWDW WA No. 3

- 30.1 17 Horsley Witten Group, In c. Market Research Report April 20 , 2012 The PA DEP program allows for e

- delivery of a CCR if an e

- mail address can be verif ied and
validate d . 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, t he use of e

- mail supplements the established method of mailing CCRs and paves the way for utilities to increasingly use the technologies
availab le 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 th eir 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 ut ility’s customers will opt for electronic delivery of their CCR (as they have for their bills)

.

6.0 SUMMARY

A review of similar industries show s that the annual drinking water quality CCR is unique in its current specific delivery requirements; howe ver, 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 coul d still collect email addresses through the hard copy billing process and then email the CCR to those who provide addresses.

The next step s are to develop guidance as to how primacy agencies and the utilities they regulate can effectively integrate newer electronic dissemination methods as option s 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, developm ent, and acceptance of e

- deli very of
the CCR ;

• Define the role of EPA, EPA R egions

, state primacy agencies, and industry partners in outreach and communication activities;

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

• Solic it feedback on the efficacy of electronic communication methods.EPA OGWDW WA No. 3

- 30.1 18 Horsley Witten Group, In c. Market Research Report April 20 , 2012 Ultimately, through this process, EPA and the water sector hope to build greater transparency and public participation in protecting the Nation’s drinking water

.EPA OGWDW WA No. 3

- 30.1 19 Horsley Witten Group, In c. Market Research Report April 20 , 2012 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

- wa ter

- 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 Recla mation Plant Report for 2010. Retrieved from http://www.greensboro

nc.gov/modules/showdocument.aspx?documentid=3701

City of Joliet, Illinois. CSO Email Alerts. Retri eved January 11, 2012, from http://www.cityofjoliet.info/public

- utilities/cso.htm

City of Mishawaka Utilities Company, Indiana. Combined Sewer Overflow Notification Registration. Ret rieved 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 Implementati on of the Water Supply (Water Quality) Regulations 2000 (as amended) in England. Retrieved from http://dwi.defra.gov.uk/stakehol ders/guidance

- and

- codes

- of

practice/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 h ttps://schoolalerts.iowa.gov/about.jspEPA OGWDW WA No. 3

- 30.1 20 Horsley Witten Group, In c. Market Research Report April 20 , 2012 Lincoln County School District, Mississippi. Alert! Notification System. Retrieved January 12, 2012, from http://lcsd.k12.ms.us/?page_id=8

Metropolitan Washingto n 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 Januar y 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 Grou ndwater Sources. Retrieved from http://www.elibrary.dep.state.pa.us/dsweb/View/Collection

- 8852

Pennsylvania Department of Environmental Protection. Consumer Confidence Repor t (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

- Pike

Researc h.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/WetWeatherOverflo wPublicNotificationProgra
m.aspx

San Diego Gas and Electric. Power Emergency Notification System (PENS). Retrieved January 13, 2012, from http://sdge.com/safety/outages/p ower

- emergency

- notification

- systemEPA OGWDW WA No. 3

- 30.1 21 Horsley Witten Group, In c. Market Research Report April 20 , 2012 Sanitary District of Hammond, Indiana. Combined Sewer Overflow Public Notification. Retrieved January 11, 2012, from http://www.hammondsd.com/html/cs o_notification.html

State of Indiana. Rule 2.1. Combined Sewer Overflow Public Notification. Retrieved from www.in.gov/legislative/ iac /T0 327 0/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%20R eport.pdf

Town of Speedway, Indiana. CSO Public Notifications. Retrieved January 11, 2012, from http://www.townofspeedway.org/department/division.php?fDD=7

- 73

United Kin gdom Ministry of Justice, National Archives. The Water Supply (Water Quality) Regulations 2000. Retrieved from http://www.legislation.gov.uk/uksi/2000/3184/pdfs/uksi_2 0003184_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 o f 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/faq

bank

- 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 Re trospective Reviews of Existing Regulations. Retrieved from http://www.epa.gov/improvingregulations/documents/eparetroreviewplan

- aug2011.pdf

United States En vironmental 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.cfmEPA OGWDW WA No. 3

- 30.1 22 Horsley Witten Group, In c. Market Research Report April 20 , 2012 United States Environmental Protection Agency (EPA). Emergency Planning and Community Right

- to

- Know Ac t (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. 1 578: End Unnecessary Mailers Act of 2011. Retrieved from http://www.gpo.gov/fdsys/pkg/BILLS

112s1578is/pdf/BILLS

- 112s1578is.pdf

United States Government Printing Offic e. 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 T ech 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.). Ret rieved 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 Improv ement, 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, Wat er 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