Copyright 2012 American Water Works Association. Webinar Moderator

Transcription

1 Copyright 2012 American Water Works Association 1 Webinar Moderator Adam Carpenter Regulatory Analyst American Water Works Association Adam Carpenter works in AWWA s DC Government Affairs Office, and serves as an expert on a diverse set of drinking water issues including climate change, hydraulic fracturing, consumer confidence reports, carbon capture and storage, the energywater nexus, and other water and environmental issues. Along with his colleagues, he works to further AWWA s mission of supporting clean, affordable drinking water through sound application of science into policy, source water protection, sensible regulation, public awareness, and building stakeholder consensus. 2 1

2 Enhance Your Webinar Experience Close Programs Instant messengers Other programs not in use GoToWebinar Support 3 Webinar Survey Immediately upon closing the webinar Survey window opens Thank you 4 2

3 Products or Services The mention of specific products or services in this webinar does not represent AWWA endorsement AWWA does not endorse or approve products or services 5 Panel of Experts Mindy Eisenberg Chief, Protection Branch US Environmental Protection Agency JT Hand Chief Operating Officer The York Water Company Scott Bradway Water Quality Program Coordinator Portland Water Bureau 6 3

4 Agenda I. US EPA s Interpretive Memo on Consumer Confidence Report Delivery Mindy Eisenberg II. Is the Message Getting Out/Is our Audience Receiving it? JT Hand III.Implementing Electronic Delivery of CCRs Scott Bradway 7 Ask the Experts Mindy Eisenberg JT Hand Scott Bradway Enter your question into the question pane at the lower right hand side of the screen. Please include your name and specify to whom you are addressing the question. 8 4

5 US EPA s Interpretive Memo on Consumer Confidence Report Delivery Mindy Eisenberg Chief, Protection Branch Office of Ground Water and Drinking Water 9 Presentation Outline Consumer Confidence Report (CCR) Rule Retrospective Review CCR Delivery Requirements CCR Delivery Interpretive Memo CCR Delivery Methods Approaches to Electronic Delivery Important Considerations Additional Resources 10 5

6 CCR Retrospective Review EPA s Final Plan A 12 to 16 month review beginning in October 2011 EPA will consider reviewing the Consumer Confidence Report Rule to look for opportunities to improve the effectiveness of communicating drinking water information to the public, while lowering the burden of water systems and states. One example suggested by water systems is to allow electronic delivery through , thereby reducing mailing charges. 11 CCR Delivery Requirements Mail or otherwise directly deliver, one CCR to each customer by July 1st every year. In addition, make a good faith effort to reach non-bill paying consumers. Greater than 100,000 persons served must also post the CCR on the Internet. Send a copy to the director of the primacy agency (e.g., state drinking water program.) Submit to the primacy agency a certification, within 3 months of mailing, that the community water system distributed the CCR, and that the content is correct. A bill-paying customer is one who receives a water bill directly from the water utility. 12 6

7 Delivery Requirements (cont d) Small system mailing waiver (State s Governor or Tribal Leader approval.) Fewer than 10,000 persons served: Publish CCR in at least one local newspaper; notify customers that CCR will not be mailed; and make reports available upon request. 500 and fewer persons served: Notify customers that CCR is available upon request, and must provide notice at least once per year by mail, door-to-door delivery or public posting that report is available. Electronic delivery does not replace delivery waivers but is another option for small systems. 13 EPA s January 3, 2013 CCR Delivery Interpretive Memo and Framework 14 7

8 CCR Delivery Methods and Approaches 2 Implementation Approaches 2. Electronic Delivery with Paper CCR Delivery Option 1. Paper CCR Delivery with Electronic CCR Delivery Option Delivery Methods 1. Mail paper copy 2. Mail notification that CCR is available on website via a direct URL 3. direct URL to CCR 4. CCR sent as a file attachment 5. CCR embedded in the message 6. Additional electronic delivery that satisfies otherwise directly deliver 15 Directly Deliver Requirements Three elements must be met in order to use electronic delivery to comply with the requirement to directly deliver the CCR: 1. Electronic delivery must provide the CCR in a manner that is direct. 2. If a CWS is aware of a customer s inability to receive a CCR by the chosen electronic method, it must provide the CCR by an alternative method allowed by the rule. 3. A CWS must prominently display a message and the direct URL in all mail notifications of CCR availability. 16 8

9 CCR Delivery Methods Not Allowed 1. A customer must not have to navigate to another webpage to find any required CCR content if viewing the CCR on a website (e.g., address search engine.) 2. Use of social media (e.g., Twitter or Facebook) directed at billpaying customers does not meet the requirement to directly deliver. 3. The use of automated phone calls (e.g., emergency telephone notification systems) to distribute CCRs is not considered direct delivery. 17 Methods for Delivery of CCRs 1. Mail a paper copy of the CCR. CWS mails a paper copy of the CCR to bill-paying customers. In addition, mail to those who request paper instead of electronic delivery. Electronic delivery may not be appropriate for all CWSs. 18 9

10 Mail paper copy 19 Methods for Delivery of CCRs 2. Mail a notification that CCR is available via direct URL. CWS mails bill-paying customers a notification that the CCR is available and provides a direct URL to the CCR on a publicly available site on the Internet where it can be viewed. The URL must be prominently displayed on the mailing. Request for paper copy of CCR for those that don t have access to an electronic CCR. Other important considerations: The URL should be short. An option for a customer to request a paper CCR. Include a short statement about water quality to promote readership

11 Mail CCR sent as a URL on separate mailing (check box to request a paper copy of the CCR.) 21 Methods for Delivery of CCRs 3. a direct URL to the CCR. CWS s bill-paying customers a notification that the CCR is available and provides a direct URL to the CCR on a publicly available site on the Internet. A URL that navigates to a webpage that requires a customer to search for the CCR or enter other information does not meet the directly deliver requirement. Other important considerations: Include a short statement encouraging readership. Information on how to request a paper CCR. bounce-backs respond by sending the customer a CCR by another allowable delivery method

12 CCR sent as a direct URL 23 Methods for Delivery of CCRs 4. the CCR as a file attachment. CWS s the CCR as an electronic file attachment (e.g., portable document format (PDF)). Other important considerations: Include a short statement encouraging readership. Information on how to request a paper CCR. bounce-backs respond by sending the customer a CCR by another allowable delivery method. Be aware of spam filters

13 - CCR sent as a file attachment 25 Methods for Delivery of CCRs 5. the CCR embedded in the message. CWS s the CCR text and tables or an image inserted into the body of an . Other important considerations: Information on how to request a paper CCR. Use a catchy subject line. bounce-backs respond by sending the customer a CCR by another allowable delivery method

14 CCR sent as an embedded image 27 Methods for Delivery of CCRs 6. Additional electronic delivery that satisfies otherwise directly deliver (to account for future technologies.) CWS delivers the CCR through a method that will otherwise directly deliver to each bill-paying customer and in coordination with the primacy agency. This category is intended to encompass methods or technologies not included in the other methods. A CWS will need to use a combination of delivery methods to reach all customers

15 CCR Delivery Approaches for Bill-Paying Customers 1. Paper CCR delivery with a customer option to request an electronic CCR. CWS informs customers of the electronic delivery option and registers customers who identify electronic delivery preference. The CWS may obtain this delivery preference through a variety of methods (e.g., public outreach, community newsletter, etc.) 29 CCR Delivery Approaches for Bill-Paying Customers 2. Electronic CCR delivery with a customer option to request a paper CCR. CWS delivers CCR electronically, with an option to request paper CCR delivery. Customer must take action if they do not wish to receive their CCR electronically. If a CWS knows some customers cannot receive the CCR electronically (e.g., no internet access) they must send a paper CCR

16 Do & Don t CCR Delivery Scenarios for Bill-Paying Customers DO! DON T! Include links to other nonrequired information on both paper and electronic CCRs. Include an easy way customers can request a paper CCR if they don t want an electronic copy. The URL cannot lead to a webpage with multiple CCRs (e.g., multiple years and/or different system s CCRs.) Electronically meet your recordkeeping requirement and keep the CCR URL posted on the Internet for at least 3 years. Don t make a delivery change without telling customers if you start a new CCR delivery method. Don t forget to deliver follow-up CCRs if an is returned. 31 Important Considerations Delivery certification Ensure delivery to every bill-paying customer, which may require a combination of paper and/or electronic delivery in a service area. Electronic delivery planning considerations Customer base assessment for electronic delivery method capabilities. Public outreach to provide advance notification of the change in delivery approach. considerations Auto bill payers Respond to bounce backs by an allowable alternative means (e.g., paper CCR.) 32 16

17 Important Considerations Electronic delivery formatting Check box on every water bill, similar to a change of address or pay by credit card, in which a customer can elect to receive a paper CCR. Short, easy to type direct URL in typeface as large as the largest type on a bill. Informational statement to encourage readership. Cost savings Consider start up costs as you plan for electronic delivery. Plan for continued printing and mailing costs. 33 Additional Resources for CCRs Interpretive Memo ulations.cfm Guidance Documents mpliancehelp.cfm EPA s on-line CCR Catalog ( Update your CCR Catalog link and contact information ( ccrupdate) CCRiWriter (

18 Ask the Experts Mindy Eisenberg JT Hand Scott Bradway Enter your question into the question pane at the lower right hand side of the screen. Please include your name and specify to whom you are addressing the question. 35 Is the Message Getting Out? Is our Audience Receiving it? JT Hand Chief Operating Officer The York Water Company 36 18

19 2011 CCR Electronic Distribution Results Friday, February 10, :00 PM s Sent Link, Not an Attachment If you're having trouble viewing this , you may see it online. Share This: This is an automated message. Please do not respond to the sending account listed above. Dear Customer, The York Water Company is pleased to report that exhaustive testing in accordance with EPA and PA DEP guidelines has shown that our drinking water is safe and meets and exceeds all federal and state requirements. The 2011 Drinking Water Quality Report is now available by visiting us at and clicking on 2011 Water Report or go to If you would like a hard copy of the report, please us at customer.service@yorkwater.com and provide your name and address and we will be happy to mail you a copy of this report. To receive this and other documents electronically enroll at East Market St York, PA US This was sent to yahoo.com. To ensure that you continue receiving our s, please add us to your address book or safe list. manage your preferences opt out using TrueRemove. Got this as a forward? Sign up to receive our future s. Opt Out Option CCR Electronic Distribution Snapshot 638 Opens 45 Clicks 38 19

20 2011 Electronic CCR Penetration Results Total s Sent 7264 Total Received 6749 Total Bounces 515 Soft 175 Hard % 7.1% Firewall/Permissions CCR Penetration Results Total Received 6749 Total Opened 2593 Total who Clicked 38.4% % 10.15% Total who Opted Out What Does This Mean? 204 Customers Clicked on the Link and Presumably Read the CCR. Conclusion: 3.02% Penetration Rate for Electronic Distribution of the CCR 40 20

21 Affect of 2011 CCR Media Announcements Published in Local Newspapers Feb 10, York Daily Record The Evening Sun York Dispatch Layout & Design: $ 280 Advertising: $2416 Total: $2696 How Many Customers/Consumers Contacted York Water? 23 How Many Wanted a Hard Copy CCR? 9 How Many Wanted a Hard Copy CCR? Economics of the 2011 CCR York Water is Proud of our Results We want our Customers to Know Produced 59, CCRs Single Copy Costs Hard Copy: $ $35,394 Digital Copy: $.10 Graphic Design Printing USPS Compliance / Labeling $ 2,020 $16,478 $ 3,464 Mailed 53, CCRs Postage $10,736 Advertising $ 2,

22 What are We Doing with Our 2012 CCR? Published in Local Newspapers Feb 8, This is an automated message. Please do not respond to the sending account listed above. Dear York Water Customer, The York Water Company is pleased to report that exhaustive testing in accordance with EPA and PA DEP guidelines has shown that our drinking water is safe and meets and exceeds all federal and state requirements. The 2012 Drinking Water Quality Report is now available. To view the 2012 Drinking Water Quality Report and learn more about your drinking water, visit us at This report contains important information about the source and quality of your drinking water CCR Electronic Distribution Snapshot February 8, :00 pm s Sent Received As of 2/11/ % Opened -339 Unique Clicks 12 Customers Opt Out 44 22

23 2012 CCR Penetration Results Total Received 8560 Total Opened 3487 Total who Clicked Total who Opted Out 40.74% % 12.14% What Does This Mean? 339 Customers Clicked on the Link and Presumably Read the CCR. Conclusion: 3.96% Penetration Rate for Electronic Distribution of the CCR ~ 1 Percentage Point Higher than 2011 CCR 45 Notice on All Water Bills in February 2013 Billing Cycles The York Water Company is pleased to report that exhaustive testing in accordance with EPA and PA DEP guidelines has shown that our drinking water is safe and meets and exceeds all federal and state requirements. The 2012 Drinking Water Quality Report is now available. To view the 2012 Drinking Water Quality Report and learn more about your drinking water, visit us at This report contains important information about the source and quality of your drinking water. York Water will no longer mail printed copies of the report to all of our customers. If, however, you would like a hard copy of the report, please us at customer.service@yorkwater.com and provide your name and address or submit your request at and we ll be happy to mail you a copy of the report

24 Economics of the 2012 CCR (Est.) Produced CCRs Graphic Design Printing USPS Compliance / Labeling Per Customer Cost 2012 $.08 $4725 $ 2,020 $ 0.20 $ 0.00 Mailed 2 CCRs Postage $ 1.04 Advertising $ 2, Questions? 1% Increase in Confirmed Penetration Rate at a cost savings of $30,000 Better for the Environment Direct, Convenient Information Access for our Customers 48 24

25 Ask the Experts Mindy Eisenberg JT Hand Scott Bradway Enter your question into the question pane at the lower right hand side of the screen. Please include your name and specify to whom you are addressing the question. 49 Implementing Electronic Delivery of CCRs Scott Bradway Water Quality Program Coordinator Portland Water Bureau 50 25

26 Learning Objectives Pros and Cons of Electronic Direct Delivery of CCRs Some things PWSs may want to consider 51 Portland Water Bureau Overview Largest PWS in state of Oregon. - Retail to 566,000 - Wholesale to 388,000 - Approximately 20% of ORs population

27 Traditional CCR 12 page report - 4 color - Non glossy - Attractive 53 Traditional CCR System Information 54 27

28 Traditional CCR Data Table 55 Traditional CCR Other Information 56 28

29 Delivery 2012: Mailed 325,000 reports - Mailed to all addresses in service area - Sent as bulk mail for efficiency 57 Costs 2012: $105,000 - $60,000 Postage and Handling - $33,000 Printing - $12,00 Staff time 58 29

30 2013 Direct Delivery 3 options - Mail Report - Direct Link/Report - Mail link to report on bill or separate mailer 59 Considerations for Direct Delivery Customer requests for efficiency E-Billing - Limited s Quarterly billing LCR Compliance Existing messaging on bills limited space 60 30

31 Mailing Direct Link Postcard to all services 325,000 Attractive Catchy (and approved) language Phone number to request paper copy and translation Online paper copy request form 61 Additional Methods Media release Social Media Outlets Featured on website Articles in neighborhood papers 62 31

32 Costs Limited cost savings of $20,000 - $18,000 in printing - $1,000 postage 63 Advantages Cost savings (Limited) Public perception of efficiency Drive customers to website Better tracking of readership 64 32

33 Advantages Environmental 65 Disadvantages Less readership? More complex 66 33

34 Future Possibilities Bill Notification - $80,0000 postage - Quarterly billing: Report earlier - Change message timing/cycle 67 Summary Some cost savings Better tracking of readership Public Perception is biggest advantage 68 34

35 Ask the Experts Mindy Eisenberg JT Hand Scott Bradway Enter your question into the question pane at the lower right hand side of the screen. Please include your name and specify to whom you are addressing the question. 69 AWWA 2012 eccr Survey Summary Environmental: 2,218 tons of paper (equivalent to 44,000 trees) are used each year to print CCRs Look for detailed results from AWWA s 2012 survey in the March edition of Journal-AWWA

36 Upcoming Webinars March 6 Water Main Condition Assessment March 19 Sponsored Badger Meter Webinar: Optimizing Meter Reading System Performance April 3 Continual Quality Improvement in the Laboratory Register for a 2013 Webinar Bundle Individual Full Year Water Treatment and Operations Group Full Year Regulatory/Legislative Distribution Topics Mitigation of Hazards, Disasters and System Register Online at: 71 Upcoming Specialty Conferences Register Online at:

37 ACE 2013 Explore a world of ideas and innovation with your peers and leaders in the water industry. For More Information 73 Thank You for Joining AWWA s Webinar As part of your registration, you are entitled to an additional 30-day archive access of today s program. Until next time, keep the water safe and secure

38 Presenter Biography Information Ms. Eisenberg is the chief of the branch of the Office of Ground Water and Drinking Water involved in writing the recent USEPA Interpretative Memo on electronic delivery of CCRs and the retrospective review team that examined and interpreted the existing regulation for USEPA. Mindy Eisenberg Mr. Hand is the CEO of The York Water Company, which has been successfully running a multiyear pilot program of electronic delivery of CCRs, and will share the results of the program and feedback received from customers. JT Hand Mr. Bradway is a program coordinator at Portland Water Bureau, and among other projects, is leading the utility s efforts to move toward electronic delivery of CCRs. He will be discussing the factors that went into the utility s choices, both for the current year and for potential changes in future years. Scott Bradway 75 38