NDWAC CCR December Meeting Summary
This week, the National Drinking Water Advisory Council (NDWAC) held two meetings on December 1st and 2nd discussing advice and recommendations for EPA on targeted issues related to revisions to the Consumer Confidence Report (CCR) Rule.
The NDWAC reviewed the Report of the Consumer Confidence Report Rule Revision Working Group to the National Drinking Water Advisory Council, voting on consensus suggestions and non-consensus additional guidance (formerly “non-consensus recommendations”) that will move forward to EPA for decision-making. The NDWAC will move forward with the recommendations and non-consensus additional guidance outlined in the above report, noting that over the past two days the Council did add in new language and hold discussion that is not reflected in the linked version. Below is a short summary that includes some of the discussion during the meeting, and the new language and changes in both the consensus suggestions and non-consensus additional guidance. Please visit the above link for more detail on all of the Council’s recommendations.
- Advancing Environmental Justice and Supporting Underserved Communities
- CCR access to renters and non-billpaying customers needs to be improved, potentially through postcards.
- The primacy agency role in addressing underserved communities will be recognized and encouraged.
- Template use and generation by the primacy agency should be encouraged.
- Further differing opinions were added to the non-consensus additional guidance regarding additional information being included in the CCR (financial information), with those opposed feeling this would not be appropriate for the CCR.
- Improving Readability, Understandability, Clarity, Accuracy of Information, and Risk Communication of CCRs
- Language on a potential summary page for sample locations will be less specific to address security concerns.
- Additional differing opinions on the use of units in the CCR were added to the non-consensus additional guidance. Some members of the NDWAC felt units should be consistent with those used by the water system in Primacy Agency reports, while others maintained that this may be confusing for the public.
- Addressing accessibility challenges, including translating CCRs and meeting Americans with Disabilities Act (ADA) requirements.
- Verification of CCR translation will be difficult and create burden for primacy agencies.
- Translation flexibility is needed for small systems.
- Defining “best effort” to address accessibility challenges is necessary.
- CCR Delivery Manner and Methods, Including Electronic Delivery
- Council members continued to disagree on whether the CCR biannual delivery will be the same or include new information. Arguments for the same information added that the CCR could include a statement and contact information that customers could use to obtain the most current testing results.
- Discussion was held on potentially using schools and daycares to deliver water system information to legal guardians.
The Report will be adjusted to reflect the new language and discussion described above before being sent to Administrator Regan.
