I. TITLE II OF THE AMERICANS WITH DISABILITIES ACT (ADA)
| Topic | Current Rule | Revised Rule | Applicable Year |
|---|---|---|---|
| ADA Compliance | No requirements for CCRs to meet specific accessibility standards. | The Justice Department's 2024 final ruling updates Title II of the ADA, requiring web content and mobile applications to be accessible to people with disabilities. Content must meet the Web Content Accessibility Guidelines (WCAG) Version 2.1, Level AA technical standards. Specifically, CCR PDFs must be ADA-tagged to be accurately read aloud by screen readers for blind users. Systems serving populations of 50,000 or more persons must comply starting April 24, 2026. All other systems must comply by April 26, 2027. |
2026/2027 |
II. EPA'S CCR RULE REVISIONS: REPORT DELIVERY & ADMINISTRATION
| Topic | Current Rule | Revised Rule | Applicable Year |
|---|---|---|---|
| Timing of Reports | Annually by July 1st. | Systems serving 10,000+ Persons: Must distribute the report twice per calendar year (by July 1st and December 31st). The July 1st report includes an annual summary of the previous calendar year. The December 31st report includes a summary of the previous calendar year and, if applicable, a 6-month update on violations, action level exceedances, and UCMR results. Systems serving <10,000 Persons: Continue to distribute annually by July 1st. |
2027 |
| Direct Delivery | Mail or directly deliver to each customer. | Systems must use mail or an electronic delivery method. Systems using electronic delivery must still provide a paper copy upon customer request. | 2027 |
| Good Faith Delivery | Good faith efforts to reach non-billed consumers (e.g., mail to patrons, posting on Internet/public places). | New examples of good faith efforts include: bulk delivery of postcards with direct links, an opt-in notification system (email/text), advertising on social media, and holding public meetings. | 2027 |
| Wholesalers/Consecutive Systems | Deliver information to the purchaser system(s) by April 1st or a mutually agreed-upon date. | Deliver information to the purchaser system(s) by April 1st and October 1st, if the purchaser system is required to deliver reports twice per year. | 2027 |
| Certification | Submit certification to primacy agency no later than 3 months after distribution. | Submit a copy of the report and certification to the primacy agency no later than 10 days after the system is required to distribute the reports. | 2027 |
| Recordkeeping | Systems serving 100,000+ persons must post online. | Systems serving 50,000+ persons must post their current year's report to a publicly accessible site on the Internet. Any system posting a CCR on a website must maintain its availability for at least 3 years. | 2027 |
III. EPA'S CCR RULE REVISIONS: IMPROVING READABILITY AND RISK
| Topic | Current Rule | Revised Rule | Applicable Year |
|---|---|---|---|
| Data Format | Systems must present contaminant data in tables. | Systems must present contaminant data in a clear and understandable format, which may include, but is not limited to, one or more tables. | 2027 |
| Definitions | The current rule requires definitions for several terms (e.g., MCL, AL, MRDL). | In addition to the definitions in the current rule, the revised rule requires CCRs to include definitions of contaminant, pesticide, and herbicide. | 2027 |
| Summary | Not explicitly required. | Systems must include a summary of the key information (e.g., contact info, violations, report purpose) at the beginning of the report. | 2027 |
| Translation Access | A statement in the appropriate language(s) is required in communities with limited English proficiency. | Must contain either information on where to obtain a translated copy or assistance in the appropriate language. Systems serving more than 100,000 persons are required to develop language access plans. | 2027 |
| Accessibility | No specific current requirements for accessible report formats. | Systems must make a reasonable effort to provide the reports in an accessible format to anyone who requests an accommodation. | 2027 |
| Arsenic & Nitrate | Existing health effects language for nitrate and arsenic. | Revised educational information on health effects of nitrate and arsenic is required for systems that detect the contaminants above half the MCL but are not in violation of the MCL. | 2027 |
| Revised Total Coliform Rule (RTCR) | Existing standard language for RTCR compliance in the reports. | Updated standard language for the Revised Total Coliform Rule compliance in the reports. | 2027 |
| Unregulated Contaminant Monitoring Rule (UCMR) | Systems may include a brief explanation of the reasons for monitoring. | Systems must include a brief explanation of the reasons for monitoring for unregulated contaminants. | 2027 |
| Lead Action Exceedances | No explanation about the exceedance or corrective action required. | Systems that have exceeded the lead action level must clearly identify the exceedance, include an explanation, and a description of any corrective actions. | 2027 |
| Corrosion Control Efforts | Not explicitly required. | CCRs must include template language to explain their corrosion control efforts. | 2027 |
IV. EPA'S NEW REGULATIONS ON PFAS
| Topic | Current Rule | Revised Rule | Applicable Year |
|---|---|---|---|
| PFAS MCLs | There are no PFAS MCLs currently enforced by the EPA. The following states have MCLs on one or multiple PFAS substances: California, Massachusetts, Michigan, New Hampshire, New Jersey, New York, Pennsylvania Vermont, Wisconsin |
In 2024, the EPA established legally enforceable MCLs for six PFAS in drinking water: PFOA, PFOS, PFHxS, PFNA, and HFPO-DA (with individual MCLs), and a Hazard Index MCL for mixtures of two or more of PFHxS, PFNA, HFPO-DA, and PFBS. Public water systems must monitor for these PFAS and complete initial monitoring by 2027. Public water systems that violate one or more of these MCLs must take action to reduce levels and provide public notification beginning in 2029 (five years after the rule establishment). |
2027/2029 |
V. EPA'S LEAD AND COPPER RULE REVISIONS (LCRR)
| Topic | Current Rule | Revised Rule | Applicable Year |
|---|---|---|---|
| Service Line Inventory | The inventory must identify the material and location of each service line, must be updated on an annual basis, and access to the inventory must be provided in the CCR. Water systems serving more than 50,000 persons must make the publicly accessible inventory available online. | No additional revisions. This inventory must be updated on an annual basis. | 2024 |
| Service Line Material Notifications | Systems with lead, galvanized requiring replacement, or lead status unknown service lines must provide repeat notifications on an annual basis by the November 15 due date. | No additional revisions. Notifications must be sent on an annual basis. | 2024 |
| Service Line Replacement Plan | No existing requirement. | Systems with one or more lead, galvanized requiring replacement, or lead status unknown service lines must create a service line replacement plan by November 1, 2027. This plan must detail material identification, standard full replacement procedures, customer communication (before and after), and flushing instructions. | 2027 |