CCR Summary Section Under the 2027 Rule: What's New, What's Required
For twenty-eight years, the front of a Consumer Confidence Report (CCR) was whatever the utility's template author thought belonged there. Some utilities led with a general manager's letter. Some opened with a table of detected contaminants. Some fronted a graphic of a water glass and a tagline. None of that was wrong under the 1998 rule — the original CCR Rule at 40 CFR Part 141 Subpart O regulated content elements without prescribing their order, and the result was twenty-eight years of inconsistent opening pages that a typical customer skipped because they did not know what they were looking at.
The revised CCR Rule, finalized by EPA on May 24, 2024 (89 FR 45980; docket EPA-HQ-OW-2022-0260) and effective January 1, 2027, changes that. The 2024 rulemaking added a new section — 40 CFR § 141.156 "Summary of report contents" (89 FR 46013) — that requires every community water system to place a plain-language summary "displayed prominently at the beginning of the report." The summary is short, prescribed in content, and the first thing the customer sees; it is also the piece of the CCR that a primacy agency inspector will check first during compliance review.
This guide walks through what § 141.156 actually requires, how it ties back to the violation and compliance disclosures in the amended § 141.153, where utilities routinely miss the plain-language bar, and example language keyed to the standard text EPA prescribed in the rule. For the broader rule, see the CCR requirements 2027 summary; for the full drafting sequence, see how to write a CCR.
What the CCR summary section is
The summary section — sometimes called the "snapshot," the "at-a-glance," or simply the "summary" — is the opening block of content in a Consumer Confidence Report. Under § 141.156(a), each report "must include a summary displayed prominently at the beginning of the report, including a brief description of the nature of the report." It appears before any data tables, before any source-water narrative, before a general manager's letter (if the utility chooses to include one), and before any marketing content.
Structurally, the summary is a half-page to one-page section that answers three questions for the customer in plain English: did any contaminant in my drinking water exceed a federal or state limit during the reporting period, were there any violations of the utility's treatment, monitoring, or reporting obligations, and who do I contact for more information. The summary replaces the scattered disclosure pattern of the 1998-era CCRs, where a customer had to cross-reference a data table, a footnote, and a narrative paragraph to know whether the utility had a compliance problem.
The summary is not a replacement for the detailed data tables that follow. Detected contaminants, MCLs, MCLGs, detection ranges, and health-effects language continue to appear in the body of the report under § 141.153. What changes is that § 141.156 surfaces the top-line answer — "we met all federal and state standards" or "we had one monitoring violation for lead and copper in Q2" — in language a non-specialist can read without a glossary.
What changed in the 2024 rulemaking
The 1998 CCR Rule required specific content elements at § 141.153 — source-water information, detected contaminants, compliance with MCLs, violation narratives, and health-effects language for exceedances — but did not prescribe the order of those elements, and it did not require a distinct summary section. In practice, most utilities inherited a template from a state water association or a primacy agency that placed a letter or a detected-contaminants table at the front.
The 2024 rulemaking, driven in part by the America's Water Infrastructure Act of 2018 (Public Law 115-270) directive to improve CCR risk communication, did two things. First, it amended § 141.153 (89 FR 46012) to refine the required report content — including the disclosures at § 141.153(d)(6), (d)(8), (f), (h)(6), and (h)(7) that cover violations, exceedances, and significant-deficiency narratives. Second, it added a new § 141.156 "Summary of report contents" (89 FR 46013) that requires every CCR to open with a prominent plain-language summary referencing those disclosures.
EPA's stated rationale, in the rule preamble, is that consumer research conducted during the rulemaking showed that most customers who received a CCR under the 1998 rule did not read past the first page, and that a majority of those who did could not answer basic questions about whether their utility had violated a federal standard during the reporting period. The § 141.156 summary is the regulatory response: standardize the front-page content so the customer gets a reliable answer in the first 30 seconds.
Under § 141.156(d), the summary "should be written in plain language and may use infographics." The CCR requirements 2027 summary covers the plain-language standard in more detail, and how to write a CCR covers its operational application across the full report.
What § 141.156 actually requires
Read as codified, § 141.156 prescribes two required elements at a minimum, three conditional elements, and one verbatim standard paragraph. Section 141.156(d) adds that the summary "should be written in plain language and may use infographics." The list below tracks the subsection structure directly.
Required: summary of violations and compliance information — § 141.156(b)(1)
At a minimum, the summary must include a summary of the violations and compliance information contained in the report under § 141.153(d)(6) and (d)(8), § 141.153(f), and § 141.153(h)(6) and (h)(7). In plain terms, that folds in:
- § 141.153(d)(6) — compliance-table disclosures of violations (including footnote language explaining the violation and corrective action),
- § 141.153(d)(8) — the lead-action-level exceedance disclosure,
- § 141.153(f) — the narrative requirement for any violation of monitoring and reporting, filtration/disinfection, lead and copper control, Acrylamide/Epichlorohydrin treatment, recordkeeping, special monitoring under §§ 141.40–141.41, or a variance/exemption; the narrative must be "clear and readily understandable,"
- § 141.153(h)(6) — significant-deficiency and fecal-indicator-positive source-water disclosures for ground water systems under subpart S,
- § 141.153(h)(7) — subpart Y (microbial/disinfection byproduct) compliance disclosures.
For a utility with no violations during the reporting period, the summary-of-violations element is typically a short affirmative sentence — "During [calendar year], [Utility Name] met all federal and state drinking-water standards and had no monitoring, reporting, or treatment-technique violations." For a utility with one or more violations or an MCL exceedance, each one must be surfaced in the summary in plain language, not buried in a footnote elsewhere in the report.
Required: contact information — § 141.156(b)(2)
The summary must include contact information for the owner, operator, or designee of the community water system as a source of additional information concerning the report, per § 141.153(h)(2). Section 141.153(h)(2) requires the telephone number specifically; EPA also recommends, but does not require, including a website or social-media pointer if the utility uses one.
Conditional: paper-copy request directions — § 141.156(c)(1)
For utilities using the electronic delivery methods at § 141.155(a)(1)(ii), (iii), or (iv) — direct-URL, email with CCR attached, or email with a direct URL (see the direct-URL electronic delivery guide) — the summary must include directions for consumers to request a paper copy, consistent with § 141.155(a)(2). Systems using traditional paper delivery do not include this element.
Conditional: translation information — § 141.156(c)(2)
For systems subject to § 141.153(h)(3) because they serve a large proportion of consumers with limited English proficiency (as determined by the primacy agency), the summary must include information on where consumers may obtain a translated copy or language assistance. The CCR translation and accessibility guide covers how primacy agencies determine LEP thresholds and what counts as "appropriate language(s)."
Conditional: public-notification cross-reference — § 141.156(c)(3)
If the utility is using the CCR to also meet the public-notification requirements of 40 CFR Part 141 Subpart Q (Tier 3 public notices in particular), the summary must state that the report is also providing public notification of one or more violations or situations, include a brief statement about the nature of the notice, and describe how to locate the notice within the body of the report.
Required standard language — § 141.156(f)
Section 141.156(f) prescribes the following verbatim sentence, which must appear in every summary:
Please share this information with anyone who drinks this water (or their guardians), especially those who may not have received this report directly (for example, people in apartments, nursing homes, schools, and businesses). You can do this by posting this report in a public place or distributing copies by hand, mail, email, or another method.
This is a literal-text requirement. A utility may not paraphrase or translate it into different wording; translated copies provided under § 141.156(c)(2) or § 141.153(h)(3) render the same directive in the target language.
Optional: 6-month-update description — § 141.156(e)
Systems serving 10,000 or more persons that must distribute a second report by December 31 under § 141.155(j)(2) should include, in the summary of that second report, a brief description of the nature of the report and the 6-month update, noting the availability of new information for January through June of the current year. See the twice-yearly distribution guide for the operational sequence.
Plain-language requirement
Section 141.156(d) states that the summary "should be written in plain language and may use infographics." EPA did not finalize a specific Flesch-Kincaid grade-level target in the rule or preamble, but the rulemaking record points to readability guidance used by federal agencies under the Plain Writing Act of 2010 and CDC clear-communication guidance, which target roughly a 6th- to 8th-grade reading level for general-audience health communications. The CCR translation and accessibility guide covers the reading-level guidance in more detail and its interaction with the § 141.156(c)(2) translation requirement.
In practice, three drafting rules get a utility to plain-language compliance. First, define technical terms the first time they appear — MCL, MCLG, treatment technique, action level — and use the defined term consistently. Second, use short sentences and active voice; "we tested our water" instead of "water testing was conducted." Third, avoid jargon and acronyms that do not have a plain-English equivalent; "the state drinking-water program" is clearer than "the primacy agency" even though the second term is more precise.
"Should be" in § 141.156(d) is advisory rather than mandatory — a primacy-agency inspector reviewing a CCR for compliance cannot cite a utility purely for a failed readability score. The inspector can, however, cite a summary that omits a required § 141.156(b) element, buries it in an unintelligible way, or fails to include the verbatim § 141.156(f) language. Most state primacy agencies are adopting their own readability review guidance to standardize their enforcement approach; check your primacy agency's drafting guidance before finalizing a summary.
Example summary section
The block below is an example § 141.156 summary for a hypothetical electronic-delivery utility with no violations and no exceedances during the reporting year. Elements are labeled to show which § 141.156 subsection each line satisfies. The verbatim § 141.156(f) sharing paragraph appears last, unchanged.
2026 Drinking Water Report Summary — Centerville Water Utility (brief description of the nature of the report — § 141.156(a))
Did our water meet federal and state standards? (violations/compliance summary — § 141.156(b)(1) referencing § 141.153(d)(6), (d)(8), (f), (h)(6), (h)(7)) Yes. During 2026, Centerville Water Utility met all federal and state drinking-water standards. No contaminant exceeded its maximum contaminant level (MCL) or triggered a treatment-technique action level. We had no monitoring, reporting, filtration, disinfection, lead-and-copper, or treatment-technique violations.
Questions about this report? (contact information — § 141.156(b)(2) referencing § 141.153(h)(2)) Call (555) 123-4567 or visit centervillewater.gov/ccr. To request a paper copy by mail, call the same number. (paper-copy request directions — § 141.156(c)(1), because this utility delivers electronically under § 141.155(a)(1)(ii))
Share this report (verbatim standard language — § 141.156(f)) Please share this information with anyone who drinks this water (or their guardians), especially those who may not have received this report directly (for example, people in apartments, nursing homes, schools, and businesses). You can do this by posting this report in a public place or distributing copies by hand, mail, email, or another method.
For a utility with a violation, the violations/compliance block expands to name each violation in plain English: what it was, when it occurred, and what corrective action the utility has taken or is taking. Example: "We had one monitoring violation in April 2026: we were late submitting a required lead-and-copper monitoring report to the state drinking-water program. The late report covered Q1 2026 and contained no exceedances; we submitted it in May 2026 and the state confirmed no further action is required." For an MCL exceedance, the block must also describe the health effects of the contaminant in plain English; the underlying detail (contaminant, detected level, MCL, duration, EPA-standard health-effects language) continues to appear in the detailed § 141.153 data tables later in the report.
Common operator mistakes
Three drafting mistakes appear repeatedly in the 2025 draft CCRs primacy agencies have been reviewing in advance of the 2027 compliance date.
First, utilities are burying the compliance/violations summary in a general manager's letter at the top of the report. The letter is not prohibited by the rule, but § 141.156(a) requires the summary to be "displayed prominently at the beginning of the report" — which primacy agencies interpret to mean the first block of substantive content. Moving the letter to a later position in the document (or cutting it entirely) is the standard fix.
Second, utilities are writing the violations and exceedance summaries in technical language inherited from the § 141.153 detailed data tables. The § 141.156(d) plain-language guidance applies, and primacy agencies have been flagging summary language that is a direct copy-paste from the data tables. A summary that reads "TTHM concentration of 92.4 μg/L exceeded the 80 μg/L MCL in Q2 2026" has technically disclosed the exceedance but fails the plain-language norm the rule encourages. A compliant rewrite: "Between April and June 2026, our drinking water contained higher-than-allowed levels of trihalomethanes, a group of chemicals that form when chlorine reacts with natural organic material in source water."
Third, utilities are omitting the verbatim § 141.156(f) "Please share this information…" paragraph or paraphrasing it. The paragraph is prescribed text; it must appear in every summary exactly as written in the rule. Omission or paraphrase is a straightforward compliance finding during primacy-agency review.
The CCR 2027 checklist includes the § 141.156 elements as a compliance-tracking checklist so that drafting does not miss any required element, and the CCR 2027 deadline calendar lays out the drafting-and-review timeline that feeds the July 1, 2027 first-report deadline. Utilities coordinating across operational teams should also review the utilities resource hub for drafting-workflow references. Software support for summary-section drafting, including template libraries and compliance-status calculators, is covered in the CCR software guide.
FAQ
Is the summary section required for all community water systems?
Yes. Every community water system subject to the CCR Rule must include a summary at the beginning of its CCR under 40 CFR § 141.156, effective for reports delivered on or after January 1, 2027 — which, for most systems, means the annual CCR distributed by July 1, 2027 covering calendar year 2026 data. The requirement applies regardless of system size, service population, or delivery mechanism. Small systems using the direct-URL electronic delivery mechanism must still include the § 141.156 summary as the opening block of the CCR document at the hosted URL. For background on what a CCR is and who must produce one, see what is a CCR.
How long should the summary section be?
Half a page to one full page. EPA did not finalize a specific length requirement in § 141.156, but the rule's structural intent — a summary "displayed prominently at the beginning of the report" under § 141.156(a) — means the section should be concise enough that a customer can read it in under a minute and comprehensive enough to cover every required element. Utilities with no exceedances and no violations can typically fit the summary into a half-page; utilities with multiple violations or an MCL exceedance may need a full page to describe each in plain English. A summary that runs past one page defeats the purpose of the section as a quick-read top-of-report element.
Do I need to use any prescribed language verbatim?
Yes, one paragraph. Section 141.156(f) prescribes a verbatim sharing statement — "Please share this information with anyone who drinks this water (or their guardians)…" — that must appear in every summary exactly as written. No other § 141.156 element has a verbatim text requirement, though § 141.153 contains its own specific mandatory language for particular disclosures (for example, the § 141.154(d)(1) lead statement) that the summary's violations/compliance block may cross-reference. State primacy agencies often publish model summary templates tuned to their own context; check your primacy agency's guidance before drafting.
What happens if my utility has an MCL exceedance during the reporting period?
The exceedance must appear in the summary's violations-and-compliance block under § 141.156(b)(1), which references the § 141.153(d)(6) and (d)(8) compliance-table disclosures and the § 141.153(f) violation-narrative requirement. The summary entry must describe the contaminant, the level detected, the applicable MCL, the duration of the exceedance, and a plain-English health-effects summary. The exceedance also continues to appear in the detailed § 141.153 data tables later in the report with the EPA-standard health-effects language from Appendix A to Subpart O. For exceedances that are still ongoing as of the CCR delivery date, the summary must describe current status and direct the customer to any public-health advisory in effect. The how to write a CCR guide covers the MCL-exceedance drafting sequence in operational detail.
Last reviewed: 2026-04-18 by Andy Zhang.
Sources
- 40 CFR § 141.156 — Summary of report contents (eCFR current). https://www.ecfr.gov/current/title-40/chapter-I/subchapter-D/part-141/section-141.156
- 40 CFR § 141.153 — Content of the reports (eCFR current). https://www.ecfr.gov/current/title-40/chapter-I/subchapter-D/part-141/section-141.153
- 40 CFR Part 141 Subpart O — Consumer Confidence Reports (eCFR current). https://www.ecfr.gov/current/title-40/chapter-I/subchapter-D/part-141/subpart-O
- U.S. Environmental Protection Agency, "National Primary Drinking Water Regulations: Consumer Confidence Reports," 89 FR 45980 (May 24, 2024), docket EPA-HQ-OW-2022-0260. https://www.federalregister.gov/documents/2024/05/24/2024-10919
- EPA Consumer Confidence Report Rule landing page. https://www.epa.gov/ccr
- America's Water Infrastructure Act of 2018, Public Law 115-270. https://www.govinfo.gov/link/plaw/115/public/270
- Plain Writing Act of 2010, Public Law 111-274.