CCR Translation Requirements

There are two distinct translation triggers under the 2024 CCR Rule Revisions, and conflating them is the most common compliance mistake systems make. One applies based on the demographics of your service area, as your primacy agency determines it; the other kicks in automatically once your system crosses the 100,000-person population threshold.

Both take effect January 1, 2027 — meaning your first fully compliant CCR, covering 2026 data, must meet these requirements. (89 FR 46013, May 24, 2024)

The two triggers, side by side

| Trigger | Who it applies to | What it requires | Codified at | |---------|------------------|------------------|-------------| | Primacy-determined large proportion of LEP consumers | Any system whose primacy agency (state or EPA Region) determines it serves a large proportion of consumers with limited English proficiency | Translated content in the CCR itself — specific regulatory text and contact information for further help — in the appropriate language(s) | 40 CFR § 141.153(h)(3) | | Systems serving 100,000 or more persons | Any community water system serving a population of 100,000 or more | A written LEP plan: evaluate languages spoken in the service area, document how translation will be provided, and report annually | 40 CFR § 141.155(i) |

These are not a small-system version and a large-system version of the same rule. They are independent obligations. A system serving 150,000 people faces both. A system serving 8,000 people in a community where the state has identified a large proportion of Spanish-speaking residents faces only Trigger 1. A system serving 200,000 people with no primacy-agency LEP determination still faces Trigger 2.

Trigger 1: Primacy-determined large proportion of LEP consumers

What the rule says

Under 40 CFR § 141.153(h)(3), if consumers with limited English proficiency make up a "large proportion" of your service area — as determined by your primacy agency — your CCR must contain information in the appropriate language(s) about the importance of the report and either:

The phrase "large proportion" is not federally defined as a percentage or a head count. EPA delegates that determination entirely to primacy agencies. Your state or EPA regional office sets the threshold, applies it to the demographics of your service area, and notifies systems that fall under the requirement.

What this means operationally

You don't self-assess under Trigger 1. Your primacy agency tells you whether this applies. If it does, you have two options for how to comply:

  1. Translate the full CCR into the required language(s), or
  2. Include a prominent notice in the CCR — in the required language(s) — directing consumers to where they can obtain a translation or get assistance.

The second option is more common for systems that serve a modest number of LEP consumers in one language. The first is typically expected where a large portion of the service area uses a non-English language predominantly.

State-level variation

States can and do set their own thresholds for what counts as a "large proportion." California, for example, uses a trigger of 1,000 residents or 10 percent of the community served, whichever is lower, under California Health & Safety Code § 116470. California also names specific languages — including Spanish, Chinese, and Hmong — based on statewide demographic data.

If you serve a California water system, the state requirements under Title 22 layer on top of the federal floor. See California CCR requirements for the specifics.

Trigger 2: Systems serving 100,000 or more must have an LEP plan

What the rule says

Under 40 CFR § 141.155(i), community water systems serving 100,000 or more persons must develop a written plan for providing assistance to consumers with limited English proficiency. The plan must:

This is a planning and documentation requirement, not just a content requirement. You must have a written plan on file, and it must reflect an actual assessment of the languages present in your service area — not a generic placeholder.

Relationship to Trigger 1

Trigger 2 is cumulative, not a replacement for Trigger 1. A system serving 100,000 or more people must comply with the LEP plan requirement under § 141.155(i) regardless of whether its primacy agency has made a "large proportion" determination. If that determination has also been made, the system faces both the translated-content obligation under § 141.153(h)(3) and the written plan obligation under § 141.155(i).

Think of the LEP plan as the infrastructure behind the translation obligation — a documented process for identifying who needs help, what languages are involved, and how the system will deliver accessible information year to year.

The 100,000-person cliff

The CCR rule uses four population-based thresholds for different obligations: 500, 10,000, 50,000, and 100,000. (40 CFR §§ 141.151–141.156) These are "or more" and "or fewer" cliffs — 100,000 means exactly 100,000 and above. A system serving 99,500 people does not trigger the LEP plan requirement. A system serving exactly 100,000 does.

Population counts for this purpose are based on the population your system is permitted or certified to serve, as reported to your primacy agency.

What "translated content" must include

When Trigger 1 applies, the translated information in your CCR must address:

The regulation does not require the entire CCR to be translated. It requires that LEP consumers receive enough information in their language to understand that the report exists, that it matters, and how to get help reading it. (40 CFR § 141.153(h)(3))

Some primacy agencies have developed boilerplate inserts for the most common languages in their states. Check with your state drinking water program before drafting your own — using an approved insert simplifies review and reduces the risk of error.

What an LEP plan must include

For systems triggering Trigger 2, the written LEP plan is a living document. At minimum it must contain:

  1. A language assessment — an inventory of the languages spoken by LEP consumers in your service area, based on available demographic data (Census Bureau data, state demographic tools, or service area surveys are all acceptable evidence bases)
  2. A translation approach — how your system will provide accessible CCR content and other critical communications to LEP consumers (this can include contracted translation services, bilingual staff, partnerships with community organizations, or electronic translation tools where appropriate)
  3. Annual review — a process for updating the plan each year and reporting material changes to your primacy agency alongside the annual certification

The first plan is due with your first 2027 report. (40 CFR § 141.155(i))

Your plan does not need to be submitted as a separate standalone document. It can be included as an attachment to your CCR or as part of your certification filing, depending on what your primacy agency accepts. Confirm the format requirement with your state drinking water program.

California Title 22: state-level layered requirements

California has its own LEP requirements for CCRs that go beyond the federal floor. The California Department of Water Resources administers these alongside the State Water Resources Control Board. Rather than detailing them here, see California CCR requirements, which covers Title 22, Health & Safety Code § 116470, the specific language triggers the state uses, and how the eAR electronic submission interacts with translation compliance.

If you serve a California water system, treat the California page as your operative compliance reference, with this page as the federal baseline context.

Step-by-step: how to comply with both triggers

The steps below apply to all community water systems preparing for the 2027 CCR cycle. Follow all steps — some will conclude with "not applicable" for your system, and that's a valid outcome, but you need to confirm it.

Step 1: Confirm your population served

Identify the official population count your system reports to your primacy agency. This is the number used to evaluate the 100,000-person threshold for Trigger 2 and to inform the primacy agency's determination under Trigger 1.

Step 2: Contact your primacy agency for a Trigger 1 determination

Ask your state drinking water program or EPA regional office whether your service area has been identified as having a large proportion of LEP consumers under 40 CFR § 141.153(h)(3). Do not assume. Many states have already issued guidance listing which systems are affected; others will require a request. Get the answer in writing.

Step 3: If Trigger 1 applies — add translated content to your CCR

Obtain the required translated insert(s) from your primacy agency or draft them using approved templates. At minimum, the insert must explain what the CCR is, why it matters, and how consumers can obtain a translated copy or get assistance. Place the insert prominently in the report — before or alongside your report's main content, not buried at the end.

Step 4: Evaluate whether Trigger 2 applies to your system

If your system serves 100,000 or more persons, you must develop a written LEP plan. If you serve fewer than 100,000, you can skip Steps 5 and 6.

Step 5: Conduct a service-area language assessment

Pull demographic data for your service area from the U.S. Census Bureau (American Community Survey tables on language spoken at home are the standard source). Identify the languages spoken by LEP residents in your service area and the approximate number of speakers. Document your methodology and the data source.

Step 6: Write and file your LEP plan

Draft the plan to include: your language assessment findings, the translation approach your system will use for CCR content and other critical communications, and your annual review process. Submit it with your first 2027 CCR as required under 40 CFR § 141.155(i). File a copy in your compliance records.

Step 7: Build annual review into your CCR production schedule

Both triggers require ongoing attention — Trigger 1 because primacy agency determinations can change as demographics shift, Trigger 2 because the LEP plan must be reviewed and updated annually. Add a translation compliance checkpoint to your CCR production and electronic delivery workflow.

Last reviewed: 2026-05-03. Next scheduled review: every 3 months until Jan 1, 2027 effective date.