EPA
WaterSense
Comments on the
April 2006 Draft Specifications
for
Certification Programs for Irrigation Professionals
Compiled on October 19, 2006
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Comments on the Draft Specifications for Certification Programs for Irrigation Professionals
Commenter Page
Andy Smith, Irrigation Association 3
Irrigation Association 5
Laura Hodnett, Medford Water Commission 8
Lome Haveruk, DH Water Management Services, Inc. 9
Mike Grundvig, Contractor 10
Rex Winn, Idaho Power 1 1
Tim Wilson, The Irrigation Water Management Society 12
Tom Reynolds, Water Balance, LLC 13
Tony Gregg, Austin Water Utility 14
Richard Harris, East Bay Municipal Utility District 15
PLANET, Landscape Association 16
Denver Stakeholder Meeting: Draft Specifications for
Certification Programs for Irrigation Professionals 19
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Comments on the Draft Specifications for Certification Programs for Irrigation Professionals
Commenter: Andy Smith
Affiliation: Irrigation Association
Comment Date: 05/24/2006
In discussions various interests regarding the EPA's desire to recognize certification programs for
irrigation practitioners, it has become apparent that certain limitations should be considered
regarding the attributes of organizations that are allowed to apply for approval of their
certification programs. Listed below are some enhancements to consider:
Qualifications for Organization Offering Irrigation Certification
The organization should be a college, university, trade school, vocational school, or trade
association. Any entity wishing to apply for approval shall have a minimum often years
experience in providing comprehensive irrigation industry certifications with widespread
government, industry and market acceptance. The organization making application must be
nationally recognized as a credible resource for certification offerings. Said certification offerings
must not be tied to specific products or manufacturers. The organization should have a full time
staff and regular business hours to assist with administrative issues. The organization should have
the ability to offer testing within 90 days notice. The organization should have a systematic
means to provide, document and publish continuing education requirements for registrants over
time. The organization should have a web based directory to provide consumers with means to
verify certification.
References
The organization should document at least 10 irrigation industry references in writing. The
references should include contact information for the reference as well as any supporting
documentation deemed appropriate for determining the organization's credentials. The references
should include at least one of each of the following:
A federal agency
A state agency
A municipal/local government agency
A manufacturer of irrigation products
A distributor of irrigation products
An irrigation contractor
An end user of an irrigation system
An academic institution
A student of their current program
An authorized instructor of the currently offered curriculum
Some of the above items are lofty goals. They should be discussed as I truly feel EPA wants this
program to mean something.
Also, our current rules would not allow us to provide EPA with a sample exam as required. This
would compromise the content of our exam and we would not want to let that happen. We will
need a workaround solution.
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Comments on the Draft Specifications for Certification Programs for Irrigation Professionals
One other item for consideration is the timing of the proposed changes to the education program.
I would like to consider the impact this activity may have on this program.
Andy Smith
State & Affiliate Relations Director
Irrigation Association
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Comments on the Draft Specifications for Certification Programs for Irrigation Professionals
Commenter: Irrigation Association
Affiliation: Trade Association
Comment Date: 5/10/2006
The Irrigation Association (IA) strongly supports the Environmental Protection Agency's (EPA)
commitment to water efficiency through the recognition of Irrigation Certificate Programs.
Certificate holders in programs that are well organized and of high quality significantly improve
the chances that an irrigation system will be not only efficient but effective.
The EPA is confronted with a classic dilemma of those choosing evaluation criteria - do you seek
excellence or assume that a rising tide lifts all boats? The Irrigation Association counsels that, in
a highly technical field such as irrigation, the under-trained or under-qualified cast doubt on the
credibility of any program with which they are associated. For this reason, the EPA should
initially set the highest achievable standards for its certification program to gain the public's
acceptance and confidence.
The Irrigation Association suggests the following changes or modifications to the draft Criteria
for the qualification of certification programs:
New Section: 1.1 Sponsoring Organization Qualifications
a) Sponsoring organization may be an association, foundation, education institution,
trade union, or incorporated private company;
b) The sponsoring organization shall not be in the business of supplying irrigation
products or services;
c) A sponsoring organization shall have been incorporated for a minimum period of five
(5) years;
d) A sponsoring organization must post a roster of certification holders on a website by
name, location, and certificate type.
e) The sponsoring organization shall supply five (5) references of financial stability
from its bankers, accountants or suppliers.
Section 2.1 Independent Oversight Committee
(All program drafts)
Second sentence: Increase the number of professionals on an oversight committee from
three to six. An oversight committee must have a variety of backgrounds so that complex
subject matter can be debated and resolved.
Third Sentence: Reduce the number of an organization's employees on the oversight
committee from 1/2 to 1/3. This clause along with the expansion of the oversight
committee itself will limit the number of paid employees actively engaged in the
certification process thus reducing any incentive control the certification process,
Section 2.2 Experiential Agreement (Auditor Certification Draft)
The auditor program should train individuals to perform audits with both classroom and field
training methods. Suggest modification of the wording to the following- "The certification must
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Comments on the Draft Specifications for Certification Programs for Irrigation Professionals
require that the applicant have proof that they have performed a field audit as part of a course of
study or within a specified time period following the exam as established by the oversight
committee."
A separate auditing certification for golf courses should be considered.
Section 2.3 Exam Content (Auditor Certification Draft)
The subject of system maintenance would be more appropriately covered in the separate installer
certification
Section 2.3.1 Exam Content (Designer Certification Draft)
Cost estimating and maintenance are items generally not relevant to proper irrigation design and
should be dropped from the question pool in this certification.
Section 2.3.1 Exam Content (Installation Certification Draft)
It is recommended that a couple of items be added in this section to examine a candidate's
knowledge of OSHA rules and regulations. In addition, an understanding of electrical circuit
operation is desirable.
Section 2.3.1 Exam Content (All Certification Drafts)
The last sentence in this section should be expanded with the addition of the following "Exams
questions should be rotated periodically so that a random selection of questions from a question
pool will be used. This will inhibit the sharing of answers from on examination to another.
Section 2.3.3 Quality Assurance / Quality Control (All Certification Drafts)
It is recommended that the second sentence of this section be changed to read "An independent
academic institute or professional testing organization must grade each examination and report
the results to the individual candidate and oversight committee. "This academic institute or
professional testing organization shall maintain the question pool used for all exams."
Section 3.3 Documentation of Independent Oversight Committee Responsibility
The last sentence should be modified to read as follows, "A copy of the oversight committees
rules of conduct or the sponsoring organizations by-laws pertaining to the oversight committee
should be submitted as documentation."
The Irrigation Association looks forward to working with the EPA on all irrigation certification
programs with the expectation that this activity will have a significant impact on the nation's
water use.
Respectfully submitted by
Thomas H Kimmell
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Comments on the Draft Specifications for Certification Programs for Irrigation Professionals
Executive Director
Irrigation Association
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Comments on the Draft Specifications for Certification Programs for Irrigation Professionals
Commenter: Laura Hodnett
Affiliation: Medford Water Commission
Comment Date: 4/24/2006
As a water utility employee who is responsible for conservation programs, I am thrilled to see this
effort moving forward. Following are a few comments relative to the proposed exam content.
I see "water pressure and its affect on sprinkler performance" listed as exam content only for
Irrigation Auditors. Perhaps this topic is intended to fall under "hydraulics and pumps" or some
other category listed for Designers and Installers, but that is not clear. While we also see
problems associated with inadequate pressure, it has been our experience that sprinkler systems
that operate well above the pressure ranges specified by manufacturers is one of the most
prevalent and wasteful practices associated with irrigation systems. As such, I believe it
deserves a high level of attention in the certification process. It is important that pressure
regulation be integrated into initial design, and that installation and maintenance personnel both
understand its importance and recognize its symptoms. Not identifying excessive pressure until
an audit is done is remedial, whereas it is better addressed at the time of installation.
While it is not proposed as a part of the current program, I'd personally like to see consideration
of a product requirement that all standard spray sprinklers (non rotors) must be pressure
compensating. Without that, even if the initial design included such sprinklers, there is not a high
likelihood that the correct models will be supplied if/when sprinklers need to be replaced.
A couple other topics I'd also advocate covering are low head drainage (the need for check
valves) and water waste associated with autodrains. Both of these situations result in water being
drained from sprinkler lines after each cycle, which is both unnecessary and wasteful (especially
when we advocate multi-cycling to obtain better absorbtion). It may be that these will be topics
addressed under "impact of site conditions on equipment choices," but I am mentioning it anyway
since that is not clear.
I also note that "maintenance" is a topic for the Designer and Auditor certifications, but not the
Installation and Maintenance Professionals. This seems like an obvious content for the latter
certification, and its omission seems odd.
Thanks for your consideration.
Laura Hodnett
Medford Water Commission
Medford, OR
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Comments on the Draft Specifications for Certification Programs for Irrigation Professionals
Commenter: Lome Haveruk
Affiliation: DH Water Management Services Inc.
Comment Date: 05/13/2006
Hi Jane
It was a pleasure meeting with you in Denver. I found the meeting to be very informal and
informative at the same time. It is not that often that so many irrigation experts get together and
at the same time have one goal in mind.
I have taken some time to review everything and have only a few suggestions that will allow the
program to have a broader reach than I am seeing indicated in the draft documents.
Version 1.0
EPA Water Efficiency Program 7 April 2006
2.1 Independent Oversight Committee
The certification process provided by an organization must be supervised by an independent
oversight committee. The oversight committee must be established by the organization and be
composed of at least three professionals who are recognized for their expertise in the irrigation
field. Full time employees of the organization must hold less than half of the oversight committee
positions. The committee must be able to exercise independent judgment and oversight to assure
the integrity of the certification process.
This section limits smaller companies that could utilize the lA's established certification board
and national training centre (CIT) for overseeing the certification process to meet the "supervised
by an independent oversight committee" requirement. What I would suggest is rewording to
include corporations to partner with entities that can fulfill this requirement. This will allow for
some of the more creative, smaller, well established, quality irrigation training companies to
participate and send their students through a nationally if not internationally recognized
certification and examination process. This way we do not have to reinvent the wheel which is
already rolling in the right direction - water efficiency.
What I would also, like to see is that any "Instructor delivering training must be certified in that
field" prior to teaching a class.
I do not see any other concerns from an independent training organizations point of view.
However, I would like to stress that in no way does the IA become the sole body designated to be
established for the creation, delivery, and examination of irrigation training programs.
Lome Haveruk, CID, CIC, CLIA, WCP
DH Water Management Serivces Inc.
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Comments on the Draft Specifications for Certification Programs for Irrigation Professionals
Commenter: Mike Grundvig
Affiliation: Contractor
Comment Date: 4/17/2006
As a contractor and consumer, I am pleased with the EPA's efforts to improve the efficiency of
our water use. There is so much we can do to improve/reduce our water use.
Thank you,
Mike Grundvig
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Comments on the Draft Specifications for Certification Programs for Irrigation Professionals
Commenter: Rex Winn
Affiliation: Idaho Power
Comment Date: 04/28/2006
I think this concept is very timely, perhaps even behind the curve because of the water issues
facing our nation today. I look forward to seeing progress. I believe education, correct design
and operation run hand in hand in this regard. With a new as well as existing customers it should
start with education so that they understand just how important it is that they be a part of the
benefits (to be realized by all) of Environmentally Safe Water Practices. This now takes them to
a Good System Design, because without a good irrigation design, being environmentally
conscience in belief and practice won't happen. Understanding the correct operation of a well
designed irrigation system is paramount to being a good steward of our limited water supply.
Every water user needs to understand their impact on the local, national and perhaps the global
setting of good Environmentally Safe Water use and Practices.
This is very important information that the whole nation needs. However there may be hot spots
that should be the focal point of immediate need. To increase interest and participation in
Environmentally Safe Water Practices, perhaps a State and/or Federal tax credit could be offered.
This tax credit being based upon the attendance at educational seminars, installation and
operation of well designed irrigation systems plus on an individual, corporate or State level some
type of commitment to partnering in Environmentally Safe Water Practices, with follow-up to
insure continued success of the program. I believe that the marketing of this concept would be
essential to the level of success to be achieved. My thoughts and I wish you the best in this
worthy project.
Rex Winn, CID
Idaho Power Company
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Comments on the Draft Specifications for Certification Programs for Irrigation Professionals
Commenter: Tim Wilson
Affiliation: The Irrigation Water Management Society
Comment Date: 5/10/2006
Jane,
I look forward to the call. Here are my thoughts on the meeting in Denver:
1 . Great job. I heard from our rep. Brent Mecham that it went well.
2. 1 am concerned about any recommendations that would favor older well established
organizations and hinder the participation of smaller newer groups that might have good
innovative ideas and programs. Requirements such as history and financial resources tend to
favor the older established groups and exclude others. (Country club mentality)
3. There seems to have been a lot of talk about the importance of water management
qualifications. I would ask you to keep in mind that we have a great water management
certification that is established and in use. It is in demand and recognized as a very timely and
beneficial program.
4. 1 support the idea of getting started with something now so as to get the ball rolling.
5 . 1 would advise you all to include Planet in these discussions since they have a good
certification program.
Tim Wilson
The Irrigation Water Management Society
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Comments on the Draft Specifications for Certification Programs for Irrigation Professionals
Commenter: Tom A. Reynolds, CID, CLIA, TSP-USDA/NRCS, CSWP
Affiliation: Water Balance, LLC
Comment Date: 4/14/2006
The scope of knowledge, as laid forth in 2.3.1 of "...System Designers..." may be too broad. My
concern would be that important study and challenging problem exercises time and focus would
be diluted by time and effort studying Plumbing and Electrical Code, along with Grading and
Drainage. But EPA did not qualify their intentions, with respect to depth of knowledge required,
or proportions of these areas (percentage/weight) to the whole Study Outline. I would strongly
encourage all of this time be spent in a deeper study of soils and plant nutrition. Drainage
engineers, plumbers and electricians will thank us.
There is another concern. I haven't conducted the study, but it seems reasonable that more direct
delivery of water to "confined" rootzones of shrubs and trees using micro-irrigation technologies
is increasing, while whole area sprinkler irrigation of the same plant layout/design is on the
decline. Many contend that confined active rootzones are more efficient, while many insist that
roots need to expand way beyond their "drip lines." The debate continues.
Higher root densities may promote higher soil organism concentrations due to the proximity and
concentration of root exudates. Confined root zones are more dense, and may be viewed
therefore as more efficient. The point here is that there are profound differences between
irrigation design for mixed species sharing common drip irrigation valves and an over-head
system water a mono-culture of grass. I discourage any glossing over this fact. Let us also keep a
close on that trend towards precision rootzone management, as enabled though thoughtful micro-
irrigation design and intelligent management strategies.
I would carry it one step further. I would sub-divide the training to let those who will design
sprinkler systems get certified for that, while those whose focus is micro-irrigation, let them get
certification in that. They are definitely that different.
Other than these comments, words can not express my gratitude for your clearly enlightened
efforts towards nothing less than the single most urgent ecological matter facing humans.
Tom A. Reynolds, CID, CLIA, TSP-USDA/NRCS, CSWP
Water Balance, LLC
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Comments on the Draft Specifications for Certification Programs for Irrigation Professionals
Commenter: Tony Gregg
Affiliation: Austin Water Utility
Comment Date: 05/26/2006
My first comment has to do with process. Since municipal conservation professionals have very
limited budgets to attend workshops on proposed specification, to the extent possible, the
workshops should be held in the same City on the same date if they are half day workshops or on
consecutive dates if they are full day workshops. I have heard that attendance was very low at the
workshop in Denver and it was primarily for this very reason. It is not clear to me why this
workshop was not held in the afternoon, after the HEX spec workshop in DC on 4/28/06. I hope
in the future you will schedule workshops to be more convenient and less costly for the
participants.
As to the Certification for Irrigation Professionals, my comments apply to two of the proposed
certification programs. I do not believe that having a certification program for an Installation and
Maintenance Professional or an Irrigation Designer without an independent rater will be of
substantial value and will potentially devaluing the brand of this program. In Texas, we have had
for many years a licensing program for irrigators and there is no assurance that you will get a
quality system by hiring a licensed irrigator primarily because there is no required independent
inspection or rating system. I would not like to see EPA repeat this inadequate system on a
national level.
I think the model that should be followed in the Energy Star Homes programs which now requires
an independent rater to be available as the house is constructed rather than just after the fact.
That way, problems are caught before it is too costly to remedy them. For irrigation systems,
EPA could develop a set of high efficiency specifications and then require that a rater certify that
they installed system meets this system. The rater would have to be able to see the design of the
system before installation, be present during installation before it was backfilled, and test the
system after installation. This is the only way to guarantee premium performance.
So at this time, I would recommend that EPA not go forward with a certification program for
either a Installation and Maintenance Professional or an Irrigation Designer.
I do think there could be value in an certification program for Irrigation Auditors, though perhaps
this certification should also be delayed so that EPA could consider whether the Irrigation
Auditor Certification could be expanded to include the rating of new systems as I have described
above.
I would be welcome the opportunity to work with EPA to develop the type of system I have
described. I do think the time is right to address this issue. Thank you for the opportunity to
comment.
Tony Gregg
Water Conservation Manager
Austin Water Utility
Austin, Texas
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Comments on the Draft Specifications for Certification Programs for Irrigation Professionals
Commenter: Richard Harris
Affiliation: East Bay Municipal Utility District
Date of Comment: 6/23/2006
Thank you for the opportunity to comment on the draft specifications for irrigational professional
certifications under EPA's Water Efficiency Program. We believe such a program has merit and
want to comment in areas that we feel will be critical to achieving success and measurable water
efficiency in landscape design, installation and maintenance.
The program appears to be administered by independent organizations and oversight committees,
which could number a few or many. Recognizing there may be benefits of early adoption, co-
funding where budgets may be limited, among others, we have some concern that having
numerous individual organizations could create some discrepancies, different rule-making that
might have varying levels of "deemed efficient practices" from one region to another or among
different states. This may lead to market confusion among professionals, builders, consumers. We
suggest a more universal setting of criteria and passing scores may prove more effective.
The requirements for continuing education credits, proficiency and certification renewals are
good and will help to maintain efficiency levels, while keeping professionals and certification
levels current with advances in practice and technology.
We have some concern over certification being based on one audit, three years of maintenance
and three years of irrigation design only. We suggest more than one audit is necessary to become
proficient, and would like other design and maintenance experience to be based on peer reviewed
"water-efficient irrigation practices" specifically. Locally we have seen many poor and improper
irrigation designs and maintenance practices from professionals with 5, 10, 15 years of
experience. The program should consider certifications based on the majority or a select percent
of professional work completed.
Would like to learn more about the data collection and reporting process and support functions
under the program to assist in quantifying the success rate of program adoption and level of
effective water efficiency.
Thank you and good luck.
Richard Harris
Manager of Water Conservation
East Bay Municipal Utility District
Oakland, CA
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Commenter: PLANET
Affiliation: Landscape Association
Date of Comment: 9/1 1/2006
Professional Landcare Network Suggested Changes dated September 1 1. 2006
Version 1.0 EPA Water Efficiency Program 7 April 2006 ***Draft***
Draft Criteria for the Qualification of Certification Programs for Irrigation System
Installation and Maintenance Professionals under EPA's Water Efficiency Program
2.2 Experiential Requirement
The certification must require that the applicant have a minimum of at least three years of
demonstrated experience in the field of irrigation installation and maintenance. In addition, the
practitioner must provide evidence of a working understanding of all components (full
comprehension of all system parts and the ability to disassemble, repair, and assemble each part).
The oversight committee must have established the standard of proof for the experiential
requirements.
Three years of demonstrated experience may deter practitioners from being certified. And the
certification exam should evaluate proficiency. Therefore, evidence of a "working understanding
of all components" is not necessary.
Suggested change:
The oversight committee must establish the standard of experiential requirements (which
may be suggested requirements).
2.3.1 Exam Content
The exam process should be structured so that passing practitioners must have demonstrated
proficient applied knowledge in the following subject areas:
• System design layout and equipment specifications particularly as they pertain to distribution
uniformity and system efficiency
* Soil/water/plant relationships
• Precipitation rates and irrigation scheduling
* Impact of site conditions on equipment choice
* Hydraulics and pumps
• Blueprint reading and interpretation
• Recent innovations and technology developments
Suggested change:
The exam process should be structured so that passing practitioners must have
demonstrated comprehensive, job-related knowledge related to irrigation systems and land
care management.
Specific exam content and questions should be established or approved by the oversight
committee.
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2.3.3 Quality Assurance/Quality Control
The examination process must include the following QA/QC elements:
* The technical content of exam questions should be established or approved by, and periodically
reviewed by the oversight committee to ensure that the exam meets the requirements specified in
Section 2.3.1.
Suggested Change:
• The technical content of exam questions should be established or approved by, and
periodically reviewed by the oversight committee to ensure that the exam meets the
functional requirements of the job and tasks.
In addition, an independent academic institute or professional testing organization must review
the exam questions to ensure that they accurately test the subject material. The exam question
review process should be conducted at least once every two years, or more frequently as
determined by the oversight committee.
Suggested Addition:
The examination and testing mechanism:
Shall utilize reliable testing mechanisms to evaluate individual competence that is
objective, fair to all candidates, job-related, and based on the knowledge and skills
needed to function in the discipline.
Shall implement a formal policy of periodic review of the testing mechanisms to
ensure ongoing relevance to knowledge and skills needed in the discipline.
Shall utilize policies and procedures to assure that all test administration and
development materials are secure and demonstrate that these policies and
procedures are consistently implemented.
• Exams must be administered by an independent academic institute, a professional testing
organization, or an irrigation professional certified in the subject matter.
• Exams must bo graded by an independent academic institute, professional testing organization,
or a certified irrigation professional not involved in the training or proctoring of the practitioner
being examined.
• The security and integrity of the test questions and test processes must be protected at all times.
2.4 Renewal Suggested Change: Recertification Process
The certification must have a renewal process with a set periodicity.
2.4.1 Expiration
A certification must be recertified at least once every twe Suggested Change: three years, or
more frequently as established by the oversight committee.
2.4.2 Maintained Proficiency
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One aspect of the renewal Suggested Change: recertification process must require the
submission of documentation that the practitioner has maintained proficiency in the subject
matter (e.g. continuing education units). The oversight committee should establish valid
documentation requirements of maintained proficiency.
3.4 Documentation of Independent Oversight Committee Composition
For the current oversight committee, provide each committee member's name, committee
position, professional affiliation, and a brief synopsis of irrigation expertise Suggested Change:
and land care management expertise.
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EPA Water Efficiency Program
Draft Specifications for Certification Programs for Irrigation Professionals
Stakeholder Meeting
EPA Region 8 Building
Denver, Colorado
May 3, 2006
1:00 pm to 4:00 pm
Participants:
Timothy Malooly, Irrigation by Design, Inc.
Andy Smith, Irrigation Association
Steve McCoon, Walla Walla Sprinkler Company
Dan Fuhrman, Irrigation Contractor
Dale Morehouse, Irrigation Designer
Lawrence Budd, Walla Walla
Kristen Tromly, NREL
Tom Kimmel, Irrigation Association
Lome Haveruk, DH Water Management Services Inc.
Gene Reagan, Texas Turf Irrigation
Jodi Johnson, HydroPoint Data Systems
Karen Moore, VIT Products Inc.
Warren Gorowitz, Ewing Irrigation Products
Steven Smith, Aqua Engineering
Brent Mecham, Northern Colorado Water Conservancy District
Art Elmers, Netafim USA
Jane Anderson, Environmental Protection Agency
Joanna Kind, Eastern Research Group, Inc.
Christy Mil stead, Eastern Research Group, Inc.
Program Overview
Jane Anderson thanked the participants for attending the meeting and indicated that the
EPA is looking for comments on the draft specifications. The participants introduced
themselves.
J. Anderson provided an overview of the EPA's Water Efficiency Program, which is a
voluntary private-public partnership program that was initiated to protect the future of the
nation's water supply through the promotion and enhancement of water efficient products
and services. The mission of the Program is to change the way that Americans think
about water. The EPA is looking to transform the marketplace through this program to
make water efficient products, practices, and systems a preferred choice among
consumers and businesses. The Program goals are to reduce water and wastewater
infrastructure costs and to conserve water resources for future generations by raising
awareness of the importance of water efficiency, ensuring product performance, assisting
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with the differentiation of products and services, promotion of product development, and
supporting state and local water efficiency efforts.
The Water Efficiency Program will label products based on their performance following
testing at independent third party facilities. Water efficient service programs will also be
labeled.
J. Anderson briefly explained the differences between the product and service
components of the Program. The products that are labeled through the Program will be
backed by the credibility of the EPA; will be promoted through partnerships with utilities,
manufacturers, and retailers; will realize water savings on a national level; will be about
20% more water efficient than the average counterpart; will perform as well or better than
less efficient counterparts; will achieve water efficiency through multiple technology
options; will be effectively differentiated by a product label; will be independently
verified; and will provide measurable results. The services in this program must
demonstrate a higher level of efficiency requirements/achievements than their peers;
provide quantifiable results in terms of water savings; be easy to find and use; and should
not require end-user sacrifice in terms of convenience, comfort, hygiene, health or safety.
Lastly, the professional certification program will have verified knowledge of water-
efficient principles and procedures.
There are several key roles for the partner organizations in this Program, including the
EPA, local utilities, manufacturers and service providers, and retailers. The EPA will
strive to create the ethic of water efficiency through education and awareness; will build,
monitor, and protect the program brand; will support the framework for certification
applications; and will publish a web-based registry of certified products and services.
Local utilities will promote the certified water-efficient products and services to
customers and will promote the program brand by using materials developed by the EPA.
The manufacturers and service providers will manufacture water efficient products or
support services independently verified to meet the EPA criteria for efficiency and
performance, and will label and promote those products and services. The retailers will
stock, promote, and sell water efficient products.
J. Anderson indicated that the EPA has spoken with a number of stakeholders in
developing the draft criteria. The public comment period provides an opportunity for
broader participation. EPA has also developed draft criteria for High Efficiency Toilets
(HETs). The Water Efficiency Program's first stakeholder meeting, to discuss the HET
spec, was held on Friday, April 28, 2006.
Product and service categories planned for the Program include residential plumbing
products, certification programs for irrigation professionals, irrigation products,
commercial plumbing products, and new homes.
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The EPA Water Efficiency Program approach to landscape irrigation is to address both
the service aspects of irrigation systems as well as the component products. The purpose
of the landscape irrigation product specifications will be to differentiate products in the
marketplace based on their water efficiency and performance. Draft specifications will be
developed for controllers and soil moisture sensors, with the intent to complete the
specifications prior to the next irrigation season.
The purposes of the Irrigation Certification Program recognition are to promote training
and certification among irrigation professionals and to encourage consumers to select
irrigation professionals who have shown a commitment to water efficiency, by achieving
certification through a recognized program. It was noted that the Program is not
certifying individuals.
The Water Efficiency Program is taking a process oriented approach to qualifying
programs. The recognition criteria include requirements for experience, an exam, and
renewal of certification. The EPA criteria lay out broad content areas that must be
covered, relying on an oversight committee to attest to the quality of the specific content
covered by the certification program. Certification Programs wishing to earn EPA Water
Efficiency Program recognition must also meet criteria for minimum acceptable
experience for candidates, must have their certification exams reviewed periodically, and
must include a process for candidates to demonstrate continued proficiency for renewal
of their certification.
There are three categories of certification programs: Irrigation Designer, Irrigation
Auditor, and Irrigation Installation and Maintenance Professional. J. Anderson described
the specification development process and indicated that following this meeting the
specifications will be finalized based on the comments received. The participants were
informed that the meeting was being recorded and were asked to identify themselves
when speaking.
Discussion of General Program Approach
The participants discussed the qualification of potential service providers. Gene Reagan
suggested the development of specific criteria for service providers. Brent Mecham
suggested that the certification program have one test standard (i.e. one set of tests), with
multiple certification providers. G. Reagan expressed concern for the fact that there are
no criteria developed indicating who may be a provider of recognized certification
programs. G. Reagan recommended the development of specific criteria of the
sponsoring organization. For example, the sponsoring organization should be in place for
a specified number of years, have no conflict of interest, and should not be in the business
of supplying products. He stated that it should be an educational institution, a
foundation, or a private institution.
The participants discussed the different types of training programs in the industry. L.
Haveruk indicated that there is a lot of training within the industry, although the
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Irrigation Association is the main provider of training. However, a few suppliers and
manufacturers also provide training. Tom Kimmell explained that once the EPA develops
a certification program, an "industry" will develop to fill the niche (i.e. certifications),
which may potentially lead to quality assurance issues. T. Kimmel stated that EPA
should define who the provider can be and what criteria they should meet. G. Reagan
provided information on the certification program in Texas, and explained the issues with
training. Due to the fact that the program was run by a state agency, one particular service
or product could not be endorsed, which created a conflict because many manufacturers
provide training. Tim Malooly commented that one main motivation of manufacturers in
providing training is the lack of comprehensive, organized, and consistent training of
irrigation professionals. However, if good programs were to be developed through the
EPA Water Efficiency Program, then manufacturers' training programs may not be
necessary anymore.
J. Anderson addressed the differences between training and certification programs, and
explained that the EPA chose to focus on a certification program because of the
complications involved with training. T. Kimmell indicated that in the IA there is only
one certification that requires IA training, the auditor certification. Andy Smith
commented that if individuals can demonstrate their capabilities through the attributes of
certification program, then they should be certified. G. Reagan agreed, stating that the
training will fall into place following the establishment of the certification programs and
recommended that EPA look at training in the future.
Jane Anderson asked whether the program was starting at a good point, or if the
certification program should begin at a more basic level. Art Elmers indicated that the
market will create the necessary programs in order to certify individuals. B. Mecham
explained that in Colorado, there are some certified irrigation professionals that are not
necessarily competent, and thus the water utilities are not seeing any water savings. A.
Elmers stressed the importance of having a mechanism to remove individuals'
certification if they are not practicing water efficient technologies as trained. A. Smith
suggested continuing education approval as a possible solution and asked G. Reagan to
explain the continuing education process in Texas. In the Texas program, the training
provider must be approved to provide continuing education for licensing as well as have
the training material approved by the state. However, the Texas program has lost integrity
due to the fact that the criteria for approval of a training provider are not that stringent.
J. Anderson informed the group that this is addressed in the Independent Oversight
Committee requirement in the specifications. The participants were asked if this
requirement adequately addressed concerns or if the EPA should contract a group of
irrigation professionals to review materials. A. Elmers noted that contracting a group of
irrigation professionals would assist with standardization. T. Kimmell indicated that
having the EPA perform this function would not really add value, rather add another
layer to the process. L. Haveruk directed the participants to Section 2.1, the Independent
Oversight Committee section of the draft criteria and indicated that the current wording
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already addresses these issues. T. Kimmell suggested that the Independent Oversight
Committee be composed of six professionals instead of three. T. Kimmell also suggested
that full time employees hold less than one-third of the positions, rather than one-half.
Dale Morehouse raised the issue of certified individuals competing with individuals that
are not certified and how those that are not certified can be expected to do the job
correctly. J. Anderson explained that the EPA hopes that once the Program is in place, it
will assist the certified individuals with obtaining business due to public recognition of
the Water Efficiency label; however, those that are not certified cannot be stopped from
selling their services. A. Elmers indicated that the EPA would drive the market to accept
certified individuals, similar to the Energy Star program.
G. Reagan indicated that irrigators in Texas are really excited about the weight EPA's
name will carry in the certification program because there is a need in Texas to raise the
level of professionalism. L. Haveruk added that an individual that does not recognize the
value of a system installed by a certified irrigation professional is not the target customer.
T. Malooly stressed the need for incentives and encouragement for those individuals that
are practicing water efficiency and for those irrigation professionals that are installing
water efficient systems. He stated that the EPA should create certification endorsements
for programs that are rigorous and demanding, and keep a high educational standing in
the programs. T. Malooly suggested that the EPA encourage state programs and water
purveyors to support those professionals that are certified with incentives. A. Elmers
suggested one such incentive, in which during drought conditions, individuals that do not
have an irrigation system installed by certified irrigation professionals are restricted in
their water use.
L. Haveruk provided a comment on Section 2.3, the Exam Requirement, and suggested
the inclusion of a hands-on component to the exam. One example would be to require
individuals to design and build an irrigation system to pass the test. A. Elmers stressed
the need to include a mechanism to address recertification and elimination of certified
individuals who are no longer competent. T. Malooly suggested the inclusion of hard
evidence of the individual's proficiency in the renewal process of the program, for
example, inclusion of pictures, documents signed by a local agency, etc. Warren
Gorowitz asked if there are any other certification programs that the EPA could use as a
model. J. Anderson indicated that the Energy Star did certify contractors for HVAC
systems; however, the program was moving away from this.
W. Gorowitz indicated that Ewing offers training classes to customers free of charge and
is interested in being able to offer a certification program to customers. The distribution
companies have a strong reach to the contractors. Additionally, a number of Ewing
employees have been through the IA certification program, and therefore want to ensure
that these employees can be brought up to the same level. W. Gorowitz provided
information on the C27 license process in California and the shortage of funds to enforce
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those individuals practicing without the C27 license. A. Elmers suggested that public
education of the EPA program may address this issue.
J. Anderson confirmed that the participants have expressed the need for enhancing the
renewal process and for inclusion of practical hands on training in the certification
programs.
B. Mecham mentioned that "maintenance" is not included in the testing subject material
criteria for the Irrigation Installation and Maintenance professional specification;
however, it is mentioned in the Irrigation Designer and Auditor specifications. He
suggested that water management and maintenance should be combined and inserted into
Section 2. 3.1 of all specifications.
T. Malooly stated the differences between maintenance with respect to warranty and to
water delivery adjustments should be clear. A. Smith suggested adding maintenance to
the auditor program. Lawrence Budd suggested the addition of post installation
inspections to auditing. T. Kimmell suggested adding a maintenance repair test, to ensure
that the person being certified can go beyond identifying what is wrong in a text book
situation, but can actually apply that knowledge in the field.
Dan Fuhrman suggested the addition of a fourth certification program, Landscape Water
Management certification. J. Anderson indicated that other stakeholders have provided
similar comments and that the EPA will look into this. J. Anderson asked the participants
if this would be a substitute program or an add-on to the current three certification
programs. The participants indicated that this program should be at a higher level, with
prerequisites along with other elements to prove the individual has a high level of water
efficiency knowledge.
T. Kimmel explained that each of the IA certification programs vary in their knowledge
requirements and complexity. For example, the auditor is the "kindergarten" of the
certifications. It is a one day course and exam, where the designer certification is
multiple courses and years of experience. B. Mecham explained that the term
'certification' does not distinguish between levels of experience and testing, as in a trade.
J. Anderson recognized this difficulty and asked if there were any suggestions for
addressing this issue. T. Malooly indicated that in Minnesota, there are different terms
used: accreditation, certification, and licenseship, each with corresponding elements.
W. Gorowitz expressed support of the proposed Water Management Certification and
provided information on the California AB2717, which was looking at AB325. Water
districts have expressed the need to get contractors more knowledgeable of water
management, and one suggestion was for a water management certification program to be
developed. However, this program was not developed because they were not sure it
would meet the EPA certification criteria. B. Mecham indicated that the IA does have a
water management component, but it needs to be revamped to meet EPA certification
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criteria. T. Kimmell stated that the current certification programs are a starting point, and
a Water Management Certification could be the next step. L. Budd indicated that there is
a masters program in water conservation currently in development at CSU, and water
management training could also be included in this program.
T. Malooly asked J. Anderson if the EPA had a timeline for measuring the effectiveness
of the program. J. Anderson indicated that there is no set date at this point, and that the
initial metrics will be the number of partners signed, with the goal of measuring water
savings in the long run.
Steven McCoon stated that there needs to be a benefit to contractors practicing water
efficiency. There are many rebates offered to homeowners for products that don't save
water because they are not being properly managed. A contractor with a close
relationship with the end user is where savings will occur. A. Smith brought up protection
of the trade name and fraud prevention.
T. Kimmell asked whether the certification program falls under the EPA or the new
Water Efficiency organization. J. Anderson informed the participants that it is the EPA
Water Efficiency program. T. Malooly inquired if there was funding for a national
advertisement campaign over a sustained period of time. J. Anderson indicated that print
public service announcements (PSA's) are currently in development. The current
program budget does not include broadcast PSA's.
G. Reagan inquired of EPA' s limitations on enforcement. J. Anderson reminded the
participants that this is a voluntary program and that EPA will not be the police, rather it
is the responsibility of the certification program to ensure that the standards are being
met. The EPA will monitor label use. T. Malooly suggested a requirement stating that a
program must self enforce. The participants discussed this topic. T. Kimmell explained
that certification means an individual has a level of understanding, and a certification
cannot be removed. T. Malooly stated that the topic of enforcement should not be
discussed at this point in time in order to allow the programs to continue.
T. Kimmell suggested the three certifications programs as the base. The Water
Management Certification, once launched, would have more qualification requirements.
B. Mecham indicated that the Best Management Practices had a financial incentive for
participants; however, this program lacks any incentive. One suggestion would be for
manufacturers or distributors to offer discounts to those irrigation professionals that were
installing water efficient technologies. J. Anderson indicated partnerships will be planned
with distributors, who will be asked to support the program.
The participants discussed the difficulty in getting irrigation contractors to install water
efficient technology. W. Gorowitz indicated a financial incentive is needed for the
contractor to get them to use these products. Currently, the incentives go to the individual
paying the water bill, the homeowner. The homeowner gets excited for water savings; but
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the contractor tells the customer that the products don't work. Therefore there is a need
for some kind of incentive to the contractors. L. Budd suggested that the EPA
recommend to cities and agencies the use of certified contractors, which would give
certified contractors a better shot of getting jobs.
L. Haveruk suggested the separation of the Irrigation Installation and Irrigation
Maintenance professionals. L. Haveruk also suggested the addition of scheduling to the
Irrigation Designer exam requirements. The addition of water use budgeting was also
discussed. However, G. Reagan indicated that there is the phrase 'site appropriate
irrigation scheduling' in the Irrigation Designer and Installer requirements; therefore this
is covered. J. Anderson asked if the language was clear enough and the participants
agreed.
With respect to Section 2.4.1, L. Haveruk suggested that all three certification programs
be renewed every year instead of every two years. J. Anderson explained the proposed
grandfathering process at the renewal level of certification following implementation of
the certification program.
A. Smith requested that the certification criteria be publicly available, and posted on a
website for consumers to view, should they desire to. J. Anderson indicated that the
criteria will be posted on the EPA website, and that partners could link to this website. A.
Smith also suggested the maintenance of a real-time certification database that is readily
accessible for the public to verify those that are truly certified. A link from the EPA
website to a database of certified individuals was another suggestion.
T. Malooly suggested that the EPA review the certification programs every five years or
upon demand.
B. Mecham raised a question of concern regarding the three programs: How will
individuals be discouraged from getting the easiest certification just to be certified by the
EPA. For example, why not just get the Auditor Certification and say you have an EPA
recognized certification. J. Anderson indicated that this area is being explored. It was
noted that the contractor is not getting certified, the program is getting certified.
J. Anderson indicated that a name for the EPA Water Efficiency Program has not been
decided at this time. Participants were informed that controllers and sensors are currently
being researched, and that if there is any interest in these areas, the process is informal
until the draft specifications are released.
L. Haveruk recommended additional programs in the future to include certified water
manager and certified irrigation technician.
Irrigation System Auditor Certification
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L. Haveruk indicated that the term 'auditor' is much more encompassing than in previous
years, and includes assessing, fixing, auditing, and retrofitting. The participants briefly
discussed changing the name from Irrigation Systems Auditor; however, no decisions
were made. The term 'auditor' is what is used in the industry and the terms 'irrigation
system auditor' in the specification should address these concerns.
G. Reagan expressed concern with the lack of experience requirement for the Irrigation
System Auditor certification, stating that in order to maintain the integrity of the auditing
certification, there should be criteria for specified training or experience. J. Anderson
confirmed with participants that a hands-on piece should be added to the auditor program.
A. Elmers stated that there is a difference between auditors that simply make
recommendations to those that also specify what areas need to be fixed. For example,
there are auditors in NYC that audit for all types of water use, not specifically irrigation.
B. Mecham suggested that potential auditors complete an apprenticeship prior to
certification, for example, the completion of five audits with a certified auditor and
submit those to demonstrate the individual's knowledge and experience. J. Kind asked if
an apprenticeship would burden the auditor and B. Mecham explained that it would be
beneficial for both parties.
J. Anderson asked the participants to focus on the draft certification criteria for the three
irrigation programs for the remainder of the discussion. The participants discussed the
Irrigation System Auditor certification. G. Reagan suggested the inclusion of
prerequisites for auditor certification. T. Kimmell suggested that the Irrigation System
Auditor certification be set up as an entry level program, with intent to teach people how
an irrigation system is designed. In this program, an auditor would not be certified until
the individual had completed a number of audits for submission to the Certification
Board. B. Mecham recommended the use of the term 'accredited auditor' prior to
certification. T. Kimmell suggested the term 'practicing auditor.' Jodi Johnston suggested
that this requirement should be expanded to the maintenance certification as well due to
the fact that there are newer products on the market every year. G. Reagan indicated that
the Irrigation Designer and Irrigation Installer certification programs already have a three
year requirement. J. Anderson asked if there was a need for specific documentation or
demonstration of experience. L. Haveruk suggested an approach in which the auditor in
training is responsible for a book, which has to be signed off by someone indicating the
individual has completed the hands-on experience. S. Smith suggested this process be
completed through sponsorship.
T. Kimmell indicated that in the exam content section, the auditor system maintenance is
good to know, but is not a minimal level. A. Elmers suggested the insertion of
'identification/recognition of system maintenance requirements' to the exam content. G.
Reagan suggested the addition of 'knowledge of system components' to the exam
content. The participants discussed the responsibilities of an irrigation auditor. Due to the
evolution of the responsibilities of irrigation auditors, T. Malooly suggested the creation
of levels of auditing based on experience. For example, an accredited auditor level and a
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higher level, but not quite at level of water management. The participants discussed the
use of another term other than 'auditor' due to its negative connotation to the public.
Other suggestions included assessor, evaluator, water conservation practitioner, and
system evaluator. G. Reagan indicated that there is a lack of standardization among
different cities of what water auditing entails. In some areas it also includes indoor
plumbing. J. Anderson reminded participants that the full title is Irrigation System
Auditor or Certified Irrigation Landscape Auditor. The inclusion of a 'definition of
terms' to help clarify the definitions was suggested.
Irrigation Designer
A. Elmers suggested the addition of text in the Designer Specification Section 2.3.1
regarding reclaimed/recycled water use. J. Anderson asked if it would be applicable
across all jurisdictions. L. Haveruk indicated that the addition of this text would
demonstrate efficient irrigation. A. Elmers suggested addition of 'evaluation of available
water sources.'
G. Reagan commented on the Irrigation Designer exam content, and recommended that
'hydraulics and pumps' be changed to 'system hydraulics' and 'system pumps' as two
separate bullets. T. Kimmell recommended the inclusion of OSHA rules and regulations
and electrical circuit operations to the exam content. The participants discussed the
inclusion of electrical circuitry inclusion and agreed that it should be added. J. Kind
asked participants if there was consensus to add these two pieces, and the participants
indicated that the electrical circuit operations should go to the Designer certification and
OSHA to the Installer certification. L. Budd suggested the addition of water budgeting to
the Irrigation Designer Specification under 2.3.1, the exam content. S. McCoon suggested
the addition of filtration knowledge to the Irrigation Designer exam content requirement.
A. Elmers suggested the addition of the phrase, 'assessing water source and quality.' J.
Anderson reminded the participants that these were minimum requirements, and that
programs could go above and beyond those listed in the specification. T. Malooly
suggested using the text, 'consider but not limited to' for section 2.3. 1, to highlight this.
It was suggested that the term 'drainage' in section 3.1 of the Irrigation Designer
specification, be changed to 'slope and runoff
With respect to Section 2.4.2, Maintained Proficiency, T. Malooly suggested having a
methods and practice manual requirement for candidates to submit. For example, creation
of a manual of processes that have been completed could be submitted.
In section 1.0, Scope and Objectives of the Irrigation Designer certification, T. Malooly
suggested inserting 'develop design and/or written specifications' or 'develop
construction documents.'
T. Malooly recommended adding Errors and Omissions insurance as an Irrigation
Designer requirement. A. Smith indicated that the Irrigation Designer program could
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instead be marketed to the insurance company. L. Haveruk mentioned that this
requirement might limit some people due to financial constraints. The participants
reached consensus to discuss this requirement at a later date.
The Irrigation Designer draft certification criteria were discussed. With respect to section
2.3.3, G. Reagan commented on the independent testing organization, and indicated that
this needs to be an individual that understands how to develop exam questions and write
exam questions that are readily recognized, clear, and concise. J. Anderson indicated the
draft language attempts to address this and asked participants for better wording. B.
Mecham suggested a professional test writers group. J. Johnston suggested reviewing the
exam every year rather than every two years due to the changing industry. T. Kimmell
indicated that the IA reviews the exam internally twice a year and that there is no outside
review of the exam. T. Kimmell provided input on having a university review test
questions. J. Anderson informed the group that the intent is for an analysis of how well
the question tests for knowledge. T. Kimmell briefly explained the process within IA. It
was noted that a requirement for an annual review might be burdensome for some
institutions financially. J. Anderson suggested splitting the requirements for internal and
external review. For example, EPA could require an internal review every year and an
external review once every three or 5 years. A. Elmers noted that the requirement
already states that a periodic technical review is required, and this can be left to the
specific program.
Irrigation Installation and Maintenance Professional
G. Reagan suggested that the Irrigation Installer certification specification include
language stating that the installer must comply with local regulations/state regulations. J.
Anderson asked how this process would be enforced in a certification program, due to
geographic and state differences.
The participants discussed the Irrigation Installation/Maintenance Professional draft
certification. It was noted that a previous comment was to separate the two. A. Elmers
indicated that the language in section 1.0 is not consistent due to the use of 'irrigation
practitioner' instead of 'irrigation professional.'
Closing Remarks
J. Anderson reviewed the timeline for completion and indicated the comment period is
open until May 26, 2006. The specifications should be finalized in the June/July
timeframe and qualification applications will be accepted shortly thereafter.
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