Response to Public
     Comments Received
February 2007 Draft WaterSense(
   High-Efficiency Bathroom
   Sink Faucet Specification

       October 1, 2007

                                                            Response to Comments on Draft
                                            High-Efficiency Bathroom Sink Faucet Specification
This document provides WaterSense's responses to public comments received on the February
8, 2007, Draft High-Efficiency Bathroom Sink Faucet Specification. The actual comments can be
viewed at www.epa.gov/watersense/docs/faucet_comments508.pdf.
                                                                         October 1, 2007

                                                           Response to Comments on Draft
        Sff1S€                            High-Efficiency Bathroom Sink Faucet Specification
Issue                                                                           Page
I.    General Specification Comments	4
II.    Comments on Section 1.0-Scope and Objective	6
III.   Comments on Section 2.0-Water Efficiency and Performance	7
IV.   Comments on Section 5.0- Definitions	11
V.    Comments on Supporting Documentation	12
                                                                        October 1, 2007

                                                           Response to Comments on Draft
                                           High-Efficiency Bathroom Sink Faucet Specification

Specification Name

   a.  Several commenters recommended changing the name of the specification from "High-
       Efficiency Bathroom Sink Faucet Specification" to "High-Efficiency Lavatory Faucet
       Specification" for clarity, as this is the terminology used within the industry and in
       referenced standards to describe this category of product.

       Response: WaterSense agrees with this recommendation and has made the appropriate
       changes throughout the specification.

Reference to Standards

   b.  Several commenters recommended updating all  references made to ASME A112.18.1 to
       the full title of the standard, ASME A112.18.1/CSA B125.1.

       Response: WaterSense agrees with this comment and has updated all references to this
       standard throughout the specification and in the  supporting documentation.

   c.  One commenter recommended including a reference to NSF/ANSI Standard 61, Section
       9. This standard addresses the requirements under Section 1417 of the Safe Drinking
       Water Act requiring all pipes and plumbing fittings or fixtures intended to dispense water
       for human consumption to be lead-free.

       Response: WaterSense recognizes the need to clarify that any WaterSense labeled
       faucet or faucet accessory certified  under this specification is also required to comply
       with NSF/ANSI 61, Section 9.  While NSF/ANSI 61, Section 9 is already incorporated by
       reference into ASME A112.18.1/CSA 125.1, and is therefore part of this specification,
       WaterSense decided to make it clear that all WaterSense labeled faucets meet all
       applicable health and safety standards.  Section 2.0 of this specification has been
       updated to include the appropriate reference to the  NSF/ANSI standard. WaterSense
       has also incorporated by reference, in Section 7.0 - Definitions, the appropriate
       definitions found in NSF/ANSI  Standard  61, Section 9.

Product Marking

   d.  Several commenters suggested adding a new section to the  specification to address
       flow rate marking on products and product packaging. Commenters recommended using
       the product and packaging marking requirements delineated in the U.S. Code of Federal
       Regulations (16 CFR Part 305—Rule Concerning Disclosures Regarding Energy
       Consumption and Water Use of Certain Home Appliances and Other Products Required
       Under the Energy Policy and Conservation Act [Appliance Labeling Rule],  §305.11 -
       Labeling for Covered Products).
                                                                        October 1, 2007

                                                            Response to Comments on Draft
                                            High-Efficiency Bathroom Sink Faucet Specification
       Response: WaterSense agrees that a requirement for proper marking of the flow rate on
       products and/or product packaging should be included in the specification. To address
       this comment, the following new section and language has been added to the

             "4.0    FLOW RATE MARKING
             The product and/or the product packaging shall be marked in accordance with 16
             CFR 305.11(f) with the maximum flow rate in gpm and L/min as determined
             through testing and compliance with this specification. Marking shall be in gpm
             and L/min in two-digit resolutions (e.g., 1.5 gpm [5.7 L/min])."

   e.  Another commenter requested that WaterSense require a WaterSense impression
       (either words or label) on the qualifying product itself to make post-installation
       identification easier.

       Response: WaterSense decided not to require the  actual certified products to carry a
       WaterSense impression. While WaterSense acknowledges that identifying labeled
       products after installation can be difficult, requiring manufacturers to imprint faucets,
       aerators, or other flow control devices would be burdensome and in cases of small
       components (e.g., aerators), impractical. The primary purpose of the WaterSense label
       is to help consumers  identify and choose water-efficient products at the time of
       purchase. The appropriate labeling of product packaging will serve this purpose.

Long-Term Durability

   f.   One commenter expressed concern that the long-term durability of water savings is not
       addressed by the specification. Specifically, the commenter cited a lack of criteria that
       addresses clogging of faucet aerators or other flow  control devices and questioned how
       likely these devices are to be retained by consumers if they clog frequently and cannot
       be easily cleaned.

       Response: WaterSense acknowledges that frequency of clogging and the ability of
       users to easily clean faucet accessories may have an impact on the long-term
       sustainability of water savings from these products. One way in  which this issue is
       addressed by the specification is in allowing faucet  accessories  to be removable. When
       WaterSense posed the idea of requiring faucet accessories to be non-removable (to
       decrease the likelihood of vandalism or replacement with a higher flowing accessory),
       interested  parties felt that  including this type of provision would be needlessly design-
       restrictive and could result in  high levels of user frustration and dissatisfaction.
       Interested  parties overwhelmingly indicated that faucet accessories should be
       removable to facilitate cleaning and maintenance.  To address long-term durability in
       terms of continued performance over the product's  life, the ASME A112.18.1/CSA
       B125.1 Plumbing Supply Fittings standard, which is incorporated by reference in the
       specification, requires devices, accessories, or components without moving parts to be
       life-cycle tested.  After 500,000 testing cycles, the faucet or faucet accessory shall
       continue to function as it did in the beginning of the  test and shall not develop any
       defects that could adversely affect their functionality, serviceability, or appearance.
                                                                         October 1, 2007

                                                         Response to Comments on Draft
     SdlSe                             High-Efficiency Bathroom Sink Faucet Specification
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a. One commenter felt that the scope of the specification should be narrowed to just cover
   faucet aerators,  and should not include entire faucets. This commenter stated that
   manufacturers are very unlikely at this time to develop a faucet that meets the
   requirements of this specification; rather they will simply use qualifying aerators. The
   commenter believes that maintaining the specification's current scope is misleading and
   will result in reduced water savings for the nation. The commenter feels that a national
   aerator replacement program targeting the large number of inefficient lavatory aerators
   currently in use has the potential  to yield larger water savings. The commenter also
   believes that homeowners are more likely to replace their inefficient aerators than to
   replace their entire faucet with a WaterSense labeled faucet. In proposing to narrow the
   scope of the specification to aerators only, the commenter does suggest crafting the
   specification so as to allow any faucets developed in the future that meet the
   requirements to qualify for use of the label.

   Response: WaterSense recognizes that many manufacturers will choose to  use
   WaterSense labeled aerators or other  accessories on their faucets to achieve the
   specification requirements. In fact,  WaterSense clarified that a lavatory faucet is
   considered to meet the flow rate requirement if equipped with a lavatory faucet
   accessory that meets the flow rate requirement.  WaterSense, however, has decided not
   to limit the specification to encompass only faucet accessories.  This would preclude a
   manufacturer from internally incorporating a flow rate control mechanism  and would be
   unnecessarily design-restrictive in the  approach to increasing the water efficiency of
   lavatory faucets. Since aerators and other flow control accessories are able to earn the
   WaterSense label individually, local, state, regional, and even national aerator
   replacement programs will still be possible. WaterSense does not believe that revising
   the specification to limit its scope will increase water savings and would be needlessly
   design-restrictive.  WaterSense also intends to educate consumers regarding the value
   of installing a WaterSense labeled faucet accessory as a cost-effective retrofit option.

b. One commenter recommended that the specification state that "needle spray" aerators
   (those that have no screen and emit water in a tight stream) not be allowed to qualify for
   the WaterSense label. The commenter has experienced performance issues related to
   splashing and splattering by  1.0 gpm needle spray aerator attachments.

   Response: While WaterSense has heard complaints concerning faucet accessories
   using this type of spray pattern, WaterSense does not want to endorse or deprecate one
   technology over any other, particularly because some users may find this type of spray
   pattern satisfactory or indeed desirable for their application. In  addition, WaterSense
   does not want to establish requirements that are unnecessarily design-restrictive.
   Rather, WaterSense feels it is up to manufacturers and consumers to decide which
   technologies to market and purchase.  WaterSense may engage in a consumer
   education campaign related to product spray patterns to help consumers  recognize
   there are a variety of products on the market.
                                                                      October 1, 2007

                                                            Response to Comments on Draft
        SeilSe                             High-Efficiency Bathroom Sink Faucet Specification
       Another commenter suggested that WaterSense include a "quarter turn" performance
       standard in regards to the opening and turning-off of faucets. The concern was that
       lavatory faucets that require several rotations of the handle to turn off the water are less
       likely to be turned off by users when performing tasks such as brushing teeth or shaving.
       The commenter points out that lavatory faucet water consumption is a function of not
       only flow rate (i.e., gallons/minute) but also total time of usage. The commenter's
       contention is that users will be more likely to turn off faucets during certain activities with
       a faucet that requires a quarter turn or less (or lowering the handle through an arc of
       less than 90 degrees for single lever faucets) than a faucet that requires multiple turns.

       Response: While WaterSense encourages the manufacture of easy-to-shut off and
       ergonomically correct faucets, it is uncertain at this time whether including this type of
       requirement in the specification will result in any increase in water savings. Furthermore,
       the commenter suggests that a survey is necessary to determine whether a correlation
       with faucet type can be made with the likelihood of end users  to shut-off the faucet when
       brushing teeth.  Without conclusive data indicating that such functionality impacts user
       behavior and increases water savings, WaterSense has concluded that including this
       type of requirement in the specification at the time may be unnecessarily design-

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Faucet Accessory Testing

   a. Several commenters remarked that the specification was too vague as to whether the
      entire faucet (including any flow control accessories) must be tested according to the
      ASMEA112.18.1/CSA B125.1, or whether just the flow control accessory could be
      tested alone. The commenters pointed out that under the current testing protocols, just
      the accessory (e.g., aerator or laminar flow device) can be tested for compliance with the
      standard and any faucet to which it is subsequently attached is assumed to be in
      compliance with the required flow rate as well. The commenters questioned whether
      WaterSense intended to require all faucets and accessories to be tested together to
      qualify for use of the label.

       Response: WaterSense does not intend to change the current testing protocols with this
       specification. It has always been WaterSense's intention that either the faucet or flow
       control faucet accessory be able to earn the WaterSense label. It is also WaterSense's
       intention to allow faucets that are manufactured and sold with WaterSense labeled
       accessories to qualify for and use the WaterSense label. WaterSense clarified the
       language in Section 2.0 to state that "A lavatory faucet is also considered to meet this
       flow rate requirement if equipped with a lavatory faucet accessory that meets this
                                                                         October 1, 2007

                                                            Response to Comments on Draft
                                            High-Efficiency Bathroom Sink Faucet Specification
Establishing Maximum and Minimum Flow Rates

   b.  Several commenters suggested clarifying that the 1.5 gpm flow rate at 60 pounds per
       square inch (psi) is the maximum allowable flow rate and that the 1.2 gpm flow rate at 20
       psi is the minimum allowable flow rate.

       Response: WaterSense has added the terms "maximum" and "minimum" in the revised
       specification to clarify that these are just maximum and minimum flow rates, and that
       flow rates  in between are acceptable.

   c.  Several  commenters expressed concern that setting the maximum allowable flow rate at
       1.5 gpm at 60 psi could actually result in an increase in water consumption in areas
       where 1.0 gpm aerators are already widely used (if homeowners were to replace their
       1.0 gpm aerator with a WaterSense labeled aerator). One commenter also suggested
       that WaterSense did not provide adequate justification for the proposed water-efficiency
       levels in the specification (i.e., maximum and minimum flow rates). The commenter felt
       that these decisions for establishing flow rate requirements should be made based upon
       actual testing and user satisfaction data, not on opinion or a 20 percent improvement in
       water-efficiency guideline. The concern is that WaterSense might  be setting the
       maximum  and minimum flow rates too high when users might in fact be satisfied with
       significantly  lower flow rates. The commenter also pointed out that there are several
       areas of the country where local water utilities have implemented aerator replacement
       programs  using aerators with maximum flow rates below those specified in the draft
       specification, and that have had very high reported levels of user satisfaction. The
       commenter believes WaterSense's objective should be to identify  the lowest water
       use/flow rate that still obtains a 95 percent or greater consumer satisfaction.

       Several  other commenters agreed that consumer satisfaction research should determine
       the minimum flow rate requirements, but argued that this type of research takes
       considerable time to conduct. While this research is being conducted, they see no harm
       in adopting the currently proposed specification. If the research shows that allowing
       products that flow at lower flow rates are acceptable to the end user, the specification
       can always be revised accordingly.

       Response: WaterSense considered data from the Seattle, Washington;1  East Bay
       Municipal  Utility District, California;2 and Tampa, Florida3 retrofit studies and other
       factors in making the flow rate determinations, including examining product performance
       specification sheets for existing products, considering manufacturer and other interested
       party comments and recommendations, and our own technical expertise all within the
       context of the WaterSense program goals. In addition, WaterSense recognizes that
1 Seattle Home Water Conservation Study: The Impacts of High Efficiency Plumbing Fixture Retrofits in
Single-Family Homes, December 2000.
2 Water Conservation Study: Evaluation of High Efficiency Indoor Plumbing Fixture Retrofits in Single-
Family Homes in The East Bay Municipal Utility District Service Area, July 2003.
3 Tampa Water Department Residential Water Conservation Study: The Impacts of High Efficiency
Plumbing Fixture Retrofits in Single-Family Homes, January 2004.

                                       8                                  October 1, 2007

                                                        Response to Comments on Draft
                                        High-Efficiency Bathroom Sink Faucet Specification
    several water utilities across the country have distributed faucet aerators with flow rates
    less than 1.5 gpm and that have demonstrated very high levels of user satisfaction.  In
    response, WaterSense has maintained the maximum flow rate at 1.5 gpm, but has
    lowered the minimum flow rate from 1.2 gpm to 0.8 gpm in order to allow faucet aerators
    with maximum flow rates less than 1.5 gpm to meet the specification and qualify for the
    WaterSense label.

d.   Numerous commenters made recommendations on changes to the proposed minimum
    flow rate of 1.2 gpm at 20 psi. Most commenters recommended lowering the minimum
    flow rate and a few suggested  having no minimum flow rate at all.

    Specific suggestions  for lowered minimums included 1.0 gpm at 20 psi,  1.1 gpm at 20
    psi,  and 0.8 gpm at 30 psi. The commenters that recommend 1.0 gpm and 1.1 gpm at
    20 psi were concerned with user satisfaction  issues when fixed orifice flow restrictors
    are used at low water pressures. Besides the reduction in flow due to low water
    pressures, they also cited the further reduction in flow rates that result from attaching
    any faucet accessory (e.g., aerators) to faucets due to the upstream restriction of the
    faucet. Setting the minimum at either 1.0 gpm or 1.1  gpm at 20 psi essentially requires
    manufacturers to use pressure compensating faucet accessories. They felt this would
    help ensure a high level of user satisfaction.

    One commenter recommended that the minimum flow rate be set at 0.8 gpm at 30 psi.
    This would allow for non-pressure compensating devices and provides a lower minimum
    value that would allow for lower maximum flow  rates.

    A few commenters suggested  using a flow rate differential (instead of establishing a
    single minimum flow  rate) from the faucet or accessory's designed flow  rate to establish
    allowable minimum flow rates (20 percent at 20 psi was recommended). This means
    that a faucet or accessory designed to flow at 1.5 gpm  at 60 psi would be allowed to flow
    at 1.2 gpm at 20 psi.  Similarly, this would mean the minimum allowable  flow rate for a
    1.0 gpm fixture fitting at 60 psi would be 0.8 gpm at 20 psi, and 0.4 gpm at 20 psi for a
    fixture fitting designed to flow at 0.5 gpm at 60  psi. The commenters felt that a benefit of
    this  approach would be to address the concern many other commenters had expressed
    regarding utility sponsored projects that give  away 1.0 gpm or 0.5 gpm fixtures, which
    might not otherwise qualify for the WaterSense label.

    The commenters advocating no minimum flow  rate at all want to also maximize water
    savings by allowing faucets with flow rates lower than 1.5 gpm at 60 psi (e.g., 1.0 gpm
    or 0.5 gpm) to be  used when appropriate conditions exist. Examples provided by these
    commenters included 0.5 gpm fixture fittings  in guest room bathrooms of hotels and
    hospitals with hot water recirculation systems and  good water pressure. Some
    commenters also wanted utilities to be able to continue distributing  1.0 gpm aerators, or
    even 0.5 gpm aerators, as part of their water conservation initiatives and for these
    products to earn the WaterSense label.

    Response: WaterSense strongly believes that there needs to be a minimum allowable
    flow rate to ensure performance and user satisfaction. Based upon the comments
                                                                     October 1, 2007

                                                         Response to Comments on Draft
                                         High-Efficiency Bathroom Sink Faucet Specification
    received; water savings and user satisfaction data generated by the Seattle,
    Washington; Tampa, Florida; and East Bay Municipal Utility District retrofit studies that
    used 1.0 and 1.5 gpm maximum flow aerators; and product flow curves for fixed orifice
    and pressure compensating aerators and laminar flow devices, WaterSense has revised
    the minimum allowable flow rate from 1.2 gpm at 20 psi to 0.8 gpm at 20 psi.

    WaterSense believes that this approach  allows for the greatest degree of design
    freedom for manufacturers  and  helps ensure a high level of performance and user
    satisfaction. With this minimum  flow rate, 1.5 gpm at 60 psi fixed orifice faucet
    accessories and pressure compensating faucet accessories with maximum flow rates as
    low as 1.0 gpm at 60 psi will be able to qualify for the WaterSense label (according to
    currently available product specifications and flow curves). This approach ensures that
    utility programs that are providing 1.0 gpm aerators to their consumers will be able  to
    use WaterSense labeled products to continue to achieve substantial water savings.

    WaterSense decided not to adopt the differential flow rate approach. Regardless of the
    differential, WaterSense felt it would still  need to establish some absolute minimum flow
    rate in order to avoid extremely  low flow  rates, particularly in low water pressure
    settings, that are likely to cause user dissatisfaction. In addition, there are no conclusive
    data correlating minimum flow rates to user satisfaction and to the ability of the lavatory
    faucet to perform its intended functions.  WaterSense has decided to err on the side of
    caution and has set the  minimum allowable flow rate at a level where performance  and
    user satisfaction will be  maintained.  If in  the future, conclusive data become available
    that demonstrates  lower flow rates are acceptable to users, then WaterSense will revisit
    this specification and make any appropriate revisions.

e.   Several commenters lobbied for a provision in the specification allowing lavatory faucets
    with flow rates less than the minimum allowable flow rate (e.g., 0.5 gpm at 60 psi) to
    qualify for the WaterSense label if the faucets or faucet accessories are employed
    specifically in commercial settings with adequate water pressure and where hot water
    recirculating systems are used. The commenters argued that many new "green" and
    LEED certified buildings are using such systems and it would be beneficial to facility
    owners if such systems were recognized by WaterSense.

    Response: Adding language to this specification to allow the use of fixtures with flow
    rates below the allowable minimum only  in certain situations, provided  hot water
    recirculating systems are used or facility  water pressure is above some minimum level,
    goes far beyond what can be tested and certified by the  licensed certifying bodies under
    the current WaterSense certification scheme. Enforcement of the end use of a product
    would be extremely difficult and is currently beyond the capabilities of the WaterSense

    As stated in the specification and the accompanying supporting statement, this
    specification does not apply to faucets intended for public use, which are subject to a
    maximum flow rate of 0.5 gpm at 60 psi as specified in the ASMEA112.18.1/CSA
    B125.1 standard. If WaterSense decides to address water efficiency and performance
    for these types of faucets, it will do so under a separate specification at a later date. To
                                    10                                October 1, 2007

                                                             Response to Comments on Draft
                                             High-Efficiency Bathroom Sink Faucet Specification
       provide further clarification, the scope of the specification has been revised to indicate
       that the specification applies only to lavatory faucets in private use, such as in
       residences, and private restrooms in hotels and hospitals. Metering faucets, lavatory
       faucets in public use, and residential kitchen faucets are not covered by this
       specification. Furthermore,  WaterSense incorporated definitions for public and private
       use from the National Standards Plumbing Code. These are as follows:

              "Private Use - Applies to fixtures for the private and restricted use of one or more
              individuals in dwelling units, including hotel guest rooms and hospital rooms, and
              other facilities that are not intended for public use."

              "Public Use - Applies to fixtures for the unrestricted use of more than one
              individual (including employees) in  assembly occupancies, business
              occupancies, public buildings, transportation facilities, schools and other
              educational facilities, office buildings, restaurants, bars, other food service
              facilities, mercantile facilities, manufacturing facilities, military facilities, and other
              facilities that are not  intended for private use."

Flow Rate Tolerance

   f.   Several commenters recommended deleting the +/- 0.1 gpm variance/tolerance
       proposed in the draft specification and suggested replacing it with the statistical
       measurement technique required under U.S. Department of Energy (DOE)  regulations
       relating to the Energy Policy Act of 1992 (found at 10 CFR Part 430). Commenters felt
       the proposed variance was arbitrary and potentially at odds with DOE's regulations.

       Response: WaterSense agrees with the commenters recommendations and has
       replaced the proposed flow variance/tolerance language with a reference to the
       appropriate DOE regulatory requirements.

IV,                on         5.0  -

(Note: Due to the addition of new sections to the specification, this section has been
renumbered as Section 7.0.)

   a.  Several commenters suggested that the definition for "certified flow rate"  be either 1)
       modified so as not to contain performance requirements, 2) replaced with a definition of
       "maximum flow rate" for clarity, or 3) deleted.

       Response: With the changes made to the variance/tolerance requirement in Section 2.0
       - Water Efficiency and Performance Criteria (see previous comment and response "f." in
       Section III of this document), the term "certified flow rate" has been  removed and no
       longer requires defining.
                                        11                                 October 1, 2007

                                                        Response to Comments on Draft
                                        High-Efficiency Bathroom Sink Faucet Specification

a.  One commenter recommended improving the retail cost and savings analyses provided
   in the WaterSense High-Efficiency Bathroom Sink Faucet Specification Supporting
   Statement by correcting the assumed retail cost of a WaterSense labeled aerator from
   $10 each to no more than $4 each. The commenter also suggested using the
   incremental cost between a new WaterSense aerator and a standard replacement
   aerator in determining the cost effectiveness of these products for consumers. The
   commenter argues that in many cases the consumer is purchasing a new aerator
   anyway, so the true  cost of the WaterSense aerator is the incremental cost above the
   price of the standard aerator. The commenter also recommended including the
   imbedded value of energy in the water supply and wastewater treatment in the cost
   calculations. The commenter felt that this represents a national savings that needs to be

   Response:  WaterSense agrees with the recommendation to use a lower retail cost for
   WaterSense labeled faucet accessories in determining their cost effectiveness and
   payback period. This change has been made in the revised supporting statement
   released with the final specification.

   WaterSense decided not use the incremental cost of a WaterSense labeled aerator over
   a standard  aerator in its cost effectiveness calculations. In these examples, WaterSense
   wants to demonstrate the water, energy, and cost saving benefits of using labeled high-
   efficiency products to promote their use and acceptance. WaterSense feels that by
   demonstrating the potential savings and quick payback period even when paying full
   retail cost to replace a functioning, less efficient aerator with a WaterSense labeled
   product makes a stronger case  for their universal  use. This is consistent with the
   approach WaterSense used for calculating the estimated water savings for the Tank-
   Type High-Efficiency Toilet Specification.

   WaterSense is primarily targeting residential homeowners for its education and outreach
   campaign.  For the purpose of the information contained in the supporting statement,
   WaterSense does not feel that it is necessary to include the national energy,  water
   supply, and wastewater treatment cost savings from reduced water consumption.
   WaterSense agrees that these national savings are significant and a desirable result of
   increasing the efficiency of lavatory faucets, and may provide this information in a
   different format for a different target audience.
                                   12                                October 1, 2007