EPA
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AA/atCl*ScUSC WaterSense Notice of Specification Review
WaterSense® Notice of Specification Review
I. Introduction and Background
WaterSense is a voluntary partnership program sponsored by the U.S. Environmental
Protection Agency (EPA). The program's foundation is the WaterSense label, which identifies
products that have been third-party certified to be at least 20 percent more water efficient and
perform as well as or better than standard models. WaterSense released its first product
specification for tank-type toilets to earn the label in January 2007. The program has since
developed a total of eight product specifications for plumbing and irrigation products, as well as
specifications for homes and professional certification programs. Through 2017, WaterSense
labeled products have helped consumers save more than 2.7 trillion gallons of water and $63.8
billion in water and energy bills.
On October 24, 2018, the America's Water Infrastructure Act of 20181 formally authorized the
EPA's WaterSense program. The new law requires that, not later than December 31, 2019, the
EPA shall "consider for review and revise, if necessary, any WaterSense performance criteria
adopted before January 1, 2012." This necessitates the review of several specifications,
including WaterSense's specifications for tank-type toilets, lavatory faucets and faucet
accessories, showerheads, flushing urinals, and weather-based irrigation controllers. It also
includes WaterSense's specification for homes; however, the EPA is currently in the process of
revising that specification under a separate effort.2 WaterSense has also released specifications
for flushometer-valve water closets, spray sprinkler bodies, and pre-rinse spray valves3, as well
as irrigation professional certification programs. Because these specifications were published or
underwent major revision after January 1, 2012, the EPA is not considering these specifications
in its review effort.
Consistent with existing program guidelines, in revising a WaterSense specification, the law
states that the EPA shall:
(A) Provide reasonable notice to interested parties and the public of any changes, including
effective dates, and an explanation of the changes;
(B) Solicit comments from interested parties and the public prior to any changes;
(C) As appropriate, respond to comments submitted by interested parties and the public;
and
(D) Provide an appropriate transition time prior to the applicable effective date of any
changes, taking into account the timing necessary for the manufacture, marketing,
training, and distribution of the specific water-efficient product, building, landscape,
process, or service category being addressed.
With this Notice of Specification Review, the EPA is engaging interested stakeholders in the
specification review process and, as a first step, is inviting stakeholders to provide feedback on
whether it is appropriate to revise the WaterSense specifications for tank-type toilets, lavatory
1 America's Water Infrastructure Act of 2018. www.congress.qov/bill/115th-conqress/senate-bill/3021/text
2 Learn more about the revision process related to the WaterSense specification for homes at:
www.epa.aov/watersense/homes-specification#HomeNOI
3 The EPA is in the process of sunsetting the WaterSense Specification for Commercial Pre-Rinse Spray Valves on
January 1, 2019. Learn more at: www.epa.qov/sites/production/files/2018-10/documents/ws-products-commercial-
prsv-notice-sunset.pdf
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faucets and faucet accessories, showerheads, flushing urinals, and weather-based irrigation
controllers. Section II of this notice provides some general criteria and initial program
considerations for revising the specifications. Section III provides a summary of the current
specifications and market for each product category, as well as considerations for a potential
revision. Section IV summarizes general questions for stakeholders to consider for each
specification when providing feedback to WaterSense on whether to revise a specification.
Lastly, Section V discusses the review process, beginning with this notice, and tentative timeline
for the EPA's activities.
As required by the America's Water Infrastructure Act of 2018, where feasible and appropriate,
WaterSense will continue working with standard development bodies to collect pertinent
information, and as appropriate, adopt or revise consensus performance and efficiency criteria
and test methods that will form the basis for its specification revisions.
II. WaterSense Criteria and Considerations for Specification Revisions
The EPA intends to evaluate a variety of factors as it considers the specifications for review and
revision. These factors may include additional water savings potential, continued applicability or
availability of efficiency and performance test methods and criteria, availability of more efficient
products in the marketplace, potential for specification scope expansion, and/or unintended
impacts of further flow reductions on the systems in which the products may be installed.
To provide transparency in its decision-making process, the EPA intends to use the following
criteria and considerations to determine whether it will revise each of the applicable
specifications. The EPA is seeking feedback regarding these criteria or other factors it should
consider.
Within the WaterSense Program Guidelines.4 the EPA includes conditions that might trigger a
technical revision to a specification. For product specifications, these conditions are described
below.
• WaterSense labeled products in a specific category comprise a significant portion of the
market share based on the number of units shipped as reported by WaterSense
partners. In this instance, market share means the ratio of WaterSense labeled units to
non-WaterSense labeled units sold in the same product category.
• The EPA identifies significant and broadly available improvements in technology or
product design in any labeled product category that improves the product's water
efficiency. In this context, significantly improved products include products that are
approximately 10 percent more efficient or higher-performing than current WaterSense
labeled products, are offered by multiple manufacturers, and/or capture approximately
10 percent or more of the total market share for that product category.
• The EPA becomes aware of performance issues associated with products that are
currently labeled under the specification.
• A water efficiency standard is adopted nationally that would mandate product efficiency
equivalent to that in the specification, such that the WaterSense label would no longer
differentiate products that were more efficient than those meeting the national standard.
4 WaterSense Program Guidelines, Version 5.3. December 2016. www.epa.qov/sites/production/files/2017-
02/documents/ws-proaram-auidelines.pdf.
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The EPA will also consider the following in determining the feasibility in establishing, or in this
case, revising a product specification:5
• Equal or superior product performance compared to conventional models.
• Potential for significant water savings on a national level.
• State of technology development—product categories that rely on a single, proprietary
technology will not be eligible for the label.
• Assurance that the development (or revision) of a specification will not lead to
unintended or negative environmental or economic impacts.
• Ability to measure and verify water savings and performance.
• Cost-effectiveness.
In the context of the criteria above, the EPA will review the scope, efficiency, and performance
criteria within each specification under consideration for revision to determine if updates are
necessary. The EPA will also review the current product marketplace, including product
shipment data submitted by WaterSense manufacturer partners as part of annual reporting, to
understand the market share of WaterSense labeled products and learn about technological
advancements and subsequent efficiency and performance improvements that have been made
since each specification's initial release.
III. Summary of Current Product Specification and Market Information
The following section presents a summary of the current information WaterSense has regarding
the specification criteria and market for each product category. WaterSense intends to build
upon this information through this notice and future collaboration with interested stakeholders to
inform its specification revision decisions and process. Table 1 summarizes specification,
manufacturer partner, and labeled model information related to the five specifications
WaterSense is considering for revision. The subsections below include additional information
and considerations for each product category.
Table 1. Summary Information for WaterSense Specifications Considered for Revision
Specification
Release
Date
Last
Revision
Reference Standards6
Approximate
Number of
Manufacturer
Partners7
Number
of
Labeled
Models7
WaterSense
Specification
for Tank-Type
Toilets
January
24,2007
June 2,
2014
(Version
1.2)
American Society of
Mechanical Engineers
(ASME)
A112.19.2/Canadian
Standards Association
(CSA) B45.1
142
3,400
5 As explained in the "How Does WaterSense Develop Specifications for Products to Earn the Label?" section of the
WaterSense website. www.epa.aov/watersense/product-specifications#pane-5
6 Reference standards refer to the consensus-based performance and efficiency test protocols that WaterSense has
partially or fully adopted, by reference, within each specification.
7 As of November 2, 2018.
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Table 1. Summary Information for WaterSense Specifications Considered for Revision
Approximate
Number of
Number
of
Release
Last
Manufacturer
Labeled
Specification
Date
Revision
Reference Standards6
Partners7
Models7
High-Efficiency
Lavatory
Faucet
October 1,
2007
N/A
ASME A112.18.1/CSA
B125.1
295
16,243
Specification
WaterSense
ASME A112.19.2/CSA
Specification
for Flushing
Urinals
October 8,
2009
N/A
B45.1; American Society of
Sanitary Engineering
(ASSE) 1037
25
602
WaterSense
July 26,
Specification
for
Showerheads
March 4,
2010
2018
(Version
1.1)
ASME A112.18.1/CSA
B125.1
178
8,212
WaterSense
Specification
for Weather-
Based
Irrigation
Controllers
November
3, 2011
N/A
Smart Water Application
Technologies (SWAT) Test
Protocol for Climatologically
Based Controllers (8th Draft)
with modifications
32
792
Tank-Type Toilets
The EPA released the WaterSense Specification for Tank-Type Toilets on January 24, 2007.
The EPA has since completed two minor revisions to the specification, releasing the latest
version (Version 1.2) in June 2014. Under the WaterSense Specification for Tank-Type Toilets,
tank-type toilets must meet the criteria summarized below, as applicable, to earn the
WaterSense label:
• Toilets shall conform to applicable requirements in ASME A112.19.2/CSA B45.1
Ceramic Plumbing Fixtures. Toilets with dual-flush capabilities shall conform to
requirements in ASME A112.19.14 Six-Liter Water Closets Equipped with a Dual-
Flushing Device.
• The effective flush volume shall not exceed 1.28 gallons (4.8 liters).
• Toilets shall pass flush performance criteria based on testing conducted in accordance
with the waste extraction test protocol provided in ASME A112.19.2/CSA B45.1.8
• Products shall be marked with the flush volume according to ASME A112.19.2/CSA
B45.1.
The 1.28 gallons per flush (gpf) flush volume criteria represents a 20 percent reduction in water
use compared to the 1.6 gpf federal standard established by the Energy Policy Act of 1992
(EPAct 1992). The performance requirements referenced in the specification reflect the current
consensus standards for this product category in the United States and Canada.
8 The waste extraction test requires toilets to clear 350 grams of miso paste and four balls of toilet paper.
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To date, approximately 142 manufacturers have produced 3,400 WaterSense labeled tank-type
toilet models. Table 2 provides a summary of the number and percentage of labeled tank-type
toilet models within different flush volume ranges.
Table 2. Number and Percentage of WaterSense Labeled Tank-Type Toilet Models by
Flush Volume (gpf)
Effective Flush
Volume9
< 1.28 gpf and
> 1.1 gpf
<1.1 gpf and
>1.0 gpf
<1.0 gpf and
>0.8 gpf
< 0.8 gpf
Number of Models
2,627
438
265
70
Percent of Total
77.3%
12.9%
7.8%
2.1%
WaterSense is exploring several areas related to revising the tank-type toilet specification
including further reducing the flush volume and enhancing the performance requirements. Some
initial program considerations and questions include:
• Changes in the market. At least six states and multiple municipalities throughout the
United States have adopted regulations mandating that tank-type toilets operate at a
flush volume of 1.28 gpf or less, consistent with the WaterSense specification. In a
potential revision, should WaterSense consider additional reductions to the maximum
allowable effective flush volume criteria to improve water efficiency beyond the current
WaterSense specification and potentially further transform the market?
• Performance considerations. Because the specification criteria are set to pass or fail,
WaterSense does not collect data on the specific levels of product performance (e.g.,
the amount of waste each toilet can clear). However, Maximum Performance (MaP)
Testing, upon which the WaterSense waste extraction performance test was originally
based, conducts independent testing of tank-type toilets to assess performance beyond
the criteria established by WaterSense. WaterSense requires toilets to fully flush 350
grams of miso paste, a test media having similar physical properties to human waste,
along with toilet paper. MaP evaluates tank-type toilet flushing performance up to 1,000
grams, issuing a MaP score commensurate to the grams of waste evacuated from the
toilet bowl. To date, 2,163 toilet models have achieved a MaP score of 600 grams or
greater, with 1,418 achieving the maximum allowable MaP score of 1,000 grams.10 Are
stakeholders aware of data to support a connection between increased performance and
user satisfaction? Should WaterSense consider revising its performance criteria to
require tank-type toilets to clear a larger quantity of waste and/or toilet paper?
• System concerns. If WaterSense reduces the maximum allowable effective flush
volume for tank-type toilets, will this have a significant and adverse impact on premise
plumbing systems (e.g., drainlines)? If so, are there data to substantiate the impact at
various flush volume levels?
Lavatory Faucets and Faucet Accessories
The EPA released the High-Efficiency Lavatory Faucet Specification on October 1, 2007, and
has not revised the specification since its initial release. Lavatory faucets and faucet
9 Dual-flush tank-type toilets are listed based on their effective flush volume, calculated by averaging the flush volume
from one full-flush and two reduced-flushes.
10 MaP Testing. Tank-type Toilets Complete MaP List. November 5, 2018. www.map-testina.com/downloads.html
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accessories (e.g., flow restrictors, flow regulators, aerator devices, laminar devices) must meet
the criteria summarized below, as applicable, to earn the WaterSense label:
• Lavatory faucets and faucet accessories shall conform to applicable requirements in
ASME A112.18.1/CSA B125.1 Plumbing Supply Fittings and NSF/ANSI Standard 61
Drinking Water System Components - Health Effects, Section 9.
• The maximum flow rate shall be equal to or less than 1.5 gallons per minute (gpm) (5.7
Liters per minute [Lpm]) at a flowing pressure of 60 pounds per square inch (psi).
• The minimum flow rate shall not be less than 0.8 gpm (3.0 Lpm) at a flowing pressure of
20 psi.
• The product and/or product packaging shall be marked with the maximum flow rate.
The 1.5 gpm flow rate criteria represents a 32 percent reduction in the maximum allowable flow
rate when compared to the 2.2 gpm federal maximum flow rate standard established by the U.S.
Department of Energy (DOE).11 The performance requirements referenced in the specification
represent the current consensus standards for this product category in the United States and
Canada.
To date, approximately 295 manufacturers have produced more than 16,000 WaterSense
labeled lavatory faucet and lavatory faucet accessory models. Table 3 provides a summary of
the number and percentage of lavatory faucet and faucet accessory models labeled within
different flow rate ranges.
Table 3. Number and Percentage of WaterSense Labeled Faucet and Faucet Accessory
Models by Flow Rate (gpm)
Maximum Flow Rate
< 1.5 gpm and
> 1.2 gpm
<1.2 gpm and
>1.0 gpm
<1.0 gpm
Number of Models
9,669
5,657
917
Percent of Total
59.5%
34.8%
5.6%
WaterSense is exploring several areas related to revising the lavatory faucet specification
including additional reductions to the lavatory faucet flow rate and expanding the scope of the
specification to include other faucet types. Some initial program considerations and questions
include:
• Changes in the market. At least four states and multiple municipalities throughout the
United States have adopted regulations mandating that lavatory faucets operate at a
maximum flow rate of 1.5 gpm or less when tested at a flowing pressure of 60 psi,
consistent with the WaterSense specification. California requires lavatory faucets to
have a flow rate of 1.2 gpm or less, which is a 20 percent reduction in maximum flow
rate compared to the WaterSense specification. As indicated in Table 3, there are
currently products available in the marketplace that can meet the lower maximum flow
rate criteria California established, while also adhering to WaterSense's minimum flow
11 EPAct 1992 originally set the maximum allowable flow rate for both lavatory and kitchen faucets at 2.5 gpm at 80
psi. In 1994, ASME established a performance standard in A112.18.1M-1994 to which all faucets were required to
comply and set the maximum flow rate for lavatory faucets at 2.2 gpm at 60 psi. In response to industry's request for
conformity with a single standard, DOE adopted a uniform standard maximum flow rate of 2.2 gpm at 60 psi for all
faucets in 1998.
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rate requirement of 0.8 gpm at 20 psi. In a potential revision, should WaterSense
consider additional reductions to the maximum allowable flow rate criteria to improve
water efficiency beyond the current WaterSense specification and potentially further
transform the market?
• Potential scope expansion. WaterSense is considering expanding the scope of the
High-Efficiency Lavatory Faucet Specification to accommodate other faucet types. Since
the specification's release, manufacturer and promotional partners and other
stakeholders have inquired about the potential for WaterSense to label other faucet
types that are common in homes and businesses, such as kitchen faucets or metering
faucets. In considering this scope expansion, WaterSense is interested in feedback on
the potential water efficiency and performance criteria it should establish for these other
faucet types. WaterSense is also interested in potential water savings estimates from
each potential faucet type (i.e., kitchen, deck mounted, metering, other flow control
devices) that could be achieved from installing higher efficiency products in place of
standard models.
Flushing Urinals
The EPA released the WaterSense Specification for Flushing Urinals on October 8, 2009, and
has not revised the specification since its initial release. Urinal fixtures and flushing devices
must meet the criteria summarized below, as applicable, to earn the WaterSense label:
• The average maximum water consumption must not exceed 0.5 gpf (1.9 Lpf), when
tested in accordance with ASME A112.19.2/CSA B45.1, ASME A112.19.3/CSA B45.4
Stainless Steel Plumbing Fixtures, or IAPMO Z124.9 Plastic Urinal Fixtures,12 as
applicable.
• Urinal fixtures must conform to ASME A112.19.2/CSA B45.1, ASME A112.19.3/CSA
B45.4, or IAPMO Z124.9, as applicable, when tested with a flushing device with the
same rated flush volume.
• Pressurized flushing devices must conform to ASSE #1037 Performance Requirements
for Pressurized Flushing Devices for Plumbing Fixtures,13
• Flush tank (gravity type) flushing devices must conform to ASME A112.19.2/CSA B45.1.
• The flushing device must not contain a flush volume adjustment that allows the flush
volume to vary more than ±0.1 gpf and may not be packaged, marked, or provided with
instructions directing a user to an alternative flush volume setting.
• The urinal fixture and flushing device product and product packaging must be marked
with the rated flush volume.
The 0.5 gpf flush volume criteria represents a 50 percent reduction in water use from the current
1.0 gpf federal maximum flush volume standard established by EPAct 1992. The performance
requirements referenced in the specification represent the current consensus standards for this
product category in the United States and Canada.
To date, approximately 25 manufacturers have produced more than 600 WaterSense labeled
product models—including flush devices, fixtures, and urinal systems (combinations of urinal
12IAMPO Z124.9 has since been superseded by CSA B45.5/IAPMO Z124 Plastic plumbing fixtures.
13 ASSE 1037 has since been superseded by ASSE 1037/ASME A112.1037/CSA B125.37 Performance
Requirements for Pressurized Flushing Devices for Plumbing Fixtures.
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flushing devices and fixtures). Table 4 provides a summary of the number and percentage of
labeled models within different flush volume ranges.
Table 4. Number and Percentage of WaterSense Labeled Flushing Urinal Models by Flush
Volume (gpf)
Flush Volume
< 0.5 gpf and
> 0.25 gpf
< 0.25 gpf and
> 0.125 gpf
<0.125 gpf
Number of Models
265
88
249
Percent of Total
44.0%
14.6%
41.4%
WaterSense is exploring several areas related to revising the flushing urinal specification
including further reducing the flush volume. Some initial program considerations and questions
include:
• Changes in the market. At least five states and multiple municipalities throughout the
United States have adopted regulations mandating that urinals have a flush volume of
0.5 gpf or less, consistent with the WaterSense specification. California requires wall-
mounted urinals to have a flush volume of 0.125 gpf or less, although non-wall mounted
urinals can have a flush volume up to 0.5 gpf. In a potential revision, should WaterSense
consider reducing the maximum allowable flush volume criteria to improve water
efficiency beyond the current WaterSense specification and potentially further transform
the market?
• System concerns. If WaterSense reduces the maximum allowable flush volume for
urinals, will it have a significant and adverse impact on premise plumbing systems (e.g.,
drainlines)? If so, are there data to substantiate the impact at various flush volume
levels?
• Potential scope expansion. As explained in WaterSense's Guidance on inclusion of
non-water using urinals in water efficiency incentive programs,14 WaterSense does not
intend to incorporate non-water urinals into its specification for flushing urinals. Non-
water urinals that meet applicable ANSI and ASME standards are inherently water-
efficient. However, there is at least one product (called a hybrid urinal) that combines the
non-water urinal technology with a periodic drainline clearing flush. WaterSense is
interested in more information on the long-term performance and water efficiency of this
product type, as well as an indication of whether there are other similar products on the
market.
Showerheads
The EPA released the WaterSense Specification for Showerheads on March 4, 2010. In 2018,
WaterSense completed a minor revision to the specification, releasing Version 1.1. The minor
revision reflected 2018 revisions to the ASME A112.18.1/CSA B125.1 Plumbing Supply Fittings
standard and revised, through reference to ASME A112.18.1/CSA B125.1, the spray force
performance testing protocol to accommodate high-efficiency rain showers, which have become
more popular for consumers since the EPA released the original specification.
14 Guidance can be reviewed at: www.epa.qov/sites/production/files/2017-01/documents/ws-products-nonwater-
urinal-auide.pdf
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Under the WaterSense Specification for Showerheads, showerheads must meet the criteria
summarized below, as applicable, to earn the WaterSense label:
• Showerheads shall conform to applicable requirements in ASME A112.18.1/CSA
B125.1.
• The maximum flow rate shall be equal to or less than 2.0 gpm (7.6 Lpm).
• The minimum flow rate tested at a flowing pressure of 20 psi must not be less than 60
percent of the maximum flow rate.
• The minimum flow rate tested at a flowing pressure of 45 psi and 80 psi must not be less
than 75 percent of the maximum flow rate.
• The minimum spray force shall not be less than 2.0 ounces at flowing pressure of 20 psi.
• The spray coverage of the showerhead shall meet criteria included in ASME
A112.18.1/CSA B125.1.
• Showerheads and associated packaging shall be marked according to ASME
A112.18.1/CSA B125.1, including the maximum flow rate marking.
The 2.0 gpm flow rate criteria represents a 20 percent reduction in water use compared to the
2.5 gpm federal maximum flow rate standard established by EPAct 1992. The performance
requirements referenced in the specification represent the current consensus standard for this
product category in the United States and Canada.
To date, approximately 178 manufacturers have produced more than 8,200 WaterSense labeled
showerhead models. Table 5 provides a summary of the number and percentage of labeled
models within different flow rate ranges.
Table 5. Number and Percentage of WaterSense Labeled Showerhead Models by Flow
Rate (gpm)
Maximum Flow
Rate
< 2.0 gpm
and
>1.8 gpm
< 1.8 gpm
and
> 1.75 gpm
< 1.75 gpm
and
>1.5 gpm
<1.5 gpm
and
>1.3 gpm
<1.3 gpm
Number of Models
3,549
1,288
2,136
973
266
Percent of Total
43.2%
15.7%
26.0%
11.8%
3.2%
WaterSense is exploring several areas related to revising the showerhead specification
including further reducing the flow rate and enhancing the performance requirements. Some
initial program considerations and questions include:
• Changes in the market. At least three states and multiple municipalities throughout the
United States have adopted regulations mandating that showerheads have a maximum
flow rate of 2.0 gpm or less when tested at a flowing pressure of 80 psi, consistent with
the WaterSense specification. As of July 1, 2018, California requires showerheads to
have a flow rate of 1.8 gpm or less, which is a flow rate that is 10 percent lower than the
current WaterSense specification. In a potential revision, should WaterSense consider
additional reductions to the maximum allowable flow rate to improve water efficiency
beyond the current WaterSense specification and potentially further transform the
market?
• Health and safety impacts. In developing the specification, WaterSense considered
whether reducing the flow rate would increase the risk of thermal shock or scalding. For
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more background, stakeholders should review the discussion in the WaterSense
Specification for Showerheads Supporting Statement15. Since the initial release of the
specification, industry has worked to harmonize the automatic-compensating mixing
valve standard (ASSE 1016-2017/ASME A112.1016-2017/ CSA B125.16-17
Performance requirements for automatic compensating valves for individual showers
and tub/shower combinations) and the showerhead standard (ASME A112.18.1/CSA
B125.1) to address incompatibilities of these plumbing system components and to
ensure products are marked and packaged consistently to educate consumers and
plumbing professionals on these risks. However, WaterSense is interested in feedback
on whether decreasing the flow rate maximum for showerheads could result in additional
concerns related to thermal shock and scalding.
Weather-based Irrigation Controllers
The EPA released the WaterSense Specification for Weather-Based Irrigation Controllers on
November 3, 2011. While the EPA has not revised this specification since its publication,
WaterSense has issued several technical clarifications in the intervening years to clarify the
requirements. The specification applies to stand-alone controllers, add-on devices, and plug-in
devices (collectively referred to in the specification as controllers) that use weather data as a
basis for scheduling irrigation. Controllers must meet the criteria summarized below:
• Irrigation adequacy, as calculated in accordance with the eighth draft of the Smart Water
Application Technologies™ test protocol for climatologically-based controllers (SWAT
protocol) modified by the specification, shall be greater than or equal to 80 percent for
each zone.
• Irrigation excess, as calculated in accordance with the SWAT protocol modified by the
specification, shall be less than or equal to 10 percent for each zone. The average of the
irrigation excess scores calculated across the six zones shall be less than or equal to 5
percent.
• The controller must conform to the supplemental capability requirements specified in
Section 4.0 of the specification, such as the ability to interface with a rainfall device,
capability to accommodate watering restrictions, and inclusion of a percent adjust (water
budget) feature, among others.
The irrigation adequacy criterion is based on well-documented research that indicates the
appearance of warm and cool season turfgrasses do not significantly differ when irrigated
between 80 and 100 percent of their specific evapotranspiration rates16. The irrigation excess
criterion allows for a reasonable amount of variation in controller scheduling but prevents
excessive overwatering.
Weather-based irrigation controllers currently on the market either: 1) utilize onsite weather
sensors; 2) receive a weather signal from a local weather station(s); or 3) use both, to schedule
irrigation to meet plant needs.
15 WaterSense Specification for Showerheads Supporting Statement, www.epa.qov/sites/production/fiIes/2017-
01/documents/ws-products-support-statement-showerheads.pdf
16 WaterSense Specification for Weather-Based Irrigation Controllers Supporting Statement.
www.epa.aov/sites/production/files/2017-02/documents/ws-backaround-controllers-suppstatement.pdf
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Research available at the time of specification publication suggested water savings associated
with this product category to be approximately 15 percent17.
To date, approximately 32 manufacturers have produced nearly 800 WaterSense labeled
weather-based irrigation controller models. Table 6 provides the number of WaterSense labeled
controller models by type18.
Table 6. WaterSense Labeled Weather-Based Irrigation Controller Models by Type
Stand-alone Controllers
Plug-in Devices
Add-on Devices
Number of models
770
19
3
Percent of total
97.2%
2.4%
0.4%
Since the specification was released in 2011, there has been a significant increase in both the
number of brands on the market, as well as the number of labeled models (see Figure 1). There
were only nine manufacturer partners in 2011; that number has grown to almost 45 in 2018.
Similarly, there were approximately 70 labeled models in 2012; that number has grown by a
factor often as of 2018. This is relevant to a potential specification revision because many
manufacturers and other stakeholders currently in the marketplace were not in existence and
able to participate in specification development prior to 2011. Further, due to technological
advancements in the industry, there has been a shift to cloud-based products that make use of
smartphones and smart home devices. WaterSense might want to consider reevaluating its
specification to ensure these products are effectively captured.
Number of Labeled Controller
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4
AA/atCl*ScUSC WaterSense Notice of Specification Review
WaterSense is exploring several areas related to revising the weather-based irrigation controller
specification, including:
• Changes in the market. There has been a significant increase in both the number of
manufacturers and models of weather-based irrigation controllers since the specification
was released in 2011. How does the advent of new technologies in this product category
fit within the current scope of this specification or affect how products within this category
should be defined?
• Planned revisions to the underlying test protocol. The SWAT protocol upon which
the performance criteria are based is under revision as part of the standard development
process. The American Society of Agricultural and Biological Engineers (ASABE) is
currently developing standard X627 Environmentally Responsive Landscape Irrigation
Control Systems, which, in draft form, incorporates the modifications to the SWAT
protocol included in the WaterSense specification, as well as other adjustments to the
test protocol. WaterSense is actively participating in this standard development process
and will consider adopting it by reference within a revised specification upon its
publication.
• Water savings estimates. Several comprehensive water savings studies have been
published for weather-based irrigation controllers since the EPA released the
specification in 2011, suggesting the program's water savings estimates could be
updated to be more accurate. WaterSense requests stakeholders provide additional
studies addressing water savings from this product category. WaterSense intends to
review these studies to determine potential updates necessary to its water savings
estimates for weather-based irrigation controllers.
• Product marking and labeling. WaterSense has received several inquiries from
consumers and utility partners expressing confusion about weather-based irrigation
controller packaging. In July 2018, WaterSense issued technical clarifications19
reiterating its product marking and labeling requirements for weather-based irrigation
controllers. However, WaterSense is interested in further investigating whether the
definitions and packaging requirements for add-on, plug-in, and stand-alone devices are
consistent with the needs and practices in the controller marketplace.
IV. Request for Feedback and Data
Beyond the information, questions, and considerations discussed in each of the product-specific
subsections above, WaterSense asks interested stakeholders to consider the following when
providing feedback on any of the product categories.
• Beyond market transformation and national water savings, what other considerations
should WaterSense include in its decision-making process for specification revision
(e.g., stakeholder support, rebate availability)?
• What water efficiency improvements should be made to the WaterSense specification?
• What updates to performance criteria or referenced standards should WaterSense
consider incorporating into the specification that would benefit the user experience and
ensure long-term water savings?
19 Compendium of WaterSense Product Specification, Certification, and Labeling Clarifications.
www.epa.aov/watersense/product-specifications#pane-4
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AA/atCl*ScUSC WaterSense Notice of Specification Review
• What other classes of products or new technologies within the overarching product
category should WaterSense consider incorporating into the scope of the specification?
• What new studies or data on water efficiency, performance, or water savings related to
these product categories should WaterSense be aware of?
• What unintended consequences could result from increasing water efficiency
requirements of a WaterSense specification?
The EPA also plans to consider resources available to the WaterSense program. WaterSense
continually prioritizes the development of product specifications, technical materials, outreach
campaigns, and other programs based on available resources. The America's Water
Infrastructure Act of 2018 envisions WaterSense as a program "to identify and promote water-
efficient products, buildings, landscapes, facilities, processes, and services in order to, through
voluntary labeling of, or other forms of communications regarding, such products, buildings,
landscapes, facilities, processes, and services while meeting strict performance criteria,
sensibly—(A) reduce water use; (B) reduce the strain on public water systems, community
water systems, and wastewater and stormwater infrastructure; (C) conserve energy used to
pump, heat, transport, and treat water; and (D) preserve water resources for future
generations." Considering this:
• What other categories of products with quantifiable water savings and proven
performance should WaterSense consider labeling? Any suggestions should be
accompanied with data and information to support inclusion in the program.20
V. Process for Specification Revision, Timeline, and Next Steps
Interested parties can provide input to WaterSense in response to information and questions
presented in this Notice of Potential Specification Revisions or otherwise related to these
product categories as written comment to watersense-products@erg.com by March 8, 2019.
All comments, except data claimed as confidential business information (CBI), become a part of
the public record. In the case that comments are CBI, they can be submitted as such through
EPA's contractor, Eastern Research Group, Inc. (ERG). Sensitive business information can be
claimed confidential under 40 CFR Part 2, Subpart B. ERG has an EPA-approved security plan
in place to protect CBI from unauthorized disclosure. All data submitted as confidential will be
handled as such. CBI should not be submitted electronically but can be submitted as a
hardcopy document or on a CD, DVD, or flash drive. Data submitted as CBI will not become a
part of the public record unless aggregated and masked to conceal the identity of the submitter.
Data claimed as CBI should be submitted to:
Eastern Research Group, Inc.
Attn: WaterSense Helpline
2300 Wilson Boulevard, Suite 350
Arlington, VA 22201
WaterSense will accept feedback on the information requested above and will consider all
comments and information provided by stakeholders and the general public related to these
20 For data needs related to the specification development process, see: vwvw.epa.qov/watersense/whv-cant-mv-
product-aet-label
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WaterSense Notice of Specification Review
product categories. WaterSense will also review recent studies, such as the Water Research
Foundation's Residential End Uses of Water, Version 2, and other industry resources to inform
its decision-making process. Lastly, WaterSense also plans to hold stakeholder meetings in
spring 2019 to discuss the information received as a result of this Notice of Specification
Review, as well as other information WaterSense has collected through its own market
research.
WaterSense intends to summarize information collected as part of this process by the end of
2019. At this point, it will also issue a decision on whether or not to move forward with a
specification revision for each product category. If WaterSense determines that a specification
revision is not appropriate at this time, there will be no change to the product water efficiency or
performance criteria, although minor changes could be considered to clarify marking, labeling or
certification issues. If WaterSense determines that a revision would be beneficial for a particular
product specification, it will identify existing data gaps, concerns, and next steps related to
development of a draft specification. WaterSense will provide opportunity for public comments
prior to and following the development of the draft specification, and hold additional stakeholder
meetings, as appropriate, before issuing a final specification. Also, consistent with program
guidelines and provisions of the America's Water Infrastructure Act of 2018, WaterSense will
seek to work with appropriate, applicable, and relevant consensus standards as it makes
changes to specifications.
If WaterSense decides to revise one or more product specifications, it will also consider
revisions to the WaterSense Product Certification System to establish requirements for
manufacturer partners and licensed certifying bodies regarding product certification and labeling
during the transition period between specification versions. Draft revisions to the WaterSense
Product Certification System will be made available for public comments prior to being finalized.
The EPA intends to provide an appropriate transition time prior to the applicable effective date
of any specification revision.
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