WaterSense® Notice of Specification Review
Public Meeting Summary
WaterSense® Notice of Specification Review
Public Meeting Summary
February 14, 2019, 2:00 to 4:00 p.m. Eastern, Webinar
Meeting Summary
Stephanie Tanner, the U.S. Environmental Protection Agency's (EPA) WaterSense program's
Lead Engineer, welcomed everyone to the meeting, clarified how to use the webinar software,
and reviewed the meeting agenda and purpose for the audience. The purpose of the webinar
was to provide an overview of the WaterSense program, introduce requirements from the
America's Water Infrastructure Act of 2018, and review the WaterSense Notice of Specification
The WaterSense Notice of Specification Review and the PowerPoint slides from this
presentation can be reviewed on the WaterSense website at
www.epa.gov/watersense/product-specification-review. A full list of the attendees and a list of
presenters are presented in Appendix A. The presentation discussion as well as participant
questions and comments are summarized below.
1.	Introduction
Ms. Tanner provided an overview of WaterSense, a voluntary program that labels water-
efficient, high-performing products, and described the program's history, vision, and typical
practices. She also reviewed the wide array of labeled product categories and trends in
WaterSense labeled technology adoption rates and the number of labeled product models
across categories. She discussed the program's accomplishments, noting that, through 2017,
WaterSense has helped save 2.7 trillion gallons of water and $63.8 billion in water and energy
Ms. Tanner then provided an overview of the America's Water Infrastructure Act of 2018, which
included authorization of the WaterSense program and defined the scope of products and
systems that could be included in the program. The America's Water Infrastructure Act also
directed EPA to conduct a comprehensive review of product specifications developed prior to
2012. Ms. Tanner explained the criteria EPA will use to determine if major revision of a given
specification is warranted. She then reviewed which specifications are eligible for review and
revision, including the specifications for tank-type toilets, flushing urinals, lavatory faucets and
faucet accessories, showerheads, and weather-based irrigation controllers. She concluded this
section by reviewing information related to the release of the WaterSense Notice of
Specification Review, which is the subject of the webinar.
2.	WaterSense Evaluation Criteria for Specification Revisions
EPA has not yet made a major revision to a product specification, only issuing slight
modifications or clarifications. However, in 2014, EPA revised the WaterSense Professional
Certification Program Labeling System for irrigation professionals. Ms. Tanner noted that EPA
plans to engage with industry throughout this specification review and revision process. Ms.
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WaterSense® Notice of Specification Review
Public Meeting Summary
Tanner then discussed the conditions that may trigger a technical revision to a WaterSense
specification, as detailed in the WaterSense Program Guidelines
(www.epa.gov/watersense/proqram-quidelines). and the criteria EPA considers in determining
the feasibility or necessity of a revision. She explained that EPA is seeking feedback on these
criteria or other factors it should consider for each specification undergoing EPA's review. She
then reviewed the general questions EPA requests stakeholders consider when providing
feedback on any or all of the specifications.
•	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)?
•	For each product specification, what water efficiency improvements should be made to
the WaterSense specification?
•	For each product 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?
•	For each product specification, 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?
•	For each product specification, what unintended consequences could result from
increasing water efficiency requirements of a WaterSense specification?
•	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.
Participant Questions
"Why was the specification for pre-rinse spray valves sunset?" Ms. Tanner explained that the
U.S. Department of Energy (DOE) updated the national standard to essentially meet the
WaterSense level, leaving very little room for a revised WaterSense specification with stricter
water efficiency criteria. Following a discussion with manufacturer partners, EPA received
industry support to sunset the specification.
"Does EPA coordinate its specifications with similar activities in different states to avoid
conflicts?" Ms. Tanner explained that, in general, EPA works with states to harmonize their work
and product test protocols but has no control over states' decisions. EPA shares information
and communicates consistently with states and standard committees to work bilaterally
throughout their regulation development processes.
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WaterSense® Notice of Specification Review
Public Meeting Summary
"Would EPA consider looking at drain line carry and low-flow thresholds?" Ms. Tanner
responded yes and noted that EPA would be very interested in any information stakeholders
could share to update EPA's research on the topic. She also described EPA's previous
collaboration with National Institute of Standards and Technology (NIST), which helped produce
the original WaterSense specification for tank-type toilets.
"Would EPA consider non-water or active enzyme urinal models?" Ms. Tanner noted that EPA is
not pursuing this product category at this time but would be open to any information
stakeholders would like to share. She then clarified that the urinals discussed in this
presentation were flushing urinals, which already have a WaterSense specification in place.
"Would EPA consider labeling water softeners?" Ms. Tanner noted that EPA currently has a
Notice of Intent (NOI) available on water softeners, but EPA received significant pushback from
wastewater utilities, and therefore, is not pursuing this product category at this time.
3. Summary of WaterSense Product Specifications and Market Information
Robbie Pickering (Eastern Research Group, Inc. (ERG)) summarized the current information
WaterSense has regarding the specification criteria and product market for tank-type toilets,
flushing urinals, lavatory faucets and faucet accessories, and showerheads, which are each
eligible for revision. WaterSense intends to build upon this information through collaboration
with interested stakeholders to inform its specification revision decisions. Mr. Pickering clarified
that EPA has not yet conducted new market research, and market data presented for each of
the specifications are based on information reported to WaterSense by its manufacturer
Plumbing Fixtures
Mr. Pickering reviewed the respective histories and statuses of the two plumbing fixture
WaterSense specifications eligible for review: tank-type toilets and flushing urinals. He also
reviewed the water efficiency and performance criteria stipulated in each specification and
EPA's current considerations and outstanding questions about revision, which include changes
in the market place, potential expansion of scope, and overall plumbing system concerns.
Participant Questions
"Would EPA consider updating the flush performance criteria for tank-type toilets?" Mr.
Pickering responded EPA does not currently track individual product performance levels
because product evaluation for the WaterSense label is pass/fail. However, there are other
testing programs that EPA could look to for independent data to support differentiated
thresholds for consideration.
"Does EPA expect to rely on existing data and studies for revisions to standards? Or does EPA
anticipate conducting further data collection and study in 2020 and beyond, based on the
comments it receives through this process?" Ms. Tanner responded that EPA will initially rely on
a review of existing data and stakeholder submissions but may pursue additional research when
evaluating individual product specifications. However, the timeline (the review must be
completed by the end of calendar year 2019) does not allow for extensive data collection efforts.
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WaterSense® Notice of Specification Review
Public Meeting Summary
"Why are toilets required to be ceramic?" Ms. Tanner clarified that this is not a requirement in
the WaterSense Specification for Tank-Type Toilets.
"Will EPA evaluate/endorse water saving features to be included in toilet manufacturing that are
newly patented but are not yet manufactured?" Ms. Tanner clarified that, while EPA does keep
well-informed on new and innovative technologies in the plumbing industry, the WaterSense
program is not intended to recognize these specific innovative technologies. The program also
does not directly recognize proprietary technologies.
It was suggested that EPA consider research and study of sensor-activated flush toilets. Ms.
Tanner responded that most of the program's research to date has shown that these
technologies are not generally associated with considerable water savings. Ms. Tanner also
clarified that EPA does not look at the activation mechanism in the product but rather the water
saving mechanism.
"In addition to potential premise plumbing impacts, does EPA consider potential impacts to
utilities' water distribution systems and sewer collection systems?" Ms. Tanner responded that
EPA certainly considers these impacts as part of its evaluation criteria. She also noted that EPA
would be open to discussions with stakeholders and to reviewing empirical data on this topic.
"How is WaterSense tied up with sustainability and does EPA collaborate with U.S. Green
Building Council (USGBC)?" Ms. Tanner responded that WaterSense is a tool in the proverbial
water efficiency toolkit, however, it is not a lifecycle program. She also clarified that EPA does
collaborate with USGBC and other green building standards but does not have any specific
initiatives developed with them.
In regards to hybrid urinals, a commenter indicated that "it is important to point out to
stakeholders that the ASME A112.19.19 standard includes a definition and performance criteria
for drain cleansing features [for non-water urinals]; so, while you indicate that there is only one
product [currently on the market], there [are] no constraints on other products to be developed
and tested to the same standard. One issue missing from the specification for flushing urinals is
that it allows a manufacturer of WaterSense labeled flushing urinals to provide electronic control
that can automatically change the flush volume in excess of that allowed under WaterSense.
There should be explicit language prohibiting this unless data is provided that proves this saves
water." Ms. Tanner responded that the WaterSense specification does include criteria
prohibiting manufacturers from providing information on how to change the flush volume of
labeled products, but electronic flush mechanisms are a technological problem that arose after
the publication of the WaterSense Specification for Flushing Urinals. She noted EPA would be
interested in discussing this issue further with stakeholders and manufacturers.
"The toilet specification should be updated to limit the maximum flush volume to be 1.28 gallons
per flush (gpf) for the full flush on dual flush toilets—this would ensure water savings despite
user selection of the correct flush." Ms. Tanner responded that EPA would consider this.
"Are the savings claims made by WaterSense based on engineering studies or based on actual
consumption studies at homes (using data loggers)?" Ms. Tanner noted that the program relies
largely on existing data for estimating water savings, as opposed to collecting primary data.
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WaterSense® Notice of Specification Review
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However, for products without clear water savings studies or performance criteria, EPA has led
the effort to develop research or test methodologies. EPA's work with pre-rinse spray valves is
an example of its primary data collection.
A number of questions were received inquiring about the materials used for the presentation,
Ms. Tanner clarified that the presentation slide deck, a meeting summary, and a recording will
all be made available on the WaterSense Product Specification Review web page
Plumbing Fittings
Mr. Pickering reviewed the histories and statuses of the two WaterSense specifications for
plumbing fittings eligible for review: lavatory faucets and faucet accessories as well as
showerheads. He also reviewed the water efficiency and performance criteria stipulated for
these specifications and EPA's current considerations and outstanding questions regarding
revisions, including changes in the market place, potential expansions of scope, health and
safety issues, and plumbing system concerns.
Participant Questions
"Has WaterSense seen a significant reduction in the number 1.5 gallons per minute (gpm)
models being certified now that the California standard is 1.2 gpm?" Ms. Tanner responded that
EPA will look into that information. Mr. Pickering noted an increase in WaterSense labeled 1.2
gpm models in recent reporting years based on the California standard.
"Would EPA consider revisions for preventing/revoking labels for products like showerheads
that have "easily" removable flow restrictors? This is especially important for municipalities that
use the WaterSense specification to offer rebates to reduce water use rather than just replace
an old showerhead." Ms. Tanner acknowledged that the current national standard covering
showerheads has requirements regarding the difficulty of removing the flow restrictor and EPA
can examine this in conjunction with the standards committee. Mr. Pickering noted that the
current WaterSense specification prohibits manufacturers from sharing this type of information
with customers, although EPA cannot control what other plumbing professionals or consumers
choose to post on the internet. The commenter responded that, "The issue with people adjusting
flow rates is that landlords are the ones that install the showerheads and the tenants increase
the flow rates to meet their preferences." Another commenter indicated that tamper proofing is
beneficial for jurisdictions that rely on WaterSense as the maximum standard.
"What does EPA mean by "deck mounted" faucets, in reference to new faucet categories?" Mr.
Pickering clarified that this term implies bar faucets or possibly laundry faucets and
acknowledged that EPA has received many inquiries from manufacturers on eligibility of these
types of faucets; however, a specific definition may not be available at this time.
"Is there a department in California that one could visit to place standards prior to the national
standards?" Ms. Tanner noted that plumbing or water efficiency standards are typically
established by the California Energy Commission (CEC), but CEC does not work with the
national standards body, which is DOE.
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WaterSense® Notice of Specification Review
Public Meeting Summary
"In addition to trends in new certifications for lavatory faucet models, would it be possible to
make similar data available to stakeholders for the other specifications as part of this review?"
Ms. Tanner responded that EPA would look into establishing trends as part of its product
"Instead of reducing the flow rate required for labeling across the board, would it be worthwhile
to adopt a multi-level labeling option?" Ms. Tanner explained that EPA made a conscious choice
at the outset of the WaterSense program not to produce a tiered labeling system to simplify
consumer choice. It also helps streamline product testing for manufacturers.
"Is WaterSense going to consider graywater technologies for labeling?" Ms. Tanner explained
that EPA is not currently opposed to or actively pursuing this technology category, but more
information would be needed for the program to further progress in this development. Mr.
Pickering noted that EPA would be interested in any information that contributes to
standardizing product performance or water savings in this product category.
Irrigation Controllers
Joanna Kind (ERG) reviewed the history and status of the WaterSense Specification for
Weather-Based Irrigation Controllers. She explained the different terms and types of products
covered under this specification and the test method currently used for specification testing.
She reviewed the water efficiency and performance criteria stipulated for this specification and
EPA's current considerations and outstanding questions on revision, including changes in the
market place, planned changes to the test protocol, updating water savings estimates, and
reevaluating product marketing and labeling requirements.
Future Product Categories
Ms. Kind discussed the additional products and product categories included within
WaterSense's purview, as discussed in the America's Water Infrastructure Act of 2018, and she
encouraged those that would like EPA to develop a WaterSense specification for products that
fall within these categories to submit comments and appropriate data for EPA consideration.
She also acknowledged the products categories for which EPA recently released NOIs: pool
covers and soil moisture-based control technologies. She concluded by reviewing both the
technical and market factors that EPA uses to evaluate product candidates.
4. Timeline, Comment Deadline, and Future Stakeholder Meetings
Ms. Tanner reviewed the next steps in the specification review process and reminded attendees
to submit comments, data, and questions on the WaterSense Notice of Specification Review to
watersense-products@erg.com. She noted that submissions must be received by March 15,
2019 to ensure they will be considered in the review process but emphasized that EPA was
eager to review all information. She also reviewed the instructions for claiming submissions as
confidential business information (CBI). Ms. Tanner then reviewed the tentative schedule for
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WaterSense® Notice of Specification Review
Public Meeting Summary
upcoming product-specific industry webinars scheduled throughout Spring 2019 and noted that
EPA will work with industry representatives to schedule these meetings.
Ms. Tanner concluded the webinar by reviewing the typical specification development and
revision process and indicated where within this process EPA currently stands regarding
specification reviews, which is Product Research. She also emphasized that if extensive
changes are made to a specification, then products must be transitioned and possibly re-
certified to the new specification. If required, EPA will have extensive conversations with
stakeholders on how to most efficiently execute this transition with minimal pain to stakeholders.
A grace period will likely be part of this transition. Ms. Tanner concluded by providing contact
information for the program and reiterating the Product Specification Revision web page,
Participant Questions
"How can I participate in the industry webinars?" Ms. Tanner explained that interested parties
should contact their industry representatives and those that received notice of this webinar will
receive notice of future webinars.
"What kind of data would EPA want to review from water utilities to determine if a specification
needs to be revised?" Ms. Tanner explained they would like to know what utilities are
comfortable promoting in a potential specification or revision. She also noted EPA would be
particularly interested in information in problems wastewater utilities encounter with declining
"Since EPA has looked at irrigation controllers, is there any appetite to look at cooling tower
controllers?" Ms. Tanner noted that EPA is already researching this product category but is
approaching it from a new systems-based approach, modeled after the work EPA has
accomplished in the irrigation industry. "Is EPA aware of the Alliance for Water Efficiency
(AWE) Cooling Tower Research?" Ms. Tanner acknowledged that EPA is aware of this
"What is the timeline on the systems certification?" Ms. Tanner noted that there is no timeline
associated within this certification at this time, and the specification review process will take
priority within the program.
"Are there any notable changes to annual reporting?" Ms. Tanner explained that some minor
changes occur every year and these changes were recently discussed with manufacturers. This
information is available on the WaterSense website.
"Beyond your compatibility list for irrigation controllers, are you considering some kind of online
tool that's easier to navigate?" Ms. Tanner explained EPA has limited ability to maintain online
tools, so the spreadsheet summarizing irrigation controller compatibility (available at
www.epa.gov/watersense/product-search) is the current priority.
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WaterSense	Public Meeting Summary
Ms. Tanner adjourned the meeting by encouraging those with outstanding questions to contact
the WaterSense Helpline at watersense@epa.gov or (866) WTR-SENS (987-7367) and
thanking everyone for their participation.
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WaterSense® Notice of Specification Review
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Appendix A: Meeting Participants
Jordan Acton
Jacob Adili
Abbie Batog
NSF International
John Bertrand
Fortune Brands Global Plumbing Group
Veronica Blette
U.S. Environmental Protection Agency (EPA)
Savannah Block
The Russell Group
Melissa Bomar
City of Tempe (Arizona)
Steve Bruce
Bruce Media Group-Patent Owner
Jill Brumand
City of Scottsdale (Arizona)
Matt Bruns
The Toro Company
Eileen Burke
Florida Home Partnership
Kevin Cavaioli
General Public
Tyler Cain
Lightly Treading, Inc.
Celeste Calhoun Johnson
Sloan Valve Company
Maribel Campos
ICC-Evaluation Services (ES)
Adam Carpenter
American Water Works Association (AWWA)
Joe Cavett
QAI Laboratories
Siying Chen
Masco Corporation
Bill Christiansen
Alliance for Water Efficiency (AWE)
Jim Cika
International Code Council (ICC)
Amber Clark
Sharon Clement
Town of Danvers, Public Works (Massachusetts)
Matthew Conway
Rain Bird
Cara Corbin
City of Flagstaff Water (Arizona)
Stephanie Cote
City of Guelph (Ontario, Canada)
Shahram Dalvand
Rain SpA
Brittney Darnell
City of Fresno (California)
Jennifer Davidson
City of Surprise (Arizona)
Edwin deLeon
Golden State Water Company (California)
Dan Denning
City of Bend (Oregon)
Shirley Dewi
Holly Dickman
City of Hays (Kansas)
Matt Domski
Minnesota Technical Assistance Program (MnTAP)
Kelly Doyle
City of Fort Collins Utilities (Colorado)
Michael Dukes
University of Florida
Julius Duncan
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WaterSense® Notice of Specification Review
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Kevin Ernst
Gene Faasse
T&S Brass and Bronze Works, Inc.
Nicholle Fratus
Contra Costa Water District (California)
Rob Furioso
Rochelle Gandour-Rood
Tacoma Water (Washington)
Bill Gauley
Gauley Associates Ltd.
Jeffrey Gerbick
Delta Faucet Company
Mark Gibeault
Kohler Company
Daniel Gleiberman
Sloan Valve Company
Jessica Gomez
Estrada Construction, LLC
James Harris
Rain Bird
Richard Harrison
Control Precipitation Design, Inc.
Larry Himmelblau
Chicago Faucets
Nicole Haynes
Region of Waterloo (Ontario, Canada)
Jonathan Hole
Masco Canada
Gina Holguin
Ed Hooper
City of San Juan Capistrano (California)
Greg Hunt
Chicago Faucets
Michael Hafliger
Franke Water Systems
Kelsey Jacquard
Hunter Industries
Ronn Jefferson
The Chicago Faucet Company / Geberit
Parker Johnson
T&S Brass and Bronze Works, Inc.
Kevin Kennedy
Niagara Conservation
John Koeller
MaP Testing
Thomas Kramer
Kohler Company
Louis Ku
Foremost Groups, Inc.
Deb Lane
City of Santa Rosa (California)
Nat Lee
NSF International
Brian Lee
Sonoma Water/Sonoma-Marin Saving Water Partnership
Will Leonard
LTS Design Group
Duncan Liang
CSA Group
Sean Liu
Pioneer Industries
Mark Malatesta
LIXIL Water Technology America (LWTA)
David L Marbry
Fluidmaster, Inc.
Ramiro Mata
American Society of Plumbing Engineers (ASPE)
Chris McDonald
Fortune Brands Global Plumbing Group
Bill McDonnell
Metropolitan Water District of Southern California
Cary McElhinney
U.S. EPA, Region 5
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WaterSense® Notice of Specification Review
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Lisa McEvilly
Kliman Sales. Inc.
Kevin McJoynt
Cambria Mcleod
Kohler Company
Jayant Mehta
Andrew Morris
Metropolitan North Georgia Water Planning District
Tara O'Hare
Diane Ortiz
City of Fresno Water Conservation (California)
Thomas Pape
AWE / Best Management Partners
Preston Peterson
Water Pik, Inc.
Meghan Phillips
Delta Faucet Company
Wendy Pratt
Zurn Industries, LLC
Prasanth Ramakrishnan
International Accreditation Service (IAS)
Shabbir Rawalpindiwala
Kohler Company
Julie Riddle
SiteOne Landscape Supply
Tessa Roscoe
Eastern Research Group, Inc. (ERG)
Al Strickland
Stephanie Salmon
Plumbing Manufacturers International (PMI)
Sayetsi Sanchez
City of Woodland (California)
David Schwartzkopf
Willoughby Industries
David Searcy
Medford Water Commission (Oregon)
Danira Serrano
Farhad Shahriary
Acorn Engineering Company
Ralph Siciliano
Matt Sigler
Brian Skeens
Marco Spaeth
Elena Surovtsev
STG Engineering Inc.
David Thomas
CSA Group
Gary Tilkian
Metropolitan Water District of Southern California
Culver Van Der Jagt
Van Der Jagt Law Firm
Kimberly Wagoner
Robert Wanvestraut
South Florida Water Management District
Jeff Waterman
Liberty Pumps, Inc.
John Watson
Abby Williams
Kearns Improvement District
Rebecca Winters
Region of Peel (Ontario, Canada)
Judy Wohlt
Ron Wolfarth
Rain Bird
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WaterSense® Notice of Specification Review
Public Meeting Summary
Roberto Zanola
CSA Group

Stephanie Tanner
Joanna Kind
Robbie Pickering
Magaly Orozco
February 14, 2019