EPA
Water Sense
Comments on WaterSense®
Notice of Specification Review
March 28, 2019
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AA/aterSense
Comments on WaterSense®
Notice of Specification Review
Table of Contents
Culver Van Der Jagt, Van Der Jagt Law Firm 2
Trav Giese, Giese Construction and Renovation 3
Christopher Radziminski, City of Vancouver, Canada 4
Eileen Chau, Winfield Products 6
MattSigler, Plumbing Manufacturers International (PMI) 7
Andrew D. Morris, Neela Ram, Metropolitan North Georgia Water Planning District 11
JeffTejral, Denver Water 28
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March 28, 2019
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WaterSense
Comments ori WaterSense®
Notice of Specification Review
Commenter: Culver Van Der Jagt
Affiliation: Van Der Jagt Law Firm
Comment Date: February 14, 2019
Email Text:
I would like to be involved in the creation of water sense standards for toilet top
sinks. These devices don't "use" any water for handwashing since they put the water
into the toilet tank for flushing when done with hand washing. This technology has been
successfully used in Japan for over 60 years and saves hundreds of millions of gallons
every day there. The technology is also used in many correctional facilities in the
USA. While I have been introducing my American made equivalent without a water
sense label, I believe water sense labeling is important for this proven technology.
Culver
Email Attachment
Wash your hands and reuse the
water for your next flash
2
March 28, 2019
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EPA
Comments on WaterSense®
Notice of Specification Review
WaterSense
Commenter: Trav Giese
Affiliation: Giese Construction and Renovation
Comment Date: February 18, 2019
Email Text:
Hi,
Would like to see watersense standard required silicone seals gaskets bushings as to
help make toilets & fixture leak free for the life of the products, found toilets with rubber
seals bushings all start to leak or drip at about 10 years of age. & often left in the state
for years or permanently great mitigate any potential water savings & would like to see
all 100% 316 stainless steel parts, thx please reply
3
March 28, 2019
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AA/aterSense
Comments on WaterSense®
Notice of Specification Review
Commenter: Christopher Radziminski
Affiliation: City of Vancouver, Canada
Comment Date: March 8, 2019
Email Text:
Dear Sir / Madam,
Please find attached comments responding to the EPA WaterSense Notice of
Specification Review.
Have a great weekend,
Sincerely, Chris
Christopher Radziminski, M.A.Sc., P.Eng., R.P.Bio.
City of Vancouver | Water Design Branch
1100 - 450 SW Marine Drive, Vancouver, BC V5X 0C3
t: 604.873.7453 | chris.radziminski@vancouver.ca
Email Attachment
Topic: EPA WaterSense Notice of Specification Review Response to Request for
Comments
Comment:
March 8, 2019
Eastern Research Group, Inc.
(EPA WaterSense contractor)
2300 Wilson Boulevard, Suite 350
Arlington, VA 22201
Sent via e-mail: watersense-products@erg.com
Dear Sir / Madam,
This letter provides comments which perhaps will be found useful in your review of the
WaterSense Specification for Tank-Type Toilets.
Currently, the newer WaterSense Specification for Fiushometer-Vaive Water Closets
permits a maximum flush of 4.8 litres (1.28 gallons). This means that the "full" flush
mode of a dual-flush, flushometer-valve toilet must use 4.8 litres (1.28 gallons) or less.
Conversely, the WaterSense Specification for Tank-Type Toilets permits a maximum
effective flush of 4.8 litres (1.28 gallons). This means that the "full" flush mode of a dual-
flush, tank-type toilet can use 6.0 litres (1.6 gallons). The underlying, fundamental
assumption is that for every three flushes, one is a "full" flush and two are "reduced"
flushes.
4
March 28, 2019
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EPA
Comments on WaterSense®
Notice of Specification Review
WaterSense
This assumption does not appear to be unambiguously supported by independent
reviews of user behaviour published in publicly available academic literature: The "full"
flush is often used more than assumed. This is also evident when examining different
sectors, as tank-type toilets can be found in a variety of private-use and public-use
settings such as hotels, restaurants and shops.
In the apparent absence of unequivocal evidence supporting the assumption
behind the "effective flush" concept, as of January 1, 2019 the City of Vancouver
(Canada) has harmonised its requirements for all new toilets using drinking water
to a maximum of 4.8 litres per flush. This change did not affect the majority of toilets
already on the market.
EPA WaterSense may also wish to review the available independent literature on user
behaviour to determine whether the Specification for Tank-Type Toilets could perhaps
harmonise with the Specification for Fiushometer-Vaive Water Closets for a consistent
"maximum flush" of 4.8 litres (1.28 gallons) across all toilet types and flush modes.
Hopefully these comments are helpful, and if you have any questions, please feel free to
contact me.
Yours truly,
[submitted electronically]
Christopher Radziminski, M.A.Sc., P.Eng., R.P.Bio.
Policy Analyst
1100 - 450 SW Marine Drive, Vancouver, BC V5X 0C3
604.873.7453 | chris.radziminski@vancouver.ca
5
March 28, 2019
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EPA
Comments on WaterSense®
Notice of Specification Review
WaterSense
Commenter: Eileen Chau
Affiliation: Winfield Products
Comment Date: March 12, 2019
Email Text:
Hi,
Winfield would like to propose that once a product is tested and listed under UPC, they
should be automatically be listed under WaterSense as well, no need to pay another
charge for another IAPMO certificate, which is what we are doing now. Every year, we
have to pay a fee to IAPMO for keeping WaterSense listing.
In order to get IAPMO UPC listing, the listee has to get the products tested and listed by
IAPMO. Why should EPA has to ask WaterSense participant to get an IAPMO listing and
pay extra fees every year. It is a huge burden for all the participant now. We should not
be required to make double payment for the same requirements.
Thank you.
Eileen Chau
1689 E Mission Blvd.,
Pomona, CA 91766
Tel: (909)666-5111
Fax: (909)666-5266
www.winfieldproduct.com
Working Hours: (M-F)8:00am-4:30pm Pacific Time.
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March 28, 2019
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EPA
Comments on WaterSense®
Notice of Specification Review
WaterSense
Commenter: Matt Sigler
Affiliation: Plumbing Manufacturers International (PMI)
Comment Date: March 14, 2019
Email Text:
Stephanie and Robbie-
Please accept PMI's attached comments for the EPA WaterSense® Notice of
Specification Review. If you have any questions, please do not hesitate to contact me.
Regards,
Matt Sigler
Plumbing Manufacturers International
Technical Director
847-217-7212
Email: msigler@safeplumbing.org
www.safeplumbing.org
Safe, responsible plumbing. Always.
Regards,
Matt Sigler
Plumbing Manufacturers International (PMI)
847-217-7212
msigler@safeplumbing.org
Email Attachment
See pages 8 through 10.
ami
PLUMBING
MAN U rACTUH E R5
INTERNATIONAL «
7
March 28, 2019
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¦ 1111 M PLUMBING
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March 14, 2019
PMI 2019
Board of Directors
Nate Kogler
Bradley Corporation
President
Joel Smith
KohlerCo.
Vice President
Todd Teter
Moen, Incorporated
Secreta ry-T reasu rer
Peter Jahrling
Sloan Valve Company
Immediate Past
President
Chip Way
Lavelle Industries, Inc.
Carol Baricovich
InSinkErator
Stephanie Tanner
U.S. Environmental Protection Agency
Office of Wastewater Management (4204M)
1200 Pennsylvania Avenue, N.W.
Washington, DC 20460
watersense-products@erg.com
RE: EPA WaterSense® Notice of Specification Review
Dear Ms. Tanner:
Plumbing Manufacturers International (PMI) appreciates the opportunity to provide comments
regarding the EPA WaterSense® Notice of Specification Review.
PMI is an international, U.S.-based trade association representing manufacturers that provide 90%
of the plumbing products sold in the United States. We have made the promotion of water safety
and efficiency a top priority and have included this in our mission statement1. PMI's members are
industry leaders in producing safe, reliable and innovative water efficient plumbing technologies
and have supported the U.S. EPA WaterSense® program since its inception. In the U.S., plumbing
manufacturers contribute $34.9 billion to the economy, provide more than 193,000 jobs (direct
and indirect), and generate $10.4 billion in wages.
Regarding the notice, PMI supports the current EPA WaterSense® Specifications for Tank-Type
Toilets, High-Efficiency Lavatory Faucets, Flushing Urinals and Showerheads and recommends that
no changes be made at this time. We would also like to bring to your attention the following
comments for your consideration:
• There are two EPA-funded research studies currently underway that are looking into the
impact of water conservation on public health. The first with Drexel University is titled: "Water
Conservation and Water Quality: Understanding the Impacts of New Technologies and New
Operational Strategies," and the second with Purdue, Michigan State and San Jose Universities
is titled: "Right Sizing Tomorrow's Water Systems for Efficiency, Sustainability, and Public
Health." As indicated during the EPA's March 2017 webinar to discuss the scope of these
research projects, the hypothesis of both projects was stated as:
1 PMI's Mission: To promote the water efficiency, health, safety, quality and environmental sustainability of plumbing products while maximizing
consumer choice and value in a fair and open marketplace. To provide a forum for the exchange of information and industry education. To
represent openly the members' interests and advocate for sound environmental and public health policies in the regulatory/legislative processes.
To enhance the plumbing industry's growth and expansion.
8
Plumbing Manufacturers International | 1750 Tysons Boulevard | Suite 1500 | McLean, Virginia 22102
Tel: 847-481-5500 - Visit us at www.safeplumbing.org
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"The recent use of low-flow plumbing fixtures such as faucets, toilets, and showerheads has
resulted in waterborne disease outbreaks and other water quality problems in building
plumbing systems."
Therefore, considering the possibility that one or both EPA-funded studies could show that
low-flow plumbing fixtures and fixture fittings contribute to waterborne disease outbreaks
and/or other water quality problems in building plumbing systems, PMI believes that EPA
WaterSense should wait until the studies have been finalized and vetted by stakeholders
before considering any further changes to the water consumption levels in the EPA
WaterSense® Specifications for Tank-Type Toilets, High-Efficiency Lavatory Faucets, Flushing
Urinals and Showerheads.
• Based on the November 2017 white paper titled: "Adapting to Change: Utility Systems and
Declining Flows"2, PMI believes that EPA WaterSense should first analyze the impact on
drinking water, wastewater and recycled-water infrastructures across the U.S. before lowering
the water consumption levels of tank-type toilets, lavatory faucets, flushing urinals and
showerheads below the current levels outlined in the applicable EPA WaterSense®
Specifications. Some of the potential impacts on infrastructures identified within the white
paper due to reductions in indoor water use in California include:
o On page 4 for water distribution systems, "With declining water system flows, drinking
water has a longer residence time in pipes, leading to chemicalbiological, and physical
water quality issues and potentially compromising public health and compliance with
the Safe Drinking Water Act, particularly for disinfection by-products (DBPs), coliform
bacteria, chlorine residual, and lead and copper action levels."
o On page 4 for wastewater conveyance systems, "Declining system flows decrease
wastewater flows and may increase pollutant and solids concentrations, which increase
blockages, odors, and corrosion in pipes. This leads to increases in operation and
maintenance (O&M) costs, odor complaints, and an accelerated degradation of
infrastructure."
o On page 5 for wastewater treatment plant operations, "Declining flows change the
characteristics of wastewater, including the quantity and quality of wastewater
treatment plant (WWTP) influent, causing impacts and stressing treatment processes
as salinity, ammonia, and biochemical oxygen demand (BOD) concentrations increase
beyond design specifications."
o On page 5 for recycled water projects, "Declining flows can alter treatment and cost-
effectiveness of recycled-water infrastructure by altering factors considered in system
design, like anticipated flow and water quality."
• Several states and municipalities (i.e. Colorado, Georgia, New York, Oregon, Texas, Vermont,
etc.) have adopted EPA WaterSense requirements. The further lowering of water consumption
levels for tank-type toilets, lavatory faucets, urinals and showerheads would significantly
impact current laws.
2"Adapting to Change: Utility Systems and Declining Flows," California Association of Sanitation Agencies (CASA), Water Research Foundation
(WRF), WateReuse California, California Water Environment Association (CWEA) and California Water Urban Agencies (CUWA), November 2017,
http://www.cywa.org/pubs/CUWA DecliningFlowsWhitePaper ll~28~17.pdf.
9
Plumbing Manufacturers International | 1750 Tysons Boulevard | Suite 1500 | McLean, Virginia
22102 Tel: 847-481-5500 - Visit us at www.safeplumbins.ors
-------
In closing, based on the above comments, PMI supports the current EPA WaterSense®
Specifications for Tank-Type Toilets, High-Efficiency Lavatory Faucets, Flushing Urinals and
Showerheads and recommends that no changes be made at this time.
PMI values our continued partnership with EPA WaterSense and welcomes further discussions on
the topic of water conservation. If you have any questions regarding our comments, please do not
hesitate to contact me.
Sincerely,
Matt Sigler
Technical Director
Plumbing Manufacturers International
Office 847-217-7212
msigler@safeplumbing.org
cc: PMI Board of Directors
PMI Members
*Bradley Corporation *BrassCraft Mfg. Co. *CSA Group *Delta Faucet Company *Dornbracht Americas *Duravit USA
*Fisher Manufacturing Company *Fluidmaster, Inc. *Franke *Global OEM *Globe Union Group, lnc.*Hansgrohe, Inc.
*Haws Corporation *IAPMO *lnSinkErator ""International Code Council Evaluation Service *Jing Mei Industrial (USA) Inc. *KEROX *Kohler Co
*Lavelle Industries, Inc. *LIXIL *Moen Incorporated *NEOPERL, Inc. *NSF International *Pfister *Reliance Worldwide Corporation *Similor AG
*Sloan Valve Company *Speakman Company *Sprite *Symmons Industries, Inc. *T & S Brass and Bronze Works, lnc.*TOTO USA *Viega LLC
*WaterPik *WCM Industries, Inc
10
Plumbing Manufacturers International | 1750 Tysons Boulevard | Suite 1500 | McLean, Virginia
22102 Tel: 847-481-5500 - Visit us at www.safeplumbins.ors
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EPA
Comments on WaterSense®
Notice of Specification Review
WaterSense
Commenter: Andrew D. Morris, Neela Ram
Affiliation: Metropolitan North Georgia Water Planning District
Comment Date: March 15, 2019
Email Text:
Dear Staff,
Please find our comments attached.
Thank you,
Andrew D. Morris
Water Policy Officer
470.378.1549 office
470.747.4005 cell
www.northgeorgiawater.org
Email Attachment
See pages 12 through 27.
11
March 28, 2019
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Metropolitan North Georgia Water Planning District
International Tower I 229 Peachtree St., NE I Suite 100 I Atlanta, GA 30303
March 15, 2019
VIA EMAIL (watersense-products@erg.com)
WaterSense
U.S. Environmental Protection Agency
Office of Wastewater Management (4204M)
1200 Pennsylvania Avenue, N.W.
Washington, D.C. 20460
RE: Metropolitan North Georgia Water Planning District's Comments on the WaterSense
Specification Review
The Metropolitan North Georgia Water Planning District ("District") appreciates this opportunity
to provide comments on the U.S. Environmental Protection Agency's ("EPA") WaterSense
specifications for tank-type toilets, faucets, showerheads, flushing urinals, and weather-based
irrigation controllers. The District strongly supports maintaining and, where feasible, revising
product specifications to improve product efficiency and performance.
The District serves as the regional water planning organization for the metropolitan Atlanta area
that includes 15-counties and 95 cities. The District also provides regional programs, education,
and technical assistance to more than 50 water and sewer utilities and their customers. The metro
Atlanta region is committed to water efficiency, and since 2000 these efforts have resulted in a
10% reduction in water use even as the region's population has grown by more than 1 million
people. More information on the District is available at www.northgeorgiawater.org. Many of our
water efficiency efforts depend on WaterSense-labeled products. For example:
• The plumbing code in Georgia already requires the use of WaterSense-labeled toilets,
urinals, and lavatory faucets;
• Together with its utility partners, the District has replaced more than 135,000 older,
inefficient toilets with WaterSense toilets, saving more than 2.4 million gallons of water
per day;
• The District's model ordinance for large landscape irrigation efficiency requires the use of
WaterSense labeled irrigation controllers;
• The District requires local governments to replace inefficient toilets and urinals in their
buildings with WaterSense products; and
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• Together with its utility partners, the District distributes water efficiency retrofit kits that
include WaterSense showerheads.
Based on our experience with the plans, programs, and requirements outlined above, we would like
you to consider the following comments:
A. Tank-type Toilets. WaterSense should consider revising the WaterSense specification for tank-
type toilets to require (a) better performance in terms of waste clearance and (b) a flush volume of
1.1 gpf or less provided WaterSense satisfactorily analyzes and address any potential adverse
impacts on solids transport, water age in the distribution systems, and corrosion in sewer collection
systems. It is critical that these potential impacts on the utility side of the meter be considered in
addition to potential impacts to premise plumbing on the customer side of the meter.
The Georgia State Minimum Standard Plumbing Code currently requires that all new toilets must
use 1.28 gpf or less and be WaterSense labeled. This requirement has been in place since 2012.
Based on the customer calls that come into the District's toilet rebate call center, we generally hear
positive feedback and extremely few complaints from customers. To reduce even these few
complaints, we support revising the performance criteria to require tank-type toilets to clear a
larger quantity of waste and/or toilet paper.
The District and its utilities have been seeing a small but growing percentage of customers
installing 1.1 gpf toilets. This is especially true in retrofits of multifamily residential projects,
where 1.1 gpf, 1.0 gpf, and 0.8 gpf toilets are frequently the toilet of choice. Given the growing
number of customers in the District using 1.1 gpf or less toilets, our initial impression is that 1.1
gpf or less toilets perform well and have caused few if any problems in residential settings in terms
of drain line transport. We are working on data collection efforts to evaluate their performance and
customer satisfaction more rigorously. Based on positive initial customer experience, the growing
number of 1.1 gpf toilets being installed, and the District's water efficiency goals, the District
changed its toilet rebate program in January 2019 to offer a higher rebate amount to customers that
choose to install toilets using 1.1 gpf or less.
We often receive questions from water and wastewater utilities in the District regarding the impact
of high and ultra-high efficiency fixtures on water age in their distributions systems and issues
with solids transport and corrosion in their sewer collection systems. At this point our information
is mostly anecdotal, but we are seeking more information on this topic. We ask that WaterSense
consider these two issues carefully, including additional data and analysis if possible, as part of its
efforts to evaluate 1.1 gpf toilets.
B. Lavatory Faucets. WaterSense should consider revising the WaterSense specification for
lavatory faucets to require a flow rate of 1.0 gpm or less and creating a new specification for
kitchen faucets with flow rates of 1.5 gpm or less.
The Georgia State Minimum Standard Plumbing Code currently requires that all new lavatory
faucets for private settings must use 1.5 gpm or less and be WaterSense labeled. Through the
District's retail market research performed in 2018 at Home Depot, Lowe's Home Improvement,
and Walmart included here as Attachment A. we found that a very significant number of lavatory
faucets on the market today use 1.2 gpm. Products using 1.5 gpm as required by the current
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WaterSense specification are no longer leading-edge technologies. If WaterSense wants to
continue pushing the marketplace for water efficiency forward, it would need to require a flow rate
of less than 1.2 gpm for lavatory faucets. Given that significant numbers of lavatory faucets with
a flow rate of 0.5 gpm are used in public settings, it seems reasonable to lower the minimum flow
rate for the WaterSense requirements to 0.5 gpm especially given that WaterSense is voluntary
program.
Through the District's retail market research performed in 2018 at Home Depot, Lowe's Home
Improvement, and Walmart included here as Attachment A. we found that many kitchen faucets
are available that use 1.8 gpm and 1.5 gpm. WaterSense's Water Efficiency Management Guide
for Residential Kitchen and Laundry uses 25.7 minutes as the average usage time per household
per day. While lowering the flow rate will increase the duration of use to some extent for uses like
pot filling, water savings can still be expected based on uses like hand washing, fruit and vegetable
washing, pot rinsing, garbage disposal use, etc. Based on the significant market share of 1.8 gpm
models today, 1.5 gpm may be a good standard for WaterSense to consider because it goes above
and beyond what is already common in the marketplace today.
C. Showerheads. WaterSense should consider revising the WaterSense specification for
showerheads to require a flow rate of 1.8 gpm.
The Georgia State Minimum Standard Plumbing Code currently requires that all new showerheads
must use 2.5 gpm or less. Through the District's retail market research performed in 2018 at Home
Depot, Lowe's Home Improvement, and Walmart included here as Attachment A. we found that
many of the showerheads on the market today use 2.0 gpm or less, and a significant portion have
a maximum flow rate of 1.8 gpm or less.
Products using 2.0 gpm as required by the current WaterSense specification could be considered
mid-range in terms of their efficiency. To continue pushing innovation and efficiency forward,
WaterSense should consider revising this standard to 1.8 gpm or less. There are products already
available in the marketplace at a wide variety of price points using 1.8 gpm or less.
D. Flushing Urinals. WaterSense should consider revising the WaterSense specification for wall-
mounted urinals to require a flush volume of 0.125 gpf or less provided WaterSense satisfactorily
analyzes and address potential adverse impacts on premise plumbing systems, including potential
corrosion, the buildup of minerals like struvite, and increased water age in the premise plumbing
of large commercial buildings. Alternatively, WaterSense could evaluate and consider labeling
hybrid urinals that that combine the non-water-using urinal technology with a periodic drain line
clearing flush as this may avoid or mitigate potential adverse impacts.
The Georgia State Minimum Standard Plumbing Code currently requires that all new urinals must
use 0.5 gpf or less and be WaterSense labeled, and there are numerous options available at both
this 0.5 gpf level and the 0.125 gpf level. Products using 0.5 gpf as required by the current
WaterSense specification could be considered mid-range in terms of their efficiency. To continue
pushing innovation and efficiency, WaterSense should consider revising this standard to 0.125 gpf.
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E. Weather-based Irrigation Controllers. WaterSense should maintain the labeling program for
weather-based irrigation controllers and update it as appropriate based on technological trends and
better data on landscape irrigation as they become available.
To improve outdoor water efficiency, the District recently began requiring enhanced irrigation
system design and functionality for large landscapes (irrigated landscape areas of more than 1
acre). The District developed a model ordinance for local governments to use in implementing this
requirement that specifies the use of WaterSense controllers. Checking for the WaterSense label
is a simple way for local staff to ensure a controller has the necessary technical capabilities.
Specifically, the WaterSense specifications for irrigation controllers require that the controller be
capable of interfacing with a rain sensor shut-off and include other features and reporting
capabilities to make use of pressure regulators and flow sensors.
We encourage WaterSense to maintain this labeling program and consult with manufacturers to
determine the popularity of each type of controller (stand alone, plug-in, or add-on) and consider
ease-of-use in product specification. In our experience, plug-in and add-ons to irrigation
controllers are not common and can be confusing to consumers. If this experience is shared more
broadly, WaterSense could consider whether it is desirable to continue labeling plug-in and add-
ons.
Additionally, WaterSense should consider requiring that signal-based controllers not charge a
monthly or annual fee to access the data sent over a signal. Users may forget to pay the fee, lose
access to real time weather data, and as a result the controllers would become ineffective to respond
to changing weather conditions.
F. Conclusion. WaterSense is critical to the District's work, and we support WaterSense's efforts
to maintain and, where feasible, revise product specifications to improve product efficiency and
performance.
Sincerely,
Andrew D. Morris
Water Policy Officer
And
Neela Ram
Water Resources Planner
15
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Attachment A
2018 Retail Market Research
Store No. 1 Information
Store Name:
Home Depot
Store Address:
5300 Windward Pkwy, Alpharetta, GA 30004
Date of Visit:
March 30, 2018
Showerheads
2.5 gpm
2.0 gpm
1.8/1.75 gpm
1.5 gpm & lower
Total Number
1
15
11
1
Total WaterSense
12
10
1
Brands
Sprite
Glacier Bay, Delta,
Moen, Waterpik,
Kohler
Glacier Bay, Delta,
Moen, American
Standard, Kohler
Delta
Lowest Priced
$17.98
$2.27
$9.98
12.00
Second Lowest Priced
$3.97
$19.98
NA
Third Lowest Priced
$19.98
$29.98
NA
Lavatory Faucets
1.5 gpm
1.2 gpm
1.0 gpm and lower
Total Number
1
38
0
Total WaterSense
1
38
Brands
Glacier Bay
Glacier Bay, Delta, Moen,
American Standard,
Pfister
Lowest Priced
$28.00
$11.78
Second Lowest Priced
$18.46
Third Lowest Priced
$19.98
Kitchen F aucets
2.0 gpm
1.8 gpm
1.5 gpm and lower
Total Number
3
33
9
Brands
Glacier Bay, Moen
Glacier Bay, Delta,
American Standard,
Pfister, Kohler
Moen
Lowest Priced
$39.00
$35.98
$138.00
Second Lowest Priced
$64.00
$36.95
$149.00
Third Lowest Priced
$69.00
$46.97
$168.00
16
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Store No. 2 Information
Store Name:
Lowe's
Store Address:
4925 Windward Pkwy, Alpharetta, GA 30004
Date of Visit:
March 31, 2018
Showerheads
2.5 gpm
2.0 gpm
1.8/1.75 gpm
1.5 gpm & lower
Total Number
32
14
12
1
Total WaterSense
13
11
1
Brands
Moen,
Moen, Oxygenics,
Moen, Oxygenics,
Moen
AquaSource,
Kohler, Pfister,
Kohler, Delta
Delta
Jacuzzi, Sprite,
Delta,
Proj ectSource
Lowest Priced
$2.98
$23.48
$27.48
64.00
Second Lowest Priced
$9.98
$29.98
$32.98
NA
Third Lowest Priced
$14.48
$32.98
$34.98
NA
Lavatory Faucets
1.5 gpm
1.2 gpm
1.0 gpm and lower
Total Number
1
109
0
Total WaterSense
105
Brands
Peerless
Proj ectSource, Peerless,
Delta, American
Standard, AquaSource,
Pfister, Moen, Jacuzzi,
Giagni, Kohler, Grohe
Lowest Priced
$59.00
$20.00
Second Lowest Priced
$24.98
Third Lowest Priced
$29.97
Kitchen F aucets
2.0 gpm
1.8 gpm
1.5 gpm and lower
Total Number
0
50
16
Brands
Proj ectSource,
AquaSource, Delta,
Pfister, Peerless,
American Standard,
Giagni, Kohler, Grohe
Moen, Kohler, Delta
Lowest Priced
$38.99
$78.00
Second Lowest Priced
$49.00
$99.00
Third Lowest Priced
$54.00
$109.00
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Store No. 3 Information
Store Name:
Walmart
Store Address:
5200 Windward Pkwy, Alpharetta, GA 30004
Date of Visit:
March 30, 2018
Showerheads
2.5 gpm
2.0 gpm
1.8/1.75 gpm
1.5 gpm & lower
Total Number
0
12
16
0
Total WaterSense
11
16
Brands
Peerless, Waterpik,
AquaSpa
Peerless,
Waterpik
Lowest Priced
$12.97
$2.94
Second Lowest Priced
$18.84
$6.42
Third Lowest Priced
$19.97
$8.84
Lavatory Faucets
1.5 gpm
1.2 gpm
1.0 gpm and lower
Total Number
4
2
0
Total WaterSense
4
2
NA
Brands
Peerless
Peerless
NA
Lowest Priced
$19.97
$24.97
NA
Second Lowest Priced
$34.97
$26.97
NA
Third Lowest Priced
$39.97
NA
NA
Kitchen F aucets
2.0 gpm
1.8 gpm
1.5 gpm and lower
Total Number
1
5
0
Brands
Mainstay
Peerless
Lowest Priced
$12.97
$34.97
Second Lowest Priced
$39.97
Third Lowest Priced
$59.97
18
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Store No. 4 Information
Store Name: Home Depot
Store Address: 650 Ponce De Leon Ave, NE, Atlanta, GA 30308
Date of Visit:
April 13, 2018
Showerheads
2.5 gpm
2.0 gpm
1.8 gpm & lower
Total Number
0
19
17
Total WaterSense
10
14
Brands
Glacier Bay, Waterpik,
Moen, Pfister
Delta, Glacier Bay,
Waterpik, Moen
Lowest Priced
$2.97
$9.98
Second Lowest Priced
$3.97
$12.98
Third Lowest Priced
$9.98
$13.98
Lavatory Faucets
1.5 gpm
1.2 gpm
1.0 gpm and lower
Total Number
0
87
0
Total WaterSense
87
Brands
Glacier Bay, Grohe,
Moen, Pfister, American
Standard, Delta, Kohler
Lowest Priced
$11.78
Second Lowest Priced
$18.46
Third Lowest Priced
$28.00
Kitchen F aucets
2.0 gpm
1.8 gpm
1.5 gpm and lower
Total Number
0
48
14
Brands
Glacier Bay, American
Standard, Kohler, Delta,
Kraus, Pfister
Moen, Kohler
Lowest Priced
$17.38
$114.00
Second Lowest Priced
$35.00
$119.00
Third Lowest Priced
$39.00
$129.00
19
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Store No. 5 Information
Store Name:
Store Address:
Lowe's
1280 Caroline Street NE
Atlanta GA 30307
Date of Visit:
April 23, 2018
Showerheads
2.5 gpm
2.0 gpm
1.8/1.75 gpm
1.5 gpm & lower
Total Number
25
6
9
0
Total WaterSense
6
9
Brands
AquaSource,
Moen, Delta
Delta, Oxygenics,
Moen
Oxygenics, Moen
Lowest Priced
$9.98
$32.98
$32.98
Second Lowest Priced
$14.98
$49.98
$40.98
Third Lowest Priced
$21.98
$49.98
Lavatory Faucets
1.5 gpm
1.2 gpm
1.0 gpm and lower
Total Number
0
86
0
Total WaterSense
84
Brands
ProjectSource, Grohe,
Moen, Kohler, Delta
Lowest Priced
$20.00
Second Lowest Priced
$24.98
Third Lowest Priced
$29.97
Kitchen F aucets
2.0 gpm
1.8 gpm
1.5 gpm and lower
Total Number
0
79
0
Brands
Peerless, Grohe, Pfister,
Moen, Delta
Lowest Priced
$29.00
Second Lowest Priced
$35.99
Third Lowest Priced
$38.99
20
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Store No. 6 Information
Store Name:
Store Address:
Walmart
2525 N Decatur Road
Decatur, GA 30033
Date of Visit:
April 24, 2018
Showerheads
2.5 gpm
2.0 gpm
1.8/1.75 gpm
1.5 gpm & lower
Total Number
0
6
18
0
Total WaterSense
6
18
Brands
Peerless, WaterPik
Peerless, WaterPik
Lowest Priced
$3.97
$23.84
Second Lowest Priced
$6.42
$24.84
Third Lowest Priced
$8.84
$29.87
Lavatory Faucets
1.5 gpm
1.2 gpm
1.0 gpm and lower
Total Number
0
7
0
Total WaterSense
7
Brands
Peerless and Mainstays
Lowest Priced
$9.97
Second Lowest Priced
$24.97
Third Lowest Priced
$34.97
Kitchen F aucets
2.0 gpm
1.8 gpm
1.5 gpm and lower
Total Number
0
5
0
Brands
Peerless, Mainstays
Lowest Priced
$12.97
Second Lowest Priced
$34.97
Third Lowest Priced
$39.97
21
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Store No. 7 Information
Store Name:
Home Depot
Store Address:
875 Shugart Rd Dalton, GA 30720
Date of Visit:
April 13, 2018 (online)
Showerheads
2.5 gpm
2.0 gpm
1.8/1.75 gpm
1.5 gpm & lower
Total Number
2
14
12
2
Total WaterSense
11
12
2
Brands
Pfister
Glacier Bay,
DANCO,
Waterpik, Pfister,
Delta
Glacier Bay, Delta,
Moen
No brand listed
Lowest Priced
$19.98
$2.27
$9.98
$4.38
Second Lowest Priced
$29.98
$4.82
$12.98
$7.35
Third Lowest Priced
$4.85
$13.98
Lavatory Faucets
1.5 gpm
1.2 gpm
1.0 gpm and lower
Total Number
1
73
0
Total WaterSense
1
73
0
Brands
Glacier Bay,
Glacier Bay, Delta, Moen,
American Standard,
Pfister, Kohler
Lowest Priced
$28.00
$11.78
Second Lowest Priced
$18.46
Third Lowest Priced
$19.97
Kitchen F aucets
2.0 gpm
1.8 gpm
1.5 gpm and lower
Total Number
0
52
15
Brands
Glacier Bay, Delta,
American Standard,
Kohler, Pfister
Moen
Lowest Priced
$17.38
$64.00
Second Lowest Priced
$29.98
$69.00
Third Lowest Priced
$35.98
$99.00
22
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Store No. 8 Information
Store Name:
Lowe's
Store Address:
1212 Cleveland Highway Dalton, GA 30721
Date of Visit:
April 18, 2018 (online)
Showerheads
2.5 gpm
2.0 gpm
1.8/1.75 gpm
1.5 gpm & lower
Total Number
29
15
8
0
Total WaterSense
13
8
0
Brands
ProjectSource,
AquaSource,
Jacuzzi, Moen,
Sprite, Kohler,
Pfister, Delta,
HotelSpa
Oxygenics, Kohler,
Moen, Delta
Oxygenics, Delta
Lowest Priced
$2.98
$25.98
$24.98
Second Lowest Priced
$9.98
$29.98
$29.98
Third Lowest Priced
$9.98
$31.98
$38.48
Lavatory Faucets
1.5 gpm
1.2 gpm
1.0 gpm and lower
Total Number
1
95
0
Total WaterSense
1
95
0
Brands
Peerless
ProjectSource, Peerless,
Delta, Pfister, Moen,
Jacuzzi, Giagni, Grohe,
Kohler
Lowest Priced
$59.00
$20.00
Second Lowest Priced
$24.98
Third Lowest Priced
$29.97
Kitchen F aucets
2.0 gpm
1.8 gpm
1.5 gpm and lower
Total Number
3
50
20
Brands
Moen
ProjectSource,
AquaSource, Delta,
Pfister, Giagni, American
Standard, Peerless, Kohler
Moen, Kohler
Lowest Priced
$69.00
$31.98
$69.00
Second Lowest Priced
$99.00
$40.48
$69.00
Third Lowest Priced
$199.00
$42.98
$78.00
23
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Store No. 9 Information
Store Name:
Walmart
Store Address:
2545 E Walnut Ave Dalton, GA 30721
Date of Visit:
April 18, 2018 (online)
Showerheads
2.5 gpm
2.0 gpm
1.8/1.75 gpm
1.5 gpm & lower
Total Number
0
14
10
0
Total WaterSense
14
10
0
Brands
Peerless
Peerless, Waterpik
Lowest Priced
$3.97
$12.57
Second Lowest Priced
$6.42
$19.84
Third Lowest Priced
$8.84
$26.27
Lavatory Faucets
1.5 gpm
1.2 gpm
1.0 gpm and lower
Total Number
1
7
0
Total WaterSense
1
7
0
Brands
Vigo
Peerless
Lowest Priced
$101.49
$19.97
Second Lowest Priced
$24.97
Third Lowest Priced
$26.97
Kitchen F aucets
2.0 gpm
1.8 gpm
1.5 gpm and lower
Total Number
0
7
0
Brands
Peerless
Lowest Priced
$29.72
Second Lowest Priced
$34.97
Third Lowest Priced
$39.97
24
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Store No. 10 Information
Store Name:
Store Address:
Home Depot
2891 SowegaDr
Columbus, GA 31909
Date of Visit:
April 18, 2018 (online)
Showerheads
2.5 gpm
2.0 gpm
1.8/1.75 gpm
1.5 gpm & lower
Total Number
1
11
12
0
Total WaterSense
8
10
Brands
Waterpik
Glacier Bay,
Waterpik, Delta,
Kohler, Moen
Glacier Bay,
Waterpik, Delta,
Moen
Lowest Priced
$19.98
$2.27
$9.98
Second Lowest Priced
$3.97
$19.98
Third Lowest Priced
$19.98
$24.98
Lavatory Faucets
1.5 gpm
1.2 gpm
1.0 gpm and lower
Total Number
1
69
0
Total WaterSense
1
69
Brands
Glacier Bay
Glacier Bay, Delta, Moen,
American Standard,
Pfister, Kohler
Lowest Priced
$28.00
$18.46
Second Lowest Priced
$19.98
Third Lowest Priced
$24.86
Kitchen F aucets
2.0 gpm
1.8 gpm
1.5 gpm and lower
Total Number
0
49
17
Brands
Glacier Bay, Delta,
American Standard,
Kohler, Pfister
MOEN, KOHLER
Lowest Priced
$29.98
$64.00
Second Lowest Priced
$35.98
$64.00
Third Lowest Priced
$36.95
$69.00
25
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Store No. 11 Information
Store Name:
Lowe's
Store Address:
6750 Veterans Parkway
Columbus, GA 31909
Date of Visit:
April 19, 2018 (online)
Showerheads
2.5 gpm
2.0 gpm
1.8/1.75 gpm
1.5 gpm & lower
Total Number
18
2
3
0
Total WaterSense
2
3
Brands
Moen, Kohler,
Pfister,
AquaSource, Jazz,
Sprite
Delta
Oxygenics, Delta
Lowest Priced
$2.98
$25.98
$24.98
Second Lowest Priced
$9.98
$29.98
$34.98
Third Lowest Priced
$14.98
$39.98
Lavatory Faucets
1.5 gpm
1.2 gpm
1.0 gpm and lower
Total Number
0
93
0
Total WaterSense
90
Brands
Moen, Peerless, Kohler,
Delta
Lowest Priced
$20.00
Second Lowest Priced
$24.98
Third Lowest Priced
$29.97
Kitchen F aucets
2.2 gpm
1.8 gpm
1.5 gpm and lower
Total Number
2
55
15
Brands
Moen, ProjectSource
Moen, Delta, Kohler,
Pfister, Giagni, Peerless
Moen, Delta, Kohler
Lowest Priced
$39.48
$40.48
$74.98
Second Lowest Priced
$69
$42.98
$78.98
Third Lowest Priced
$49.00
$89.98
26
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Store No. 12 Information
Store Name: Walmart
Store Address:
5448 Whittlesey Boulevard Ste B, Columbus, GA 31909
Date of Visit:
March 28, 2018
Showerheads
2.5 gpm
2.0 gpm
1.8/1.75 gpm
1.5 gpm & lower
Total Number
0
6
12
0
Total WaterSense
6
12
Brands
WaterPik,
AquaSpa
Peerless
Lowest Priced
$29.97
$3.97
Second Lowest Priced
$34.84
$8.84
Third Lowest Priced
Lavatory Faucets
1.5 gpm
1.2 gpm
1.0 gpm and lower
Total Number
1
7
0
Total WaterSense
1
Brands
Peerless
Mainstays, Peerless
Lowest Priced
$59.00
$9.97
Second Lowest Priced
$19.97
Third Lowest Priced
$24.97
Kitchen F aucets
2.0 gpm
1.8 gpm
1.5 gpm and lower
Total Number
0
8
0
Brands
Peerless
Lowest Priced
$34.97
Second Lowest Priced
$39.97
Third Lowest Priced
$49.97
27
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EPA
Comments on WaterSense®
Notice of Specification Review
WaterSense
Commenter: Jeff Tejral
Affiliation: Denver Water
Comment Date: March 18, 2019
Email Text:
Dear WaterSense Staff,
Denver Water appreciates the WaterSense partnership and the value labeling of efficient
water using products brings to consumers to transform markets and achieve national
water savings. Please consider the following in your review of standards and
specifications of WaterSense fixtures and certifications.
General comments not specific to one product:
• Changes to large market (like California, Texas or New York) standards are
significant and could lead to market confusion.
• Consider water quality criteria and any associated demand differences for use of
alternative water sources such as gray water, rainwater... with toilets, cooling
towers and irrigation. Additional study may be required to understand if changes
in water quality could increase water use or require changes to product
maintenance.
Tank type Toilets:
• Consider moving to lower gallons per flush as many markets shifted to 1.28 gpf
as baseline
• Consider reviewing criteria such as MaP score, Dual flush eligibility. Dual flush
models may not save as much as stated due to user confusion. Consider change
labeling of button on toilets to limit user confusion or remove from list.
• Lower water use could cause aging of water in service lines and potential drain
line carry issues in older plumbing - could be part of new home criteria. The
occurrence of pathogens in premise plumbing (e.g., Legionella) has become a
high visibility topic and lower water use combined with the potential of using
alternative water sources may exacerbate this concern. Studies underway could
help answer in the near future (I know of two studies at Perdue and Lehigh
Universities)
Flushing Urinals:
• Consider criteria for waterless technology as a separate specification
Showerheads:
• Consider California changing to 1.8 gpm as a market shift that WaterSense
standards could also adopt
• Slightly increases time to deliver heated water
Weather-based Smart Controllers:
• Customers can opt in / opt out of weather based control could be a major issue.
Could product specs be changed to increase adoption of weather based
operations?
28
March 28, 2019
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EPA
Comments on WaterSense®
Notice of Specification Review
WaterSense
• Update and strengthen packaging and labeling requirements for products that
require an add-on sensor.
WaterSense Homes:
• Allowed turf seems high for Western U.S., consider regional appropriateness for
outdoor water use targets.
• The worksheet shows average monthly water needs but does not state if this is
over a year or irrigation season. To evaluate if WaterSense homes are achieving
stated savings or performing better than existing builds suggest having a monthly
expected water use (Jan - Dec).
• Tree health needs more study as reductions in water use that result in tree
mortality is a significant unintended consequence.
• Do decks and artificial turf add to stormwater runoff issues or increase heat
island significantly?
• Synthetic turf may need its own classification or design features in the calculation
sheet
Irrigation Professionals:
• Nonpotable water sources may occasionally need to be supplemented with
potable water for water quality purposes; irrigation professionals should consider
alternative landscape management techniques to minimize the need for
occasional potable water usage and professionals should consider occasional
potable water usage needs in overall water savings evaluation.
• Do any of the trainings currently offered cover nonpotable water use?
Sincerely,
Jeff Tejral
Jeff Tejral | Manager of Water Efficiency
Denver Water 11: 303-628-6301 | c: 720 -220-0090
1600 West 12th Ave | Denver, CO 80204-3412
ieff.teiral@denverwater.org | http://www.denverwater.org
29
March 28, 2019
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