Executive Summary Potential WaterSense Commercial and Institutional Program Summary of Comments Received


AA/aterSense
Executive Summary
Potential WaterSense® Commercial and Institutional Program
Summary of Comments Received
Background
The U.S. Environmental Protection Agency (EPA) established WaterSense with the goal of
saving water for future generations. By helping transform the market for water-efficient products,
services, and practices, WaterSense is working to relieve the strain of expanding water supply
and wastewater infrastructure. Since 2006, the WaterSense label has helped consumers
identify products and services that meet EPA's criteria for water efficiency and performance.
In an effort to further this mission, WaterSense is now considering including partnership and
participation options for users in the commercial and institutional (CI) sector. Wth this in mind,
EPA is seeking input from its partners and other stakeholders on the current state of data
related to water use in the CI sector as well as potential program options.
On August 20, 2009, EPA released a white paper, "Water Efficiency in the Commercial and
Institutional Sector: Considerations for a WaterSense Program," and opened a public comment
period that extended until September 20, 2009. The white paper summarizes the current state
of knowledge regarding water use in the CI sector. While there are gaps in the water use data,
this paper contains the best information available to use as a basis for decision-making
regarding a national CI program. The paper also includes a discussion of the various forms that
a WaterSense CI program could take.
On October 5, 2009 in Las Vegas, Nevada, EPA held its first stakeholder meeting to solicit
comments on the white paper and discuss potential CI program options for WaterSense. EPA
will hold its second stakeholder meeting to gather additional comments and discuss program
options via webinar on January 27, 2010. Additional information can be found at
www2.qotomeetinq.com/reqister/176949330.
In general, stakeholders are supportive of EPA developing a CI component of WaterSense. The
consensus of the stakeholders was that labeling products should remain the primary focus of
the WaterSense program. This Executive Summary summarizes the comments collected via e-
mail during the public comment period and in-person at the October 5, 2009 stakeholder
meeting.
Scope of a Potential CI Program—Choosing a Broad Sector or Subsector Approach
Most stakeholders recommended EPA develop a potential CI program addressing individual
subsectors in sequence, rather than addressing the CI sector as a whole. Stakeholders
indicated that water consumption and end uses are too varied among subsectors to attempt to
address the entire CI sector initially. Stakeholders were in favor of EPA targeting subsectors
with the highest water consumption and the most interest in participating in a CI program, and
focusing on multiple subsectors with common end uses. Laundries, the hospitality sector (e.g.,
restaurants and hotels), and medical facilities were identified as subsectors with high potential.
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However, stakeholders acknowledged that there may be insufficient water use data to
accurately prioritize subsectors at this time.
Stakeholders suggested that WaterSense align its product specifications with the subsector-
based approach to provide for the simultaneous labeling of products used in the subsector with
a CI subsector program roll-out.
Certification and Labeling Program
Stakeholders are in favor of a building certification and labeling program. They indicated that
certification and labeling specifications should be separate for new and existing construction.
Stakeholders did not agree on which type of construction should be addressed first or if the
programs should be multi-tiered or single-tiered. Most agreed that third-party certification is
needed to protect the WaterSense brand and assure performance. They recommended the
program include percent reduction target goals and/or commitments to meet a set of best
management practices (BMPs). They urged EPA to require metering and submetering to assist
with developing accurate baselines and to assure that water savings from a CI program are
measurable and verifiable. Stakeholders also urged EPA to consider the crossover between
energy savings and water savings when developing a program.
Stakeholders recommended that EPA work with existing building certification programs to
identify and fill existing gaps rather than develop a duplicative program. Stakeholders stated that
EPA should learn from the WaterSense new homes program while developing a potential CI
program that includes building certification and labeling.
In addition, stakeholders suggested that EPA issue BMPs for water uses applicable to multiple
subsectors. EPA could also offer a broader commitment-based program for facilities that do not
fit into a subsector of interest.
Commitment-Based Program
Stakeholders maintained that a commitment-based program could be a good first step for
WaterSense to take towards a multi-faceted CI program. Declared partners could set and
commit to their own water reduction goals, or they could commit to a percent reduction identified
following a water audit of their facility. If water audits are performed to develop partner
commitments, EPA could collect data generated from the audits to begin building a
benchmarking database. A building certification and labeling program could then be developed
after the commitment-based program is underway and more labeled products are on the
market.
Professional Certification Program
Stakeholders indicated that EPA could label certification programs for professionals working in
the CI sector, such as water auditors, facilities managers, and plumbers.
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Technical Assistance
Stakeholders identified the need for a national repository for CI water use and benchmarking
data. Stakeholders suggested that EPA develop a benchmarking tool and create a
questionnaire to collect necessary data. They were in favor of EPA developing consistent
naming conventions and clear definitions for CI subsectors, so utilities collecting baseline data
for CI subsectors can assure that data are consistent and translatable.
Stakeholders noted that EPA could use its Web site to provide technical tools to interested
parties in the CI sector. They suggested EPA create a list of available tools helpful to CI sector
stakeholders (including propriety tools of interest) and suggested EPA develop needed tools like
water audit methodology and self-audit templates. Stakeholders indicated that EPA could post
case studies of CI water efficiency success stories on its Web site.
Awards
Stakeholders agreed that an awards program for the CI water sector is needed, especially to
recognize early adopters. However, an awards program alone would not be sufficient to
motivate change in this sector.
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