EPA
Water Sense
Comments on the January 2011 Revised Draft
Specification for Weather-Based Irrigation Controllers
May 19, 2011
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Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
Commenter
Edward Norum, California State University — Fresno 3
George Alexanian, Alex-Tronix 7
Tom Fairey, DB Live 10
Gary Okafuji, The Toro Company 13
Karen Guz, San Antonio Water System 17
Peter Carlson, Hydropoint Data Systems, Inc 20
Thomas Reynolds, Water Balance, LLC 24
Diana Schulz, Cyber-Rain 29
Steven Moore, Irrisoft, Inc 33
Brian Lennon, IRROMETER Co., Inc 43
Ben Silverman, Rain Bird Corporation 47
Eugene Carlson, CE Technical 53
Loc Truong, WaterOptimizer, Inc 57
Brian Vinchesi, Irrigation Association 60
Dan Nourian, National Diversified Sales, Inc 66
Kent Sovocool, Southern Nevada Water Authority 70
Chris Brown, California Urban Water Conservation Council 78
Derres Catalano, Hunter Industries 81
Mary-Ann Dickinson, Alliance for Water Efficiency 83
F.PA
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WaterSense
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May 19, 2011
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WaterSense
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
Commenter: Edward Norum
Affiliation: California State University — Fresno
Comment Date: March 2, 2011
ERG Staff: The attached file contains my comments on the revised draft as invited in your email of
1/20/2011.
Commenter's Name: Edward Norum
Agricultural Engineer
Fresno, CA
Commenter's Affiliation: None
Date: February 28, 2011
Topic: Summary of Major Changes to the Revised Draft Specification for
Weather-Based Irrigation Controllers
Comments on Weather-Based Irrigation Controllers Testing Protocols as per the following
Documents:
From EPA Summary of Major Changes to the Revised Draft Specifications for Weather-
Based Irrigation Controllers - January 20, 2011
General:
The irrigation industry's effort to develop a smart controller was an attempt to integrate the
effects of soils, plant physiology, climate, topography and the irrigation system to provide
effective and efficient use of water. It was recognized that to minimize irrigation water
requirements, the effects of rainfall needed to be maximized. It was also considered critical
that the system operate without human intervention. A testing protocol was developed and
used to evaluate the degree of effectiveness of 25-30 controllers over a period of 5-6 years.
The documents referenced are an attempt to modify the testing protocol based on flawed
logic as stated in the comments.
3.1.3 Root Zone Working Water Storage Starting Point: During the performance test training the
licensed certifying bodies and the University of Florida found that starting the performance test with
the root zone working water storage (RZWWS) at full, rather than at half full as indicated in the
current version of the SWAT protocol, ensured that the reference RZWWS and controller's
RZWWS start at the same level. EPA made this change to the specification to reflect this finding.
(Page 3)
There is no scientific basis for making this change. In managing the RZWWS there is no
logical reason for completely filling the root zone with irrigation water. In fact, if rainfall is to be used
effectively, a portion of the RZWWS should be left unfilled to allow for the storage of rainfall. Even
in dry periods, there is no incentive to completely fill the root zone and risk runoff in the wet portion
of the sprinkler pattern.
3.1.4 ..The results from testing the controllers during a rainy period indicated that performance
scores are not transferable from dry to wet climates. As a result, EPA decided to add a requirement
that would test a controller's ability to handle rainfall. WaterSense is proposing the 30-day test
period include at least four days that receive at least 0.10 inches of rain. (Page 3)
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EPA
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
There is no science behind this conclusion. The original testing protocol assumes that the
product is best testing in the natural environment in which it will be required to perform. Clearly,
any arbitrary variation from the natural nature of the rainfall risks biasing the results. The controller
should have a demonstrated ability to deal with the naturally occurring weather conditions on site.
3.1.5 Order of Operations: In the early stages of specification development, some stakeholders
were concerned that the order of operations in the SWAT protocol moisture balance unfairly
penalized controllers for not being able to predict rainfall. The original research conducted at the
University of Florida in 2008 and 2009 aimed to examine this concern, but was inconclusive due to
a lack of rainfall during the study period. However, the University of Florida follow-up research
examined this same concern under periods of heavy rain and concluded that the order of
operations did impact performance scores. Based on this conclusion, WaterSense is proposing
that the order of operations implemented during the SWAT protocol daily water balance calculation
be ET first, then irrigation, and then rainfall, rather than rainfall occurring first, as designated by the
SWAT protocol. (Pages 3-4)
There is no science to support this conclusion. The comment that during heavy rains, the
protocol impacted performance scores is not justification for the change. The change downgrades
the importance of maximizing rainfall effectiveness as needed to meet consumptive use. Given that
the consumptive use is fixed by climatic conditions and that rainfall's contribution is downgraded,
the contribution from irrigation will need to be increased. This change will result in wasting of
irrigation water.
We should be encouraging the controller to adopt ever more sophisticated techniques for
managing the RZWWS. This could for example include the development of a rainfall "look ahead"
feature that improves the controller's grasp of rainfall probabilities. Improvements in dealing with
rainfall probabilities will save irrigation water while not sacrificing vegetative quality.
From Examination of SWAT Protocol Utilizing a Performance Analysis of Weather-based
Irrigation Controllers: Update With Extended Data, Michael Dukes, - January 20, 2011
Instead of being a critique of the science involved in the SWAT testing protocol, the
investigation concentrates primarily on the subtleties involved in developing passing scores.
The results of this study indicated that an ET controller's ability to handle rainfall is still one of the
most important influences over the SWAT scores. Consequently, the dependence of SWAT scores
on weather patterns indicates that the SWAT test is not transferable throughout the United States.
An improvement to this problem would be to declare a minimum number of rainfall events within
the 30-day period. This would benefit the transferability of the SWAT scores by increasing the
potential for a higher amount of rainfall. It is likely that a controller that performs well in a frequent
rainfall environment.
In general, the addition of a rain sensor increased or did not affect the SWAT scores
obtained in any of the study periods. (Page 18)
Agree: "The Results of the Study..."
Disagree: "Consequently, the dependence..."
The variability of scores has nothing to do with the SWAT test transferability. The scores
are an indication of how well each manufacturer has dealt with the challenge of integrating the
General:
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May 19, 2011
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EPA
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
influences of the sciences involved. The best way to increase the rainfall events is to change the
test period length from say one to two months and increase the minimum rainfall requirement to
0.80 in.
The removal of any runtime less than three minutes did not affect the number of reportable
scores and only minimally affected the values of the scores by as much as a few percentile points.
Though it may not have made a large difference for these study periods requiring a minimum
runtime would create a more realistic test that would encourage more efficient irrigation practices.
There is no science to support this conclusion. Until the science is available, the controller
programmers should have the latitude to establish programs that best demonstrate their system
capabilities.
The controllers met the proposed minimum score threshold of 80% for irrigation adequacy,
but generally failed to meet the 95% threshold for scheduling efficiency throughout all the study
periods when using the minimum score of the six zones. This indicated that the scheduling
efficiency score is critical to passing the SWAT test.
....The low scores from the Florida SWAT test were in contrast to the scores reported from the
official SWAT tests that were nearly 100% for these controller brands...(pages 18-19)
It must be remembered that the 95% threshold for scheduling efficiency is purely arbitrary
and has never been written into the testing protocol. The testing protocol reports the values for
each zone. Averaging values was instituted by the SWAT committee. As originally visualized, the
threshold values were best set by individual water purveyors. In chronically water short areas, high
values could be justified. National standards may not be practical.
Further the values obtained represent the current "state of the art".
...The effects of using an average may increase the passing rate of the test, but it would be at the
cost of encouraging over-irrigation... (page 19)
I agree that performance values should not be averaged across zones.
....Accounting for rainfall before irrigation on a daily basis resulted in decreased scheduling
efficiency scores in all of the study periods, but was most prominent in the frequent rainfall period
and during the periods of frequent rainfall in the high and low ETo periods. The combination of
using the average score across all zones and changing the order of calculations to the order of
, irrigation, and rainfall ensured the highest rate of passing scores whereas using the minimum
score across all zones and changing the order of calculations increased the passing rate to a
lesser extent while encouraging appropriate scheduling techniques for all landscapes. (Page 19)
Apparently the objective of the Florida study was to increase "passing scores" by changing
the mechanics of the protocol. The objective of the overall effort should be to produce acceptable
vegetation with a minimum of irrigation water.
The following definition was taken from the irrigation association website:
Smart controllers estimate or measure depletion of available plant soil moisture in order to
operate an irrigation system, replenishing water as needed while minimizing excess water
use. A properly programmed smart controller requires initial site specific set-up and will
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May 19, 2011
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EPA
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
make irrigation schedule adjustments, including run times and required cycles, throughout
the irrigation season without human intervention.
Note reference to "replenishing water as needed." The actual value required is determined by
maintaining a root zone water balance, including the contribution from rainfall, and replenishing the
deficit with irrigation water; changing the order of calculation amounts to ignoring rainfall. This will
surely result in wasting irrigation water just to ensure "the highest rate of passing scores."
File: 1000-9 (Cont/11)
Final Date: March 21, 2011
Submit to: WaterSense-products@erg.com
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May 19, 2011
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EPA
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
Commenter: George Alexanian
Affiliation: Alex-Tronix
Comment Date: March 2, 2011
Attached are our comments regarding the second WaterSense draft specification for weather
based controllers.
George Alexanian
Alex-Tronix Irrigation Controls
4761 W. Jacquelyn Ave.
Fresno, CA 93722
(559) 276-2888
www.alextronix.com
Commenter Name: George Alexanian
Commenter Affiliation: Alex-Tronix Controls, Irrigation controller manufacturer since 1977
Date of Comment Submission: March 2, 2011 revision 2
Topic: Section 1.0: Qualified WaterSense smart technology methods.
Comment: It is proper to not limit WateSense labeled products to ET based methods.
Rationale: Limiting smart technology to ET based methods would have limited innovation of
potentially simpler methods.
Suggested change (clarification): Last bullet point: "Using non ET based weather or climate
sensors"
Topic 2.0: SWAT report criteria
Comment: Adhering strictly to a 5% surplus per zone in combination while starting with a full root
zone makes it unreasonably difficult to pass for many controllers
Rationale: It will be difficult for controllers with 3 programs to satisfy six diverse irrigation needs of
the virtual landscape which will rarely if ever be present in a real landscape environment. By
Imposing a strict 5% surplus per zone in addition to that limitation is not reasonable, particularly
starting with a full root zone.
Suggested change: Irrigation excess for the six zones shall not exceed a 5% average, or 10% on
any one zone.
Topic: Section 3.1.3 Root zone working water storage
Comment: It is unreasonable to begin with a full root zone. Any irrigation on the first or second
watering day will result in a potentially large surplus causing most controllers to fail by exceeding
the strict 5% surplus requirement.
Rationale: Since the manufacturer has no control whatsoever in adjusting the setup as would
normally be done by the user in the real world, any error, for example irrigating on the first or
second day, will result in an immediate surplus.
Suggested change: Leave the starting point as the root zone being half full to allow for initial
startup minor adjustments and the allowed surplus as an average of 5% for the six zones, with no
zone exceeding 10%.
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May 19, 2011
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EPA
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
Topic: Section 5.2: Testing of add-on devices
Comment: I agree that the add-on need not be sold with the mated conventional controller.
However, it is not practical and is cost prohibitive to require testing the add-on with every controller
it could be mated to.
Rationale: An add-on simply breaks the common line to the valves much like some rain switches or
soil moisture sensors. All controllers have a common line, and it makes no electrical or operational
difference if irrigation is terminated or disabled by breaking the common line from one 24 VAC
controller to another. For consistency, the EPA must then apply the same criteria for compatibility
to rain switches and soil moisture sensors. I also understand the requirement for the add-on and
existing controller to with meet the WaterSense specifications listed in sections 3 and 4. However,
insisting that the add-on must be tested with every controller it may possibly be mated with would
ignore the 13 million existing controllers which could immediately save a significant amount of
water with a much reduced return on investment.
Suggested change: For WaterSense labeling, an add-on that only breaks the common line from a
controller to valves must be SWAT tested with a conventional (non-smart) controller that in
combination satisfy sections 3 and 4 testing and features criteria. Upon the successful completion
of that representative SWAT test, the add-on may carry the WaterSense label when used with the
controllers that the manufacturer certifies are in compliance that in combination satisfy sections 3
and 4 of this specification.
Topic: Section 8.0: Definition of an Add-on:
Comment: The distinction between an add-on and a plug- in is correct. However, the add-on does
not communicate with the standard controller through a common wire connection, while a plug-in
does communicate with the existing controller microprocessor by providing it data. The add-on is
merely a switch that breaks the common line. There is no data transfer between the add-on and
controller, hence no communication by definition.
Suggested change: Redefine the add-on device as: A product that modifies an existing system
equipped with standard clock timer controller to use current climatological data as a basis for
controlling the irrigation schedule. For the purposes of this specification, add-on devices are
defined as those that break the common line wire connection between a standard clock timer
and one or more of its valves.
This revised definition can then properly apply to rain switches and soil moisture sensors.
Topic: Draft Supplemental Guidance document, section 3.2.2.2
Comment: It is not possible for the controller instruction manual to provide the information required
to perform the SWAT test as representative of a real environment. If this must be included within
the owners manual, it must be made clear that the settings cited were specifically made to
accommodate the SWAT testing and that they are not to be used for the user's specific landscape
watering needs.
Rationale: No real landscape has all six diverse soils, precipitation rates, slopes, sun/shade ratios,
etc... The user may be misled into using those specific settings for his landscaping unless it is
clearly stated other wise.
Suggested change: Omit the list of settings used for SWAT testing in the owners manual. They will
only confuse the users.
Topic: Section 3.2.2.3: Add-on testing configuration
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May 19, 2011
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EPA
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
Comment: modify this section to match section 5.2 of the specifications that an add-on need only
be tested with one representative controller that satisfies sections 3 and 4 and that a list of other
controllers that in combination satisfy sections 3 and 4 be certified by the manufacturer of the add-
on and not be tested or sold with those controllers.
Topic: Section 3.2.3: Product documentation
Comment: Modify section that requires the listing of all the controllers that the add-on was tested
with to say that it should list the controller it was tested with and that a list of other controllers that
in combination with the add-on satisfy the WaterSense labeling is also provided.
Topic: Product retesting section 3.6.2 in Supplemental Guide
Comment: Since the labeling has been extended to commercial systems, It is not practical or
reasonable for retesting purposes that a product may be chosen from a job site by the LCB either
annually or every five years. For instance, if the existing controller is a pedestal mounted controller
as part of a central system, it would be totally unreasonable to ask that the pedestal unit be
removed from the field in order for it to be SWAT tested at a different location. For one thing, the
field pedestal is not generally programmable by itself and is reliant upon a central computer
system. The cost of a field mounted pedestal, cost of testing, and replacement may be well over
$10,000 while the add-on may be less than $100. This another example where the add-on can be
certified to be compatible with the controller if together they meet the sections 3 and 4
requirements without separate SWAT testing.
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May 19, 2011
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EPA
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
Commenter: Tom Fairey
Affiliation: DB Live
Comment Date: March 2, 2011
A completed Public Comment Template is attached. (Third try!)
Thank you
Tom Fairey
Template for Public Comment Submission on WaterSense Documents
Commenter Name: Tom Fairey
Commenter Affiliation: DbLive Corp
Date of Comment Submission: March 2, 2011 (Fourth submission: first submitted during
question and answer period, later submitted Feb. 26, 2011 without this template, second
submission earlier today using this template.)
Topic: Change Name of Test and the Subject Device
Comment: Michael D. Dukes, University of Florida, Publication # AE442 provides factual
basis for changing name to "Climatologically-based Controllers". "Weather-based is
incorrect for the subject devices. Basis for change is more fully developed in the
Rationale at the bottom of this form.
Rationale: If left unchanged, EPA will be encouraging market misrepresentation.
Suggested Change (or Language): "Climatologically-based Controllers"
Topic: If name is not changed, require a sticker or prominent sign on the device
clarifying its functionality.
Comment: Sticker necessary to avoid abetting misrepresentation of controller
functionality to the purchasing public. Sticker should say, "Not a weather forecasting or
weather predictive controller"
Rationale: You will in the future write a specification for weather-forecasting controllers.
To avoid confusion the current specification should be properly named.
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May 19, 2011
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Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
Suggested Change (or Language): Climatologically-based Controllers
Rationale:
The term, "weather based controller" may possess the acceptable etymology for
your purpose, but, accounting for what the general public understands by the
term, "weather based", its use is ambiguous to describe the class of controllers on
which your specification is focused and will result in marketing misrepresentation.
I do not believe you intend to do that. The general public will imply or assume
weather prediction or forecasting capability along with the meanings you intend.
Please conduct your own poll outside of your group. I believe you will find that
most people understand the term "weather based" to connote predictive or
forecast functionality as well as current and historic observed weather elements.
The more precise terms, "climate based controllers" or "climatologically-based
controllers" may be rejected by marketers because most consumers and many
professional irrigators do not know the precise meaning of "climate" and make no
distinction between "weather" and "climate". Other correct descriptive terms
would be "historic/current weather based controller", or "Irrigation Controller
based on Historic/Current Weather", but, both of those, of course, would be
awkward for a manufacturer's promotions and labeling.
If you feel you must persist in the use of the term "weather-based", it would be
appropriate to require a sticker or other notice on the unit and in the users guides
that it specifically does not have weather forecast capabilities.
Another reason you may wish to solve this issue now is that you may soon be
faced with creating a specification for a true "weather forecasting controller". The
water-saving potential of such technology is nine times that of a toilet
replacement and six times that of a rain sensor. FYI, DbLive Corp
(www.dblive.com) has developed, manufactured and is selling such a device. An
add-on to existing controllers, its water saving performance is so great and its cost
so small that it is readily selling without the Water Sense label. Because of the
stochastic nature of future weather, it will be extremely challenging to fashion a
test protocol for this technology, and, of course, it would be impractical to test it in
combinations with the millions of controllers up to 40 years old which it converts
F.PA
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WaterSense
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May 19, 2011
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EPA
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
to superior water saving performance. Note that converting these existing water
wasting controllers to greater water saving performance than the latest non-
forecasting systems offered will save far more water than incremental
improvement in the one million new controllers installed each year.
Our common goal is to save water! We look forward to helping the Water Sense
program any way we are able.
Topic:
Comment:
Rationale:
Suggested Change (or Language):
Topic:
Comment:
Rationale:
Suggested Change (or Language):
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May 19, 2011
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EPA
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
Commenter: Gary Okafuji
Affiliation: The Toro Company
Comment Date: March 11, 2011
To EPA WaterSense,
As requested, my comments are resubmitted in the format requested.
Regards,
Gary Okafuji
Manager, Electronic Test Lab
The Toro Company - Irrigation division
951-785-3378
Gary.Okafuji@toro.com
Template for Public Comment Submission on WaterSense Documents
Commenter Name: Gary Okafuji
Commenter Affiliation: The Toro Company
Date of Comment Submission: 3-14-11
Topic: "All runtimes during testing must be greater than 3 minutes"
Comment: This should be brought down to greater than or equal to 2 minutes or made not a
requirement at all.
Rationale: Zone #2 of the virtual landscape only allows a maximum of 6.60 minutes at a time
before runoff starts to occur.
For smaller controllers that only have 3 programs and 3 start times per program, to keep this
moisture balance in check, you have to water this zone everyday.
Using the hottest time of the year (at the site chosen) as a reference point, a weather-based
controller would compare the current weather conditions with this reference point and
subsequently adjust controller runtimes. Most of the year will have percent adjustments less
than 100%.
The 3 minute requirement isn't an issue during the hottest time (percent adjust = 100%). But in
cooler temperatures, if the percent adjust dips to 40% or lower, each runtime will be under 3
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EPA
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
minutes. For cooler areas with smaller ETs, it's more problematic.
Suggested Change (or Language): Either the 3-minute requirement needs to change or the
6.60 minute max. runtime should be increased for zone #2 to approximately 12 minutes. This
can be achieved by either or both of the following:
* Change the soil type
* Change the slope
Topic: "The Root Zone Working Water Storage (RZWWS), as defined in the SWAT protocol,
must be programmed as full at the beginning of the test."
Comment: I'm not clear on this. If you mean the moisture balance (MB), at the beginning of
30-day test cycle, the moisture balance should start at 1/4 the RZWWS. e.g. Zone #2. RZWWS
= 0.55 in. At the beginning of the 30-day test cycle, the MB = 0.28 in.
You can't have the test start with the zones' moisture balances at field capacity.
Rationale: With a rolling 30-day test period, a weather-based controller is making irrigation
adjustments based on weather information from the past few day(s). If the 30-day cycle begins
where the previous days are sunny, the controller will incorrectly irrigate, resulting in over-
watering. This is an unfair and unrealistic assessment. The controller can't anticipate where
the 30-day test cycle will begin. It needs weather data to make decisions. Having the test
cycle start in the middle of the RZWWS allows the weather-based controller to make the
appropriate adjustments.
Suggested Change (or Language): Keep the moisture balance as 1/4 of RZWWS at the
beginning of the test.
Topic: "There shall be at least four days during test period with 0.10 inches or greater of
precipitation for the test to be considered valid."
Comment: If the test is done in California (or other dry areas with little rainfall), this may be
difficult to achieve.
Rationale: It's hard enough to meet the criteria with the current SWAT protocol. There's only
about 2 periods out of the year where you can meet both the minimum requirements of ETo =
2.50 in. and rain = 0.40 in.. After crunching 2010 data from CIMIS Sta. #80, I found the
additional 4-day requirement reduces the qualification period to only one period in the year
(mid-Feb to mid-Apr) (see attached chart). If you reduce the requirement to 3 days, it opens up
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WaterSense
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
another small opportunity in the fall. Another option is to extend test period to 60 days, and
doubling the ETo and rainfall requirements to 5.00 inches and 0.80 inches, respectively.
Suggested Change (or Language): Keep the current 30-day requirements but reduce the
requirement of 0.10 inch rain days from four to three.
Topic:
Comment:
Rationale:
Suggested Change (or Language):
Periods where min. ETo arid rainfall were met
Periods where min. ETo, rainfall and days of 0.10" rain
were met
Min. Eto ¦
Minimum rainfall ¦
Minimum days of 0.10" rain ¦
CIMI5#80 (Fresno, CA)
1/1/10 -12/31/10
Rolling 30-day totals
ETo
Rainfall
— — "Minimum Eto = 2.50 in.
— — -Minimum rainfall = Q.40in.
No. days of 0.10" rainfall
Mi n. d ays of 0.10" rai nfal I
Meets min. Eto & rainfall req.
Meets min. Eto, rainfall, 0.10" days
2010 2/28/2010 3/31/2010 4/30/2010 5/31/2010 6/30/2010 7/31/2010 8/31/2010 9/30/2010 10/31/2010 11/30/2010 12/31/2010
n i n
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*
Comments on the Revised Draft Specification for
Water Sense Weather-Based Irrigation Controllers
CI MIS #80 (Fresno, CA)
1/1/10 ~ 12/31/10
Rolling 30-day totals
No. daysofO.10" rainfall
Min. daysofO.10" rainfall
Meets min. Eto & rainfali req.
Meets min. Eto, rainfall, 0.10"days
2010 2/28/2010 3/31/2010 4/30/2010 5/31/2010 6/30/2010 7/31/2010 8/31/2010 9/30/2010 10/31/2010 11/30/2010 12/31/2010
1/30,
Periods where min. EToand rainfall were met
Minimum
inimum days of 0.
din. Eto =
2.50
¦ ! I I I I
0.40
Periods where min. ETo, rainfall and days of 0.10" rain
L0" rain =
I I I I I I
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EPA
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
Commenter: Karen Guz
Affiliation: San Antonio Water System
Comment Date: March 14, 2011
To the EPA WaterSense staff involved with the Weather Based Irrigation Controllers specifications:
Attached is input from the San Antonio Water System Conservation Department. Please see that our
comments are included in the public record.
Best regards,
Mark A. Peterson
Project Coordinator - Conservation
Template for Public Comment Submission on WaterSense Documents
Commenter Name: Karen Guz
Commenter Affiliation: Director of Water Conservation - San Antonio Water System
Date of Comment Submission: March 14, 2011
Topic: Testing Modification to the SWAT protocol 3.1.1. Irrigation events totaling 3
minutes or less shall be excluded from the daily water balance.
Comment: Keep the Alliance for Water Efficiency's draft language but ensure each test is
identified as "cycle and soak" so as to prevent manufacturer "gaming" the testing.
Rationale: Short run times can be effective in clay soils as part of a cycle and soak
component. However, they also can be used during the testing to maintain performance
effectiveness not based in realty.
Suggested Change (or Language): Retain the Alliance for Water Efficiency committee's
suggested language.
SAWS
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EPA
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
Topic: Section 3.2 Performance Requirements.
Comment: Manufacturers of these products and water purveyors have expressed strong
disagreement on whether an average of the zones meets the performance threshold or each
zone meet the performance threshold. This is an important conservation concern and will affect
the WaterSense "brand".
Rationale: The EPA modified the original language as a result of follow-up research by the
University of Florida. A passing rate for each zone rather than an average of six (6) zones
clearly demonstrates the performance of the controller.
Suggested Change (or Language): Retain the EPA's proposed language.
Topic: Section 3.1.5 Order of Operations
Comment: Based on the follow-up research by the University of Florida, the order of
operations "did impact performance scores", i.e., permitted more to pass testing. However, to
retain some credibility, the order of operations should remain under current SWAT protocol.
Rationale: The proposal in the new protocol to allow rainfall to be taken into account later
which would make it so that the water balance does not reflect that the controller may have
irrigated the day or day before a big rain. Some think this is "more fair" to the controllers. Our
concern should not be what is "fair to the controllers" but how well the controllers manage to
minimize use of supplemental irrigation and allow maximal use of rainfall. If some controllers
manage this better than others by either not completing filling soil with water, by having more
accurate rain devices (tipping buckets or better rain sensors), or by using more complete
weather data to anticipate rainfall to prevent irrigation then that should be reflected in the
results for consumers. It is not good to take this as a comparison option out of the reports for
the consumer. The proposed change also makes it appear that the controllers perform better
against a person managing the irrigation system than they actually do.
There has been concern expressed that without this change, fewer controllers will pass and
earn the WaterSense label. This is not a bad thing. It may be exactly what the program needs
to retain credibility. There is a lot of concern among water purveyors that many WBIC products
increase water consumption or do not save despite manufacturer claims. If fewer earn the
label and there is more rigor to the standards, that could help overcome that perception.
Suggested Change (or Language): Retain the EPA proposed language.
18
May 19, 2011
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EPA
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
Topic: Revision of the term "Irrigation Adequacy"
Comment: The minimum of 80% irrigation adequacy infers a poorer performance than a 100%
adequacy, which the manufacturer may pursue by adjusting the controller. Yet the 80%
achieves the greater water conservation.
Rationale: Although 80% is considered excellent from a conservation perspective, it is
instinctive to look for 100% if you are a customer. Therefore the manufacturers are trying to
get that adequacy closer to 100% than to 80%. This is a detriment to getting them to function
well to not over-water. It may be part of why some controllers are not saving as much as we'd
like to see. If the metric were re-worded in some way such that it was a proportion of how
close it got to the 80% perhaps it could address that. In other words, make it sound good to be
close to 80% instead of close to 100%.
Suggested Change (or Language): Provide for gradient terms such as Maximum Efficiency
(80%) to Acceptable Efficiency (100-105%) or something similar.
Topic: Ensure that tests are performed by qualified testers, not the manufacturers
Rationale: Testing by non-biased 3rd parties lends credence to the WaterSense label and
prevents the input of illogical settings by the manufacturer.
Suggested Change (or Language):
Comment:
19
May 19, 2011
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EPA
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
Commenter: Peter Carlson
Affiliation: Hydropoint Data Systems, Inc.
Comment Date: March 15, 2011
Please find HydroPoint Data Systems, Inc. comments / questions to the WaterSense Revised Draft
Specification for Weather-Based Irrigation Controllers
If you have any questions, please feel free to contact me.
Peter Carlson | VP Product Management & Technology
HydroPoint Data Systems, Inc., provider of WeatherTRAK
1720 Corporate Circle | Petaluma, CA 94954
t 707-285-3236 | m 707-338-7033| f 707-769-9695
800-362-8774 | pcarlson@hydropoint.com
www.hydropoint.com
The green initiative with the fastest payback. Find out why:
www.weathertrak.com
Template for Public Comment Submission on WaterSense Documents
Commenter Name: Peter Carlson, Vice President of Product Management & Marketing
Commenter Affiliation: HydroPoint Data Systems, Inc. Makers of WeatherTRAK ET Irrigation
controllers
Date of Comment Submission:
Topic: Suggested new language on section 3.1.1 - minimum runtimes
Comment: Using a minimum cycle time of 3 minutes for a single irrigation cycle can be in
contradiction to the WaterSense goals of water conservation due to the water lost to run-off.
Rationale: Cycle time requirements should be determined by a landscapes soil type (each soil
has a different water infiltration rate), sprinkler precipitation rate and slope. If the landscape has
soil with a low infiltration rate, like clay soils, a spray head with a standard precipitation rate on
a steep slope, the ideal runtime will be less than 3 minutes.
-Peter
20
May 19, 2011
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EPA
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
In contrast, the total daily station runtime should not be less than 3 minutes. The controller
should irrigate as infrequently as possible to promote a healthy landscape with deep root
depths.
More detailed calculations can be provided if required.
Suggested Change (or Language):
Minimum Runtimes: The total station daily runtime (sum of all the daily irrigation cycles) that
occurs during the test period must be greater than three minutes in duration. The total water
applied to an individual station during a day's irrigation events totaling three minutes or less
shall be excluded from the daily water balance calculation.
Topic: How will we be provided the Weather data by the certifying laboratory?
Comment: The WeatherTRAK controller utilizes ASCE-ET weather data to accurately
calculate the amount of water a landscape needs and how often to irrigate. How will HydroPoint
get access to the weather data so we can send the appropriate ET data to our controller?
Suggested Change (or Language): Using the SWAT protocol, CIT handled this situation by
making the source of the ET value available.
Topic: How do we verify the quality of the weather data used by the test?
Comment: How is the weather data (ET data) used as part of the test validated and quality
assured?
Rationale: Weather station measurement equipment is subject to outdoor real-world conditions
that require the data to be validated. Some of these conditions include birds setting up nests on
a tipping rain bucket, or on an anemometer.
Also, weather stations must be properly sited to ensure that the data they collect is not biased
by nearby equipment such as a air condition or air flow interrupted by a building. Both the
National Weather Service (NWS) and CIMIS (California Irrigation Management and Information
System) have weather station citing criteria for ET based weather stations.
http://www.cimis.water.ca.gov/cimis/infoStnSiting.jsp
Suggested Change (or Language):
Rationale:
21
May 19, 2011
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EPA
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
Topic: More clarification on section 4.1 - duration to maintain time with loss power source
Comment: It is not clearly defined how long the correct calendar data and time must be
maintained without an external power source.
Rationale: To keep time some power source is required. It is reasonable for a controller to
maintain time through intermittent power outages that might affect a home or commercial
property. However, since most outages last less than 4 hours (the actual number depends on
where the location of the property). For remote areas, a power outage can last much longer.
Suggested Change (or Language): The controller shall be capable of preserving the contents
of the irrigation program settings and the correct calendar date and time when the normal line
power source is lost and without relying on an external battery backup for at least 72
continuous hours.
Topic: Removal or modification of manual operation limit in section 4.8
Comment: Troubleshooting is one of the many reasons landscape contractors utilize manual
operation. Limiting the overall time a controller can run manual irrigation will require inefficient
workarounds by landscape contractors to perform required operations.
Rationale: Troubleshooting is only one method of manual operation usage. Manual operation
can also be used to learn station based flow (which helps find small leaks in the system) or
syringe fertilizers put on the landscape. For higher station count controllers (48), learned flow
takes about 4 minutes per station or about 3 and a half hours.
Since manual operation will normally be performed by a landscape contractor while he/she is
onsite, it is unlikely that manual operation will be abused.
Suggested Change (or Language): The controller shall be capable of allowing for a manual
operation troubleshooting test cycle. The manual operation shall be limited to 60 minutes per
station per day. The controller shall automatically return to default mode even if a switch is still
positioned for manual operation.
Or
Remove Section 4.8
Topic: Table 4.0 format confusing
22
May 19, 2011
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EPA
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
Comment: The two columns provided in table 4.0 - Supplemental Capability Requirements are
confusing. Remove the two columns.
Rationale: A controller that has the WaterSense label will be "Smart" and should always be in
some smart mode. If the controller has lost communication with its signal or local senor it
should still be in some "Smart" mode. By removing the columns, required in Smart Mode and
Required in Standard Mode, these will just be requirements that all WaterSense controllers
must meet.
Suggested Change (or Language):
Topic:
Comment:
Rationale:
Suggested Change (or Language):
Topic:
Comment:
Rationale:
Suggested Change (or Language):
23
May 19, 2011
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EPA
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
Commenter: Thomas Reynolds
Affiliation: Water Balance, LLC
Comment Date: March 15, 2011
It is my pleasure and privilege to contribute to this important work.
Find my comments attached.
Tom Reynolds
Tempe, AZ
602-463-5072
Commenter Name: Thomas Reynolds
Commenter Affiliation: Water Balance. LLC
Date of Comment Submission: March 15, 2011
Topic: Section 1.0
Comment: "+ Storing historical crop evapotranspiration (Etc) data characteristics of the site
and modifying these data with an on-site sensor." I appreciate the brevity, but for general
consumption, you might expand, to be clear.
Rationale: While the integration directly to Etc is subtle, the term "historical" is best applied to
Eto. The crop or species adjustment factors are developed through remote research, ground-
truthing methods, or an expert panel and perhaps some long-term validation in the field.
Suggested Change (or Language): Consider: Storing historical reference evapotranspiration
(Eto) data characteristic of the site and modifying these data with an on-site sensor to make
them more site- and period-specific. Generally, the localized Eto is then manipulated with
credible crop or species adjustment coefficient(s), and perhaps also micro-climate and density
factors.
Alternatively, or additionally, indicate to those new to the terms that for a complete explanation
of "historical reference and crop evapotranspiration', please see IA SWAT Protocol.
Topic: Section 1.0
24
May 19, 2011
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EPA
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
Comment: Again, I appreciate the brevity, you might expand, to be clear: Your "Using onsite
sensors as a basis for calculating real time ETc" integrates such distinct elements almost to a
fault. It is clear to me the authors really refer to controllers that will use on-site sensors to
estimate site-specific, real-time Eto, which then can be modified for crop/species using
coefficients that have been transferred from remote site research, ground-truthing methods,
and long-term validation in the field. Non-turf species are then further modified with estimated
factors to account for micro-climate and density.
Rationale: The use of sensors on-site to generate an estimate of Eto is accurate. The
correction to this site-generated estimate can be modified just like the previous technique using
historical Eto.
Suggested Change (or Language): Consider: Utilize on-site, non-plant, but climatologic
sensors to generate estimates of Eto, then manipulate this estimate with additional estimates or
coefficients that have been developed through transfer of remote research, ground-truthing
methods, and long-term validation in the field and modified further for micro-climate and
density.
Topic: Section 1.0
Comment: third bullet can be more explicit without getting overly wordy.
Rationale: People with no back ground will be utilizing this.
Suggested Change (or Language): Using a remote weather station as a basis for Eto and
subsequent Etc calculations, transmission of the data to individual users at remote user sites
Topic: Section 1.0
Comment: "Using on-site weather or climate sensors" seems redundant, but that's OK. Others
may ask, "Why does second bullet so resemble the last bullet?" But since it is there, it begs the
question, isn't a soil moisture sensor is the ultimate weather sensor. Weather stations attempt
to do what soil moisture sensors do directly. If you want to know what Eto is, measure it
directly. Might consumers challenge the EPA with "There is a good reason we don't use
weather data to calculate what room temperature is going to be."
Rationale: A logical conclusion. At this juncture, the public does not know WaterSense will, or
will not, develop a soil moisture based specification. So what happens to this bullet point if the
words "weather or climate" are removed?
25
May 19, 2011
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EPA
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
Suggested Change (or Language): Using on-site weather or climate sensors, but ground-
truthing sensors, such as stem-gauges or soil moisture sensors are not included at this time.
Topic: Section 2.0
Comment: "Irrigation adequacy and excess" has been rigorously scrutinized by the leading
minds in the irrigation industry. The EPA can put a few more of the cards on the table. If the
WaterSense seal of approval means we all can purchase these systems assured that over the
course of a season, we can take soil cores to determine actual soil moisture content, and it is
within 80% or 5%, as compared to the water-balance calculation residing in the controller's
processor and log examined at any time, then fine. Early developers of the AZMet system in
Arizona, at a seminar on expert systems in agriculture in 1982 stated (paraphrasing), "due to
errors in the model, and additional errors across sensors, periodic ground-truthing to re-set the
cotton soil water balance will be necessary."
An imperfect model is be used to validate and assure citizens that a distant relative at a
research facility has been mimicked in their man-made, non-conforming back yard. The
nutrition of the plants has just a bit do with ET principals reliability.
Rationale: Problem with transfer to non-conforming sites
Suggested Change (or Language): Weather-based Irrigation Controllers for Conforming
Facilities
Topic: Section 3.0
Comment: In 3.1.3, I totally appreciate the desire of the irrigation industry to provide
assurance measures to the market. With the proper leadership and will every parcel and
property with more than 1,200 SF of turf would receive one of these systems for $50.00 to
$500.00, and it would handle all of the nation's turf, by law. Expect each installation could be
tweaked to excellent efficiency, with the givens, on turf.
Bt, does the SWAT Protocol simplify matters a bit for non-turf areas in landscapes.
Rationale: The testing can not reveal what will really happen at properties across the nation
and in the hidden, wetted root masses around plants and trees because the SWAT Protocol set
plant densities Zones 3, 4, and 5 at or above 1. A density factor of "1" translates to full cover.
Furthermore, it is unclear, but I hazard to guess, the assumption is that 100% of the areas are
wetted, though it states, "...the protocol uses a simplified approach... where complete wetting
may not be required."
26
May 19, 2011
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EPA
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
Suggested Change (or Language): Root Zone Working Water Storage (RZWWS) starting
point: The RZWWS, as defined in the SWAT Protocol, must be programmed as full at the
beginning of the test. By full, we refer to turf zones at field capacity, not to be confused with
Zones 3, 4, and 5 which must, in the interest of expediency, also be fully wetted zones. Future
amendments to this specification Must address such realities as: 1) usually less than 50% of
the micro-drip irrigated areas are actually wetted, yet full production is easily achieved, albeit
not without more frequent irrigation deliveries and (theoretically) closer attention to plant
nutrition, 2) criteria that embrace "xeriscapes", a construct from Colorado, whereby often there
are significant spaces where plant canopy cover is incomplete, 3) for nearly all new
landscapes, canopies and root systems expand and/or become more dense, which effectively
reduces the application rates, and 4) conventional calculations of "precipitation rate" may need
better explanation and assessment. All four items put pressure on us to further explore the term
RZWWS in non-turf zones.
Topic: Section 3.0
Comment: Again 3.1.3 -The EPA has adopted The lA's SWAT Protocol, which includes a
Table 1: Description of Zones Part (2)- Root Zone Working Water Storage (RZWWS)
Calculations. The group consensus has remained that the root zone depths have been
appropriately set. However, with root zone depths beyond 6 to 10 inches, with each additional
increment, we make the challenge I have established above more implausible. The more
shallow the rooting depth, the more likely those tests from the lab would agree with the data
logged by the processor.
Rationale: Soil texture and bulk density will typically change with depth, as a function of man's
interventions or as laid down over very long time.
Suggested Change (or Language): Add 3.1.6 Particularly Critical Challenges for Future
Consideration-. At this time, the IA SWAT Protocol assumes uniformity in soil physical
properties throughout and slightly even beyond 2 feet in depth, which is reasonable for woody
plants and trees. Users with plants and trees, particularly micro-drip irrigated ones, will be
advised by manufacturers that periodic evaluation of the soil moisture content will be required
with this first generation of controllers since your controller may be incapable of integrating
variable soil properties below 10"-12", thus incapable of rendering a true estimate of soil
moisture depletion verifiable by laboratory analysis.
Topic: Section 4.0
Comment: 4.5 - The relationship between station count and critical need for flow sensors may
be a bit off point. Yet, station count is the only categorization available, it seems.
27
May 19, 2011
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EPA
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
Rationale: The first rule of water management is water measurement. The reality is likely that
water prices must increase, or rather stringent water budgets must be established and
enforced, as a matter of regulation for dual metering to be affordable. Perhaps with millions of
sensors deployed, sensor cost will decline.
Suggested Change (or Language): Clocks with 9 or more stations shall be capable...with a
flow sensor.
Topic: Section 4.0
Comment: 41 - The model uses a checkbook method, and that value is present, yet
inaccessible.
Rationale: The processor calculates estimated soil water balance, and acts upon those
calculations.
Suggested Change (or Language): Furthermore, continuous, moving- 30 days of time & date
stamps associated with the calculated RZWWS for each zone just preceding each cycle start
shall be stored and accessible through a simple data port. Additionally, a button shall be
available, which when pressed at any point in time for each zone, the calculated current
balance in each RZWWS is shown by scrolling through stations on the display.
28
May 19, 2011
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EPA
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
Commenter: Diana Schulz
Affiliation: Cyber-Rain
Comment Date: March 16, 2011
Thank you for the opportunity to comment on your latest draft specification, which are
attached. Please confirm receipt of this message.
Best regards,
Diana Schulz
Diana Schulz
CEO
Cyber-Rain, Inc
6345 Balboa Blvd, Suite 230
Encino, CA 91316
818-749-7480 (mobile)
818-343-5200 (main)
818-343-5220 (fax)
DSchulz@cvber-rain.com
http://www.cyber-rain.com
Template for Public Comment Submission on WaterSense Documents
Commenter Name: Diana Schulz
Commenter Affiliation: CEO, Cyber-Rain
Date of Comment Submission: March 16, 2011
Topic: 1.0 Scope and Objective
Comment: Slightly modify the 4 bullets to broaden their applicability and recognize that there is not
a single ET calculation.
Rationale: The bullets are a little narrow in specifying how a controller receives weather
information. They also refer to using 'ET' instead of 'ET principles' when modifying schedules,
which does not reflect the fact that manufacturers use different ET equations. The language
modifications are proposed to avoid inadvertently inhibiting innovation by excluding methods of
collecting and using weather information.
Suggested Change (or Language):
cqber roin
29
May 19, 2011
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EPA
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
Bullet #1: Add italicized phrase at the end so it reads: Storing historical crop evapotranspiration
data characteristics of the site and modifying these data with an onsite sensor or real-time weather
inputs transmitted daily to the controller
Bullet #2: Slightly reword (indicated in italics): Using onsite sensors as a basis for calculating real
time irrigation schedule adjustments based on ETprinciples
Bullet #3: Slightly reword (indicated in italics): Using a central weather station as the basis for
irrigation schedule adjustments based on ET principles and transmitting the data to individual users
from remote sites
Topic: 2.0 Each zone must individually meet performance threshold
Comment: The zone configurations being tested represent a wide range of landscape parameters,
including some that do not occur commonly. Such 'extreme' conditions make compliance with
some of the virtual landscape zones less probable than would be expected with less exotic, real-
world conditions. Requiring each zone pass individually raises the performance threshold on
manufacturers beyond a point of benefit for the majority of customers.
Rationale: The landscape parameters being tested represent a wide range of conditions and
restrictions, with hydro-zones 3, 4 and 5 being fairly exotic. By requiring each controller to pass
individual zones, manufacturers will need to increase the cost of their product to address the wide
range of requirements. Measuring on combined results would be more representative of the
majority of users.
Suggested Change (or Language): Performance should be measured in aggregate
Topic: 3.1.1 Minimum run time of 3 minutes
Comment: Requiring a 3 minute continuous minimum run time on zones with clay soil and slopes
(such as zone 2) are likely to cause significant surface runoff. The standard should be changed to
allow manufacturers to cycle their watering so that the 3 minute standard is achieved through the
sum of cycles within a specified period of time.
Rationale: Run-off is a well established problem and manufacturers have effectively addressed
this problem through cycle and soak technology. Consumers are already receiving the benefit
through reduced testing time. By artificially imposing a minimum 3 minute cycle time, consumers
will incur increased runoff with no other benefit.
Suggested Change (or Language): Either no minimum run time or the aggregate of irrigation
cycles within a 24 hour period of time is a minimum of 3 minutes.
Topic: 3.1.2.1 Missing Data
Comment: Refer to data as 'weather inputs' vs 'ET data'
30
May 19, 2011
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EPA
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
Rationale: The term ET data is erroneous at its core. ET is not directly measurable. It is the
summation of various Environmental Parameters (Weather Inputs) within the framework of a
mathematical model (Penman equation or some variant) to calculate ET. Not all systems use the
same modeling protocol so the term 'weather inputs' is more appropriate. Similarly, the source of
the data should be more flexible, not limited only to an 'ET gauge' or similar device as the ET data
moniker would seem to imply.
Suggested Change (or Language): Replace 'ET Data' with 'Weather Inputs' and replace
'reference weather station' with 'weather source data'
Topic: 3.1.3 Root Zone Working Water Storage Starting Point
Comment: Change assumed testing start point to 50%
Rationale: Few home owners or irrigation professionals know their root zone working water
storage starting point when programming their controller. Therefore, in order to make programming
more user-friendly, many manufacturers do not require the user to enter their starting point. For
those that are required, most professionals assume a 50% starting point for ease. Therefore, using
50% is the most representative of how the controller will be used.
Furthermore, assuming a 100% MAD point when the product is sold to consumers could run
counter to EPA goals. Instead of manufacturers sharing the universal goal of bringing the
landscape up to field capacity immediate, the controllers would immediately begin reducing
irrigation times. This could lead to widespread landscape stress and consumer dissatisfaction. In
reaction, consumers could increase their water budget or even abandon their smart controller.
The concern was raised that it is difficult to achieve an accurate 50% MAD point in a testing
environment. However, even a reasonable variation from this starting point in the testing
environment will be considerably better representative of real-world use than a fully accurate 100%
starting point.
Suggested Change (or Language): Root Zone Working Water Storage Starting Point should be
programmed at 50%
Topic: Appendix A 1.0: Testing and Configuration
Comment: Manufacturer's should provide input into the initial scheduling of the controller.
Rationale: Irrigation controllers differ from many of the other WaterSense tested products (i.e.
shower heads or rain gauges, which conserve water in a very specific, uniform way) in that there is
a lot of variability in the underlying conditions imposed via the environment in which they must
operate. Plant types, emitters, slope, soil, climate, root depth, etc. In addition, many of the people
using the products are not educated on the subtleties of their landscapes. Manufacturer's are
challenged to deliver devices that efficiently irrigate under varying conditions yet are both
affordable and easy for consumers to use.
31
May 19, 2011
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EPA
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
The drafted testing approach is exacerbating this situation, particularly since each zone must pass
individually. The hydrozone parameters deviate widely from real-world landscape conditions and
are not representative of a typical consumer experience. In particular, hydrozones 3, 4 and 5 are
quite exotic in their conditions and restrictions. If manufacturers are not allowed to provide input as
to how their controller should be initially programmed, they will be required to complicate their
controller / user experience and instruction manual solely so the controller can be successfully
tested. Yet the water savings benefits to the consumers will be minimal as few will encounter the
extremes being tested in the hydrozones. It could even be argued that the consumer experience
would be negatively impacted due to the increased complexity of the product and/or user manual.
Giving the manufacturer input into the initial scheduling is also consistent with the certification
goals. The two criteria being measured are irrigation adequacy and irrigation excess, which are
intended measure how well controllers adjust irrigation with changes in the weather. Inaccurate
initial programming can adversely impact the results of a controller that would otherwise adjust
irrigation times appropriately. The SWAT protocol recognizes this by allowing manufacturer's to
fully program the controller prior to testing.
If the EPA wishes to test a typical consumer experience including both programming and weather
adjustments, then the test criteria should be adjusted. Hydrozones should be redefined to be
typical of a consumer landscape and/or the testing should be aggregate results across zones.
Suggested Change (or Language): Manufacturers may program the controller initially or provide
specific instructions on the initial programming of the controller for each hydrozone to
accommodate the virtual landscape.
32
May 19, 2011
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EPA
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
Commenter: Steven Moore
Affiliation: Irrisoft, Inc.
Comment Date: March 21, 2011
To EPA WaterSense team,
Please accept my comments regarding the WaterSense Revised Draft Specification for Weather-Based
Irrigation Controllers
Sincerely
Steven Moore
Irrisoft, Inc.
Office: 435-755-0400
Mobile: 435-770-3896
Public Comment Submission on WaterSense Documents
Response to: WaterSense® Revised Draft Specification for Weather-Based Irrigation
Controllers - Version 1.0 dated January 20, 2011
Commenter Name: Steven Moore
smoore@irrisoft.net
435-755-0400
Commenter Affiliation: Irrisoft, Inc. - PO box 6266 North Logan, Utah 84341
Date of Comment Submission: March 19, 2011
1. Add-On Device Testing
2. Seasonal Crop Coefficients
3. 3-Minute Run Time
4. Root Zone Water Working Storage (RZWWS)
5. Rainfall Requirement
6. Rain
7. "Mode" Requirements
8. "Rain Sensor"
9. Prohibited Watering
10. Manual Watering
11. Full Root Zone
12. Testing Location
13. SWAT Protocol
Topics:
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May 19, 2011
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EPA
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
Topic 1: Add-On Device Testing
Comment: The Add-on testing requirement needs to be changed. It currently states in section 5.2:
"Add-on devices must be tested with each base controller model with which the
manufacturer intends it to be connected".
Allow me to reword part of a paragraph from the WaterSense Program News:
"An estimated 13.5 million irrigation systems are currently installed in residential lawns
across the United States. Of the 13.5 million units installed, the majority use standard clock
timer controllers. The simple installation of a WaterSense labeled Add-on device or
replacing a standard clock timer controller with a WaterSense labeled controller could save
more than 10,000 gallons of water per household annually—that's nearly 150 billion gallons
per year across the United States."
The biggest water savings will come from improvements to existing irrigation systems. There is a
market for a simple add-on device that will reduce water use and perform to the specification.
1) Testing an add-on device with every possible controller will never happen. There are
hundreds of models of controllers. It would be too costly and not practical.
2) It is not necessary.
3) When you see differences in performance results between add-on devices or the same
add-on device tested with various controllers, the root cause of the difference has nothing
to do with the capabilities of the base controller. The differences are caused by either
weakness of the add-on device or a problem with the test process.
4) I have been working with add-on devices for 10 years and have yet to find a "Standard"
controller that would not work with our equipment.
5) The principle behind an add-on device is very simple. The device interrupts the common
wire to prevent the controller from activating a valve. The base controller performs the core
function of how long a valve runs and when a cycle starts and the add-on device is smart
enough to know if the cycle should water. Differences in the base controller do not affect
the results.
6) Testing of add-on devices has demonstrated they are just as effective as fully integrated
Smart Controllers.
7) I participated in the testing of add-on devices. We elected to test it with 2 different
controllers; one feature rich and the other was a very basic low-cost controller. The results
were not the same, but the difference in performance had nothing to do with the controller.
The difference in performance scores had to do with the order of operations problem that
has been identified and corrected. The interesting thing about that test was, the setup that
earned the highest score was the low-cost controller.
Rationale:
34
May 19, 2011
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EPA
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
8) If an add-on device can control the diverse landscape described by the SWAT protocol
without over or under watering it is an amazing work of technology. It deserves the Water
Sense Mark and the EPA should be grateful for such innovation.
Do NOT encumber the creative minds of this industry with the unnecessary cost of countless
useless tests.
Suggested Change (or Language): Change section 5.2 Add-On Devices to read:
The add-on device is not required to be packaged with the base controller(s) that it was
tested with to meet the requirements of this specification. However, the product
documentation for the add-on device must list each the required specification of the base
controller model that the device was tested with to meet the requirements of this
specification and with which the manufacturer intends it to be connected. The
documentation must also contain a statement to the effect that the device is only
WaterSense labeled when used in combination with a base controller that meets the
required specification on the provided list. The add-on device shall be tested with a
controller chosen by the Licensed Certificating Body that meets the specification as
published by the add-on device manufacturer.
Change Appendix A section 2.0 Add-on Devices to read:
Add-on devices must be tested with each a base controller model that meets the
specification published by with which the add-on device manufacturer intends it to be
connected. As a unit, the add-on device and the base controller must meet all of the
requirements contained in this specification.
Change Appendix B section 3.2 to read:
Only add-on devices certified to meet the requirements of this specification may bear the
WaterSense label. Base controllers that the add-on devices are tested with and that are
sold separately from the add-on devices shall not bear the WaterSense label. Product
documentation shall indicate that the add-on device is only WaterSense labeled when used
in combination with the a base controller^ that meets the required specification listed in
product documentation as described in Section 5.0 of this specification.
Comment: There is no detail in the specification to tell a Licensed Certificating Body how to deal
with seasonal crop coefficients at testing locations. Read fine print associated with Table 2 called
"Crop (Turf) Coefficients (Kc)" on page 6 in Draft 8 of the SWAT test protocol. The footnote states:
"The Kc values in this table are meant to be representative for test purposes only. They should
be verified before being accepted in specific locations."
1) What is the verification process?
2) How will the Licensed Certificating Body determine the values in this table?
Topic 2: Seasonal Crop Coefficients
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Comments on the Revised Draft Specification for
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WaterSense
3) How will those values be communicated to the Smart Controller Manufacturer?
4) How should this be documented in the User Manual, per requirement 5.1?
I would also like to point out that the test protocol does NOT provide any means to verify a Smart
Controller responds to the season changes of the crop coefficient. The test period is only 30 days.
A manufacturer can set a static Kc value for the month the device will be tested and achieve a
passing score.
Rationale: Seasonal crop coefficients vary from region to region. I can site many references to this
fact. But landscape water managers who have been implementing ETbased control for the last 20
years typically use a constant Kc value. They have not implemented seasonal Kc curves because
of the complexity of the process, insufficient research and documentation of the Kc curves for most
parts of the country.
The Irrigation Association BMP teaches a static Kc value incorporated into the KL value
(Landscape Coefficient). There is no reference to a sesaonal Kc.
Suggested Change (or Language): The simplest solution to this problem is to eliminate the
seasonal Kc table and use fixed Kc values for all zones. The better solution is to provide seasonal
Kc tables for each testing location.
To get the specification released I recommend the simpler approach and suggest the following
change:
Table 1: "Description of Zones" to be changed as follows:
• Zone 1, Item #6 Crop (turf) Coefficient (Kc) change to 0.64
i. ( Species factor - Cool Season Grass 0.8 x Microclimate factor - Low 0.8 x
Density factor - Average 1.0)
• Zone 2, Item #6 Crop (turf) Coefficient (Kc) change to 0.6
i. (Species factor - Warm Season Grass 0.6 x Microclimate factor - Average 1.0 x
Density factor - average 1.0)
• Zone 6, Item #6 Crop (turf) Coefficient (Kc) change to 0.6
i. (Species factor - Warm Season Grass 0.6 x Microclimate factor - Average 1.0 x
Density factor - average 1.0)
Comment: There is no question water is wasted when a sprinkler valve only comes on for 3
minutes. There is no time for the water to soak in. There are times a controller is used for other
purposes such as; filling a pond, flushing a filter, cooling the turf etc. These functions may require
valves to operate for a minute or less.
Rationale: Don't impose changes to a controller design specification. But make sure the controller
will perform as expected.
Suggested Change (or Language):
Topic 3: 3-Minute Run Time
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Comments on the Revised Draft Specification for
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WaterSense
1) I want to make sure a Licensed Certificating Body does not misunderstand the intent. A
controller manufacturer may design a controller to actuate a valve for less than 3 minutes; this
should be allowed.
2) The test should ignore run-times less than 3 minutes. But station timing and the logging process
may need to allow for a slight margin of error. I propose this minimum time be changed to 2
minutes and 55 seconds.
Comment: The heart of the SWAT Protocol is the RZWWS. The current RZWWS ranges from .55"
to 2.25". These are unrealistically high for most landscapes. A more realistic RZWWS range is .25"
to .8". The current range in the RZWWS makes it very easy to get a good score. Because a Smart
Controller can earn the Water Sense mark with only an 80% adequacy score the controller should
be tested under more realistic conditions.
Rationale: RZWWS is based in part on root depth. Many landscapes have turf roots at only 3" to
4" and shrubs and trees at 12" to 18". Yes, it would be better if landscapes had deeper roots and
many do, but that is not the normal reality.
A tighter range will more accurately demonstrate the controller's ability to adequately water without
excess. If a controller can demonstrate it waters efficiently with shallow rooted plants it will do just
as well with deep rooted plants.
Suggested Change (or Language): Modify the RZWWS calculations table in the Protocol to
shallower root systems resulting in RZWWS values ranging from .27 to a maximum of 1.14".
Zone 1: 5" root depth = 0.42"
Zone 2: 4" root depth = 0.27"
Zone 3: 12" root depth = 0.54"
Zone 4: 16" root depth = 1.14"
Zone 5: 20" root depth = 1.8"
Zone 6: 6" root depth = 0.35"
Topic 5: Rainfall Requirement
Comment: Paragraph 3.1.4 states:
"... .four days during the test period with 0.10 inches or greater of precipitation...."
I agree with this change. There needs to be some clarification in the definition of rain.
Rationale: The SWAT test protocol table 5.1 has two definitions of rain:
1) R = Gross amount of rainfall as reported in inches.
2) Rn = Net amount of daily rainfall to be used in moisture balance calculation.
Topic 4: Root Zone Water Working Storage (RZWWS)
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EPA
Comments on the Revised Draft Specification for
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WaterSense
Suggested Change (or Language): Add the word "gross" to paragraph 3.1.4:
"... .four days during the test period with 0.10 inches or greater of gross precipitation
However a better approach is described next:
Comment: The report from the University of Florida had numerous references to affect of rain on
test results. This new revised specification addressed some of the issues by changing the "Order
of Operations" and the requirement for at least 4 rain events. But there is room for additional
refinement in the test protocol. The soil moisture model that defines performance standard should
more accurately reflect real-time conditions.
Rationale: Rain is a bigger variable than ET. In the growing season ET rates will generally
fluctuate between 0.10" and 0.35". And changes from day to day normally do not vary more and
0.10." In most of the country annual rain exceeds annual ET. To date so much of the market focus
has been on ET and rain is often a secondary feature. I believe that we can look to California to
see the reason for this. A majority of Smart Controllers have been developed with the needs of the
southwest in mind. California gets very little rain and most rain comes in the "off" season, when
people turn off automatic watering.
Generally smart controllers earning better scores have features that better incorporate rain
measurements.
Rain that falls faster than the soil can absorb may run-off. Using the soil intake rate compared to
hourly rainfall rates is accepted science in quantifying effective rain. Many manufacturers use soil
intake rates as the means to limit effective rain.
The SWAT protocol is uses an older, less sophisticated, approach to quantifying effective rain:
"RN = 0.8 (R), in. - Allows for an arbitrary loss of 20% of the rainfall to non-uniformity and
The key word in this statement is "arbitrary". Why should the EPA use an arbitrary value in this test
when better science is available?
Suggested Change (or Language):
1) Change the Moisture Balance Spread Sheet calculations to an hourly time step. This means
rainfall, ET and irrigation would be accounted for on an hourly basis. The model is far more
accurate.
2) Eliminate RN = 0.8 (R), in. from the protocol and quantify Effective Rain based on the soil intake
rate by ignoring rain that falls faster than the soil can absorb.
a. Note: The SWAT Protocol already recognizes the soil intake rate to ignore run-off from
sprinklers, this should be applied to quantify effective rain.
Topic 6: Rain
runoff.
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F.PA
A
WaterSense
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
3) The SWAT protocol ignores the difference between Saturation and Field Capacity. This needs to
be changed. The following diagram is taken from the Irrigation Association's Best Management
Practices:
Figure l-i
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The Irrigation Association BMP states, "Field capacity is the amount of water retained in the soil
after ample irrigation or heavy rain when the rate of downward movement due to gravity has
substantially decreased, usually one to three days after soil saturation."
Central Irrigation Control Systems and Smarter Smart Controllers recognize this fact and quantify
the excess water to delay irrigation events. Excess soil moisture storage should be available to
store rainfall but not irrigation. The additional water savings can be significant. I not only have
science to back up this principle but years of experience utilizing this principle in Smart Control
products.
Topic 7: "Mode" Requirements
Comment: The capability table in Section 4.0 Supplemental Capability Requirements can be
simplified by eliminating the two columns labeled:
"Required In Smart Mode"
"Required In Standard Mode"
Rationale: Capability 4.2 and 4.3 should be required in Smart mode. Section 4.7 clearly describes
the performance requirements. Having the two columns to differentiate between Smart Mode and
Standard Mode does not add clarity.
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May 19, 2011
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Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
Suggested Change (or Language): Eliminate the columns labeled "Required in Smart Mode" &
"Required in Standard Mode".
Topic 8: "Rain Sensor"
Comment: The capability table in Section 4.4 requires the input from a "Rain Sensor. A tipping
bucket rain gauge should be recognized as a "rain Sensor".
Rationale: Rain input to a Smart Controller may come from a variety of sources not just a
traditional "Rain Sensor" often called a "Rain Shut-off Device"
Suggested Change (or Language): Add tipping bucket rain gauge to section 4.4 to read:
4.4 The controller shall either include a rain sensor or be capable of interfacing with a rain
sensor or tipping bucket rain gauge and shall have a means for indicating to the user when
the rain event sensor has suspended irrigation.
Topic 9: Prohibited Watering
Comment: Paragraph 4.6.3 states:
"The ability to set irrigation runtimes to avoid watering during a prohibited time of day (e.g.,
irrigation will not occur between 9 a.m. and 9 p.m.)"
Why is this requirement? Are you looking for a new feature? I hope not.
Rationale: This can already be done with any controller.
A limited number of advanced control systems have a blackout period. This type of feature adds
complexity. Plus most Smart controllers do not have a blackout window.
Suggested Change (or Language):
1) Eliminate the language.
And
2) Add a requirement to the test that would not recognize any watering occurring between
9:00 am and 9:00 pm. (Similar to section 3.1.1 that excludes any watering less than 3
minutes.)
Topic 10: Manual Watering
Comment: Paragraph 4.8 states:
F.PA
*
WaterSense
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May 19, 2011
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EPA
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
"The controller shall be capable of allowing for a manual operation troubleshooting test
cycle. The window for manual operation shall be limited to two hours, and the controller
shall automatically return to default mode, even if the switch is still positioned for manual
operation."
This is not SMART.
Rationale: Whoever added this feature has not spent even a week working in the field with
irrigation systems. This is not needed, it will only create problems. Every controller has manual
station control. If the user makes a mistake and leaves it in Manual Mode water will be saved
because the clock will not activate a valve automatically.
Suggested Change (or Language): Eliminate paragraph 4.8
Comment: Section 3.1.3 states:
" ...The Root Zone Working Water Storage (RZWWS), must be programmed as full at
the beginning of the test.
I agree with change, but there still an inherent weakness in the starting point. The problem is
related to the time of day when the test starts and when the smart controller receives or calculates
ET and if rain occurs on the first day.
Rationale: Some controllers work with daily ET and others calculate ET on an hourly basis. Those
that receive weather information from remote sites may be updated hourly or daily.
Rain and ET occur in real time. The ASCE standardized ET equation recommends an hourly ET
calculation. Rainfall is typically measured on an hourly basis.
Test results could vary based on the time of day the test started depending on the ET and rainfall
values occurring during the day.
Suggested Change (or Language): There are several options EPA could consider to resolve this
issue:
1) Implementing moisture balance calculations on an hourly time step would resolve this issue
very easily.
OR
2) Allowing the Licensed Certificating Body to adjust rainfall or ET values on the first day.
OR
3) See that testing begins early in the morning.
Topic 12: Testing Location
Topic 11: Full Root Zone
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Comments on the Revised Draft Specification for
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WaterSense
Comment: The Licensed Certificating Body should publish testing locations. The manufacturer
should be able to choose the testing location.
Rationale: Smart Control systems that use central weather stations as a basis for the ET
calculations transmit data to remote sites may not have available weather stations or
communication infrastructure to any location in the United States.
Suggested Change (or Language): The Licensed Certificating Body shall publish testing
locations. The manufacturer shall be able to choose the testing location.
Comment: Section 3.0 Performance Criteria - The first introductory paragraph states:
"...tested in accordance with the most recent version of the Smart Water Application
Technologies (SWAT) test protocol for climatologically based controllers..."
Because the SWAT test protocol is incorporated into the testing process, I recommend the EPA
review and approve changes to the SWAT test protocol.
In the "Summary of Major Changes" section 3.1 there is several recommended changes to the
SWAT protocol. I recommend the EPA review and approve the changes when implemented.
Rationale: Leaving the language as it stands leaves the EPA open to the risk that the Irrigation
Association could modify the SWAT test protocol without EPA approval or knowledge.
Suggested Change (or Language): Add "EPA approved" to the language:
"...tested in accordance with the most recent EPA Approved version of the Smart Water
Application Technologies (SWAT) test protocol for climatologically based controllers..."
Topic 13: SWAT Protocol
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A
WaterSense
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
Commenter: Brian Lennon
Affiliation: IRROMETER Co., Inc.
Comment Date: March 21, 2011
Please accept the comments attached.
Brian Lennon
Director of Sales
Office (951) 689 1701
Fax (951) 689 3706
Cell (951)258 2988
www. i rro m ete r, co m
Template for Public Comment Submission on WaterSense Documents
Commenter Name: Tom Penning/Brian Lennon
Commenter Affiliation: IRROMETER Co., Inc.
Date of Comment Submission: March 14, 2011
Topic: 2.0 Summary of Criteria
Comment: Irrigation excess of only 5% is too low.
Rationale: The 5% excess limitation is less than the normal leaching requirement
practiced for salinity management of 10%.
Suggested Change (or Language): Change the zone excess criteria to 10% here as well
as in 3.2.2.
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Comments on the Revised Draft Specification for
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WaterSense
Topic: Section 3.1.1 Minimum Runtimes
Comment: Short duration run times of 3 minutes or less should not be excluded from
the calculations.
Rationale: Such short duration run times are very realistic for steep slope and fine
textured soil applications. While the University of Florida research indicates that longer
run times may be realistic for purposes of the certification testing, it may send a
message to users of the equipment not to schedule short run times in practice. With the
primary intent of this program for residential and small commercial applications, it must
be realized that such small systems do not have long pipe runs and often do not
necessitate long run times for hydraulic considerations.
Suggested Change (or Language): Eliminate this short duration run time requirement.
Topic: 5.2 Add-On Devices
5.3 Plug-in Devices
Appendix A, 2.0 Add-On Devices
Comment: Requiring the testing and labeling of add-on or plug-in devices with every
specific model of controller is too prescriptive. This will inhibit innovation, and drive up
the cost of the device for manufacturers and ultimately consumers.
Rationale: Irrigation controllers are typically designed in "platforms" or model groups
which share the same basic infrastructure. New iterations of the same platform are
introduced frequently to allow for cosmetic changes, variations in station count, market
specific brands, etc.
Functionally these model groups have the same capabilities and their compatibility with
add-on or plug-in devices remains unchanged because the manufacturers wants to
manage costs and ensure compatibility with their own ancillary devices.
Add-on devices such as rain, flow, and soil moisture sensors have been used in the
industry for years and have a proven track record in testing. These devices are universal
in nature and require minimal controller capabilities to function.
These add-on or plug-in devices could be tested with a representative sample from each
controller model group since the outcome would be consistent across the controller
capability set. The controller manufacturer would benefit from consolidated testing
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Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
efforts. This would also reduce costs and inventory burdens for the retailer and reduce
confusion for the consumer.
The controller manufacturer can provide labeling on their packaging that serves to
identify what type of add-on or plug-in interface is compatible with their product
platforms. The packaging for the add-on device can be labeled to match up with platform
types. For example the controller could be labeled to indicate that it is "compatible with
dry contact type switch closure devices, or compatible with common interrupt type add-
on devices". The add-on device can be labeled that it was tested with certain controller
model groups that use the appropriate interface capability.
Suggested Change (or Language): Require that the controller manufacturer
identifies and displays a interface capability based on model groups or "platforms"
in order to allow integration of add-on or plug-in devices.
Suggested language: The add-on device is not required to be packaged with the base
controller(s) that it was tested with to meet the requirements of this specification. However, the
product documentation for the add-on device must list which controller model group(s) the device
has been tested with and the interface capabilities necessary to perform as tested. The controller
manufacturer must also provide a designation on the controller packaging to indicate its model
group and interface capabilities required to ensure compatibility with the add-on device. The
documentation must also contain a statement to the effect that the device is only WaterSense
labeled when used in combination with a controller identified as belonging to the same model
group as tested and labeled.
Example: The Acme Rain Switch is a dry contact type switch closure device. It has a WaterSense
label only when used in combination with the following controllers: Coyote model groups A, C, F,-
Yosemite model groups #1, # 7S.
Topic: 8.0 Definitions, Add-on device
Comment: Such add-on devices may interface with a controller through a common wire
connection or as a switch input to a defined auxiliary input connection (sensor port).
Rationale: Depending on an individual controller's capabilities, it may be better suited
to interface as a sensor input rather than as a common interrupt device.
Suggested Change (or Language): For purposes of this specification, add-on devices are
defined as those that communicate with the standard controller through a common wire connection
or interface with a controller through a defined sensor input connection.
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Comments on the Revised Draft Specification for
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WaterSense
Topic: Draft Supplemental Guidance for WaterSense® Certification and Labeling
of Weather-Based Irrigation Controllers, Section 3.6.2 Product retesting
Comment: Random testing every year is not realistic for a manufacturer with a small
number of applicable devices.
Rationale: Many manufacturers of such equipment may only offer a relative few items
applicable for certification. With fewer than five applicable devices some products will
have been tested multiple times within the five year cycle
Suggested Change (or Language): Require a random testing cycle relative to the
number of products a manufacturer offers, for example:
Less than five products offered -one test in five years.
Six to twelve products offered - random testing every other year.
Thirteen or more products offered- annual random testing of one product.
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Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
Commenter: Ben Silverman
Affiliation: Rain Bird Corporation
Comment Date: March 21, 2011
Please find Rain Bird's comments on the current draft of the WBIC specification attached.
Ben Silverman
Director, Consumer Products Division
Rain Bird Corporation
6119 E. Southpoint Road
Tucson, AZ 85715
520-741-6159 work
bsilverman@rainbird.com
Template for Public Comment Submission on WaterSense Documents
Commenter Name: Ben Silverman
Commenter Affiliation: Rain Bird Corporation
Date of Comment Submission: March 21, 2011
Topic:
Irrigation Adequacy and Excess (Sections 2.0 and 3.2)
Comment:
We agree that irrigation adequacy should be greater than or equal to 80% for each zone.
We strongly feel that irrigation excess should be less than or equal to 5% for the
average of all zones, the measure our industry has been working with for years.
Rationale:
Irrigation Excess is a measure to minimize excess or wasted water. The change in the
current WaterSense Draft Specification for Weather-Based Irrigation Controllers to limit
excess to 5% on each zone instead of 5% of the average of the six zones will adversely
affect the scope of the WaterSense program and the ability of labeled controllers to save
the most water. The SWAT test is the basis for the WaterSense specification and has
been the reference test for Rain Bird and other manufacturers for many years. Our
industry has worked with, designed to, and invested millions of dollars to develop
products based on the expectation that excess would be measured as the average of the
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Comments on the Revised Draft Specification for
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six SWAT zones. Changing this measure now will inhibit or prevent some very good
products from earning the label, succeeding in the market and thereby saving more
water.
Measuring irrigation excess by zone and setting this performance specification too
tightly may cause the Weather-Based Irrigation Controllers (WBIC) that have the
potential to save the most water, those likely to be understood and installed by
homeowners, to fail or inconsistently pass the test. The rationale for this belief is that
the ability for a WBIC to save water is based as much on the controller's ease-of-use and
understandability as on how accurately the controller calculates ET. Due to some
design constraints, Weather-Based Irrigation Controllers that are much easier for
average homeowners to understand generally will not perform as well on the
WaterSense test. However, they are easy to use, will appeal to the mass market, and as
a result they will be priced much lower than many other models of WBICs. If sold with
the WaterSense label, these products will get installed in more homes and save much,
much more water. Limiting excess to 5% on each zone instead of the average of the six
zones will not save much, if any, additional water, and meeting a 5% average excess is
very efficient compared with controllers in use today. Changing at this late date from
the traditional SWAT specification that has been used for many years to the tighter
WaterSense specification could very well prevent some of the WBIC products with the
highest potential to save water from earning the important WaterSense label.
WBICs with simple user-interfaces are very capable of measuring and predicting ET, so
the replenishment of water is accurate. However, with a simple user interface it is not
possible to calculate the Root Zone Working Water Storage (RZWWS) in the controller
logic and know when the root zone is "full". Generally, this is not a major issue, but at
certain times of year when ET is low, even a few minutes of excess watering on a spray
zone can lead to 5% excess. Despite providing the greatest opportunity to truly save
water, with the 5% excess per zone requirement, the most promising, easy-to-use, mass
market WBICs may be disqualified. More complex WBICs which calculate RZWWS are
often not understood by the user. This lack of understanding will not show up in the
WaterSense testing where the RZWWS variables are clearly defined, but it will result in
wasted water in the real world when the controller inputs are less well understood and
often programmed incorrectly. Programming confusion can lead to misapplication of
water and has been a major contributor to slow WBIC adoption.
In order to get the greatest breadth of product with the most potential to save significant
amounts of water, the EPA should keep the measurement of excess irrigation as the
average of the six zones, as has been the reporting criteria for many years.
Suggested Change (or Language):
2.0 (bullet 2) - "Irrigation excess average for all zones shall be..."
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Comments on the Revised Draft Specification for
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3.2.2 - "...shall be less than or equal to 5 percent for the average of all zones."
Topic:
Minimum Runtimes (Section 3.1.1)
Comment:
We agree that it is often, but not always, desirable to have runtimes that are 3 minutes or
greater, but any potential benefit of requiring a 3 minute minimum runtime is
overshadowed by the potential to cause wasted water and expensive product changes
for manufacturers.
Companies have already invested millions to put WBIC products on the market. Some
controllers are not currently designed with a 3 minute minimum watering time. Adding
this requirement at this late date will cause many manufacturers to add product
development cost. At the same time this requirement will save little or no additional
water.
In fact, adding this requirement could cause wasted water in some circumstances.
When a cycle/soak feature is used on clay soils with a slope, very short runtimes (less
than 3 minutes) are used to allow irrigation to soak into the soil without running off.
Rationale:
The minimal or zero incremental water savings do not justify adding this incremental
requirement.
Suggested Change (or Language):
Eliminate Section 3.1.1
Topic:
Root Zone Working Water Storage Starting Point (Section 3.1.3)
Comment:
The RZWWS starting point should be the mid-point of the root zone as has been the
case with prior SWAT testing. Many manufacturers have been working for years to the
SWAT protocol. Changing this requirement at this late date unfairly penalizes
manufacturers who believed they were doing the right thing by following a previously
prescribed definition.
Rationale:
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WaterSense
The RZWWS starting point may seem like an inconsequential choice for the
specification, but there are a few important reasons to start the test with RZWWS at the
midpoint of the root zone rather than with a full root zone.
First, if the controller comes out of the box set to anticipate a full root zone, users (who
experience has shown rarely follow manufacturer's instructions) must saturate the
irrigated area or they will think the product is not working when watering does not occur
soon enough. Such a saturation requirement, even if followed in practice by the user
would be a water wasting exercise. Also, if users skip this step, watering could be
significantly delayed and plants will suffer and may die. It is safer and more practical to
start the cycle with RZWWS water level at the mid-point. Based on real world practice,
many users will not follow start up instructions to saturate their soil at startup.
Second, as discussed in the prior comments on Irrigation Excess, starting with a full
root zone strongly favors WBICs that use more complex inputs over WBICs with simple
user interfaces. It is not a good policy to penalize easy to use products as these are the
WBICs that are most likely to benefit average homeowners. Additionally, manufacturers
have invested millions of dollars to develop many of the controllers on the market with
this starting calculation in mind. Changing this requirement at this late date, will cause
some manufacturers added development expense to compensate for an administrative
change to the test and will have no beneficial effect on saving water.
Third, we have heard of concerns about the difficulty of starting the test with the root
zone half full. Starting half full or completely full are each easy, clear and
understandable starting conditions for monitoring for the six standard SWAT zones.
Since, the RZWWS is a fixed number for each zone, starting the test tracking
spreadsheet with a full or half full RZWWS is equally easy.
Suggested Change (or Language):
Eliminate Section 3.1.3 or change the wording to start with all root zones 50% full of
water.
Topic:
Order of Operations (Section 3.1.5)
Comment:
We agree with this change.
Rationale:
WBICs should not be expected to predict rain events. This change prevents penalizing a
controller's test score for watering before a rain event occurs.
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May 19, 2011
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EPA
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
Suggested Change (or Language):
None
Topic:
Manual Operation (Section 4.8)
Comment:
A specific limit on the window of watering during manual operation is not needed as
long as the user must specify a specific time. There are occasions where watering a
zone manually for more than two hours is appropriate. However, having a timer-
controlled manual operating mode and reverting to default operations following manual
operation are important.
Rationale:
Adding the brand new 2-hour manual watering limit requirement at this late date will
require many manufacturers to redesign products and add development cost to meet a
specification that will not save additional water. We agree that manual watering should
be limited, just not to 2 hours. The feature of returning to smart operation following the
completion of a manual cycle is good practice and should be incorporated into WBICs.
Suggested Change (or Language):
Section 4.8 - Eliminate the words "to two hours".
Comment:
Rain Bird acknowledges the great work of the EPA to incorporate input from a wide
range of interested parties in the current revision of the Draft Specification for Weather
Based Irrigation Controllers. This new specification is significantly improved from the
prior specification. The EPA is to be commended on a job well done.
With this in mind, Rain Bird limited comment to what we consider VERY important
improvements to the specification. Rain Bird and other manufacturers have invested
millions of dollars in the development of a range of Weather Based Irrigation Controller
products designed to save considerable water for customers in the commercial,
professionally installed residential, and Do-lt-Yourself residential market segments.
These investments were made with the best available information: the SWAT testing
Topic:
General
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EPA
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
criteria. Rain Bird feels that the changes to the irrigation excess calculations, the 3
minute minimum runtime, and the RZWWS starting point in the current Draft WBIC
Specification will not lead to meaningful incremental water savings, but they will likely
have the effect of severely limiting the adoption of some very good products.
The specification changes we recommend will help manufacturers promote products
with the WaterSense label to meet the needs of all customer segments and help the
WaterSense program to accomplish much greater water savings.
Rationale:
Suggested Change (or Language):
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May 19, 2011
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EPA
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
Commenter: Eugene Carlson
Affiliation: CE Technical
Comment Date: March 21, 2011
Gentlemen:
Please find enclosed the re-submission of public comments in .PDF format
Eugene Carlson
CE Technical
Template for Public Comment Submission on WaterSense Documents
Commenter Name: Eugene Carlson
Commenter Affiliation: CE Technical, Fresno Ca.
Date of Comment Submission: Saturday, 19 March 2011
Topic: 1.0 Scope and Objective
Comment: ETc as mentioned in Section 1 is a little confusing and may not be appropriate to
stand alone controllers that will be tested under this protocol. To specify ETc as the basis for a
controller's water application calculation requires a very large amount of resources and may not
be applicable in a specific landscape environment. The use of ETo has much broader
application without much, if any, degradation in results.
Rationale: ETc is ETo modified by a crop coefficient K. Each crop has a different crop
coefficient. Present controllers mostly use a weather derived ETo and then base a water
schedule upon the length of watering duration for a specific landscape environment. The
adjustment for ETc from ETo is inherent in the protocol. In practicality, it is difficult to use ETc in
a landscape irrigation controller and it may produce no benefit.
Suggested Change (or Language): First sentence is OK.
"Using onsite sensors collecting ETo as a basis for approximating real time ETc; Using a
central weather station collecting ETo as a basis for ETc approximations and transmitting the
data to individual users from remote sites; or"
Last sentence is OK.
"Because rain sensors do not modify ETo or ETc but interrupt irrigation events based on
rainfall, they do not meet this onsite sensor requirement when used alone."
Topic: 3.0 Performance Criteria - 3.1.1 Minimum Runtimes
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May 19, 2011
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Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
Comment: Run times less than 3 minutes are very practical and may be more desirable than
any longer run time in some cases.
Rationale: "Cycle and soak" operation requiring runtimes less than 3 minutes may be used to
successfully compensate for slope. An algorithm in a controller can be developed using short
run times, less than 3 minutes, to compensate for or "interact" with rain events. It would be
desirable to base a minimum runtime on a value that can be used to resolve application
problems in the field.
Suggested Change (or Language): Eliminate the reference to minimum runtimes or make the
minimum runtime a more practical value such as 30 seconds.
Topic: 3.0 Performance Criteria - 3.1.2.1 and 3.1.2.1.1
Comment: ET" ought to be replaced with "ETo"
Rationale: Provide a well defined type of ET received from the reference weather station. "ET"
is very general and can be easily mistaken for other types of ET.
Suggested Change (or Language): Replace reference "ET" with "ETo".
Topic: 3.1.3 Root Zone Working Water Storage Starting Point
Comment: A RZWWS starting point ought to be placed at half full.
Rationale: A full RZWWS starting point does not allow a controller that must sense the
environmental conditions over a period of time to disallow irrigation, enough time to gather that
information. This could lead to an over irrigation condition of an otherwise fully qualified
controller.
Suggested Change (or Language): Change "must be programmed as full at the beginning of
the test." to "must be programmed as half full at the beginning of the test."
Topic: 3.1.4 Rainfall Requirement
Comment: The requirement of four days of rainfall greater than 0.1 inches is very restrictive in
some areas of the country.
Rationale: In dry climates there may long periods of little or rainfall, this may, in some cases,
extend the test for many months in dry climates when the rainfall events are under 0.1 inches.
Suggested Change (or Language): Maintain the general requirement but instead of using an
average of 0.1 inches of rainfall across the country use a minimum. This minimum would be
based upon the specific area of the country and a maximum expected time to test the unit. As
an example: The minimum rainfall would be 0.025 inches over four events and, with this
criteria, the test would be expected to last no more than 60 days.
F.PA
*
WaterSense
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May 19, 2011
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A
Comments on the Revised Draft Specification for
FPA
"WaterSense Weather-Based Irrigation Controllers
Topic: Performance Requirements - 3.2.2 Irrigation Excess
Comment: The requirement of all zones meeting the maximum of 5% excess may be
unrealistic in the light of the testing procedure.
Rationale: Very well qualified controllers are subject to a number of variables outside of the
test protocol and parameters that affect their ability to provide consistent outcomes within this
5% tolerance. A consideration ought to be build into this protocol to allow for these
unpredictable and uncontrolled variables.
Suggested Change (or Language): Maintain the overall efficiency at 5% but allow 1 or 2
zones to exceed the excess by some figure between 5% and 10%
Topic: 4.8 Manual Operation Window
Comment: The manual operation window is a little vague. The window of operation could be
better defined by specifying a starting point.
Rationale: Manual operation can start with a zone or with an overall operation, going through a
number of zones.
Suggested Change (or Language): The window of manual operation shall be limited to two
hours from its last operator input and, if no further input is received from the operator within the
last two hours, the controller shall automatically return to its default mode.
Topic: 5.1 General: Applies to Stand-Alone, Add-On Devices, and Plug-In Devices
Comment: The sentence instructing that the packaging materials "include an instruction
manual that lists the settings and specific parts used during the performance test as described
in Section 3.0." Do these also go to the end user or just to the testing facility?
Rationale: If they go only to the testing facility than it is appropriate and this document does
not need to be placed into the marketed packaging. If it also goes to the user it appears there is
little or no use to the user.
Suggested Change (or Language): Define to whom this literature is intended. If only to the
testing facility it is appropriate. If it goes to the user then it can be eliminated or a renaming
from "instruction manual" to " calibration certificate" would be appropriate if it must go to the
end user.
Topic: 5.1 General: Applies to Stand-Alone, Add-On Devices, and Plug-In Devices
Comment: The marking of the product package ought to mention, as part of its features, that it
can be used in "standard" mode. Many users do put their controllers in standard mode on
occasion. It allows testing of the controller without interrupting or corrupting any of the weather
based data to which they will return.
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EPA
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
Rationale: The marking on the package ought to be left up to the manufacturer in accordance
with good marketing practice. The "standard mode" of the controller is a very valuable feature
for the user and it maintains the integrity of the weather based operation and its programming.
Suggested Change (or Language): Remove the sentence "The product shall not be
packaged or marked to encourage operation of the controller in standard node.
Topic: 1.0 General
Comment: The sentence "The controller shall be programmed according to the list of settings
provided by the manufacturer in the product's instruction manual, as described in Section 5.1 of
this specification" is a little confusing
Rationale: The manufacturer's instruction manual will supply information on how the user is to
properly manipulate the controller's input, "the list of settings provided by the manufacturer" is
not definitive. Does it mean how to set the numbers or does it mean the value of the number
themselves? A list of settings and how to set them will be supplied to the testing facility but may
not be appropriate for inclusion in the manufacturer's instruction manual. It is appropriate the
user receive information on how to set the list of settings they derive but probably not the
settings themselves.
Suggested Change (or Language): Change to: "The controller shall be programmed
according to the list of settings provided by the manufacturer, as described in section 5.1 of this
specification
56
May 19, 2011
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*
Comments on the Revised Draft Specification for
Water Sense Weather-Based Irrigation Controllers
Commenter: LocTruong
Affiliation: WaterOptimizer, Inc.
Comment Date: March 21, 2011
Dear EPA,
Attached please find our comments to the Revised Draft Specification for Weather-Based Irrigation
Controllers date Jan. 20, 2011.
Thanks,
Loc T ruong
WATEROPTIMIZER, INC
TAMPA - JACKSONVILLE - SARASOTA - MIAMI - AUSTIN - DALLAS
4921 Memorial Highway, Suite 300, Tampa, FL 33634
V: 866-880-4030 F: 866-657-3665
http://WaterOptimizer.com
Water ptimizer inc
U.S. & Foreign Patents Pending
March 21, 2011
WaterSerise
United States Environmental Protection Agency (USEPA)
WaterSense
Office of Wastewater Management (4204M)
1200 Pennsylvania Avenue, N.W.
Washington, D.C. 20460
Re: Comments to Revised Draft Specification for Weather-Based Irrigation Controllers
Dear USEPA:
WaterOptimizer, Inc. is pleased to submit our comments to the latest Revised Draft
Specification for Weather-Based Irrigation Controllers dated January 20, 2011. Please
note that we had previously provided comments in January 2010 to the USEPA regarding
the proposed specifications. We question the need to provide supplemental capability
requirements as defined in Section 4.0. Our current comments are as follows in Italics:
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May 19, 2011
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Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
3.1.1
4.1
4.4
Minimum Runtimes: All runtimes (irrigation cycles) that occur during the test
period must be greater than three minutes in duration. Water applied during
irrigation events totaling three minutes or less shall be excluded from the
daily water balance calculation.
Comment: Was this intended to read "each zone must run for three (3) minutes"?
The controller shall be capable of preserving the contents of the irrigation
program settings and the correct calendar date and time when the power
source is lost and without relying on an external battery backup.
Comment: Many manufacturers have different means and methods of preserving
the contents of the irrigation program settings and date/time without the use of a
battery. For instance our controller, maintains both the irrigation program settings
locally in non-volatile memory and is also able to maintain these settings remotely
and can be sent to the controller after a power outage. While we meet this feature
requirement as it is worded and we agree that it is an important feature, we do not
feel that EPA should need to dictate a battery can or cannot be used (i.e. means
and methods) since it does not either promote or help conserve water in any
fashion. Please consider modifying the language to read as follows:
"The controller shall be capable of preserving the contents of the irrigation program
settings and the correct calendar date and time when the power source is lost and
power restored to the controller.
The controller shall either include a rain sensor or be capable of interfacing
with a rain sensor and shall have a means for indicating to the user when the
rain sensor has suspended irrigation.
Comment: What is the purpose of "having a means for "indicating to the user when
the rain sensor has suspended irrigation." How long should the message on the
controller appear for the user to see the message? Until the next irrigation event?
This feature appears to be a "nice-to-have" feature vs. a feature that is consistent
with water conservation mission of WaterSense. Please consider removing the
second part of this feature requirement such that it reads:
"The controller shall either include a rain sensor or be capable of interfacing with a
rain sensor to suspend irrigation."
The controller shall be capable of accommodating water restrictions as
follows:
4.6.1 Operating on a prescribed day(s)-of-week schedule (e.g., Monday-
Wednesday-Friday, Tuesday-Thursday-Saturday, any two days, any single
day, etc.).
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Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
4.6.2 Even day or odd day scheduling or any day interval between 2 and 7,
such as 3rd day, or every 4th, 5th, 6th, or 7th day interval.
4.6.3 The ability to set irrigation runtimes to avoid watering during a
prohibited time of day (e.g., irrigation will not occur between 9 a.m. and 9
p.m.)
4.6.4 Complete shutoff (e.g., on/off switch) to accommodate outdoor
irrigation prohibition restrictions.
Comment: We question if the above criteria actually provides water conservation or
smart irrigation. Many times, individuals who have restrictions like these, will
actually irrigate more. We would suggest that these criteria be left to each state or
local government entity to determine if they require this criteria.
4.8 The controller shall be capable of allowing for a manual operation
troubleshooting test cycle. The window for manual operation shall be limited
to two hours, and the controller shall automatically return to default mode,
even if the switch is still positioned for manual operation.
Comment: What is the purpose of limiting the manual operation of to two (2) hours?
If a system has 48 zones, that means if a user starts a manual cycle it would only
allow each zone to run 2.5 minutes, which is barely enough time to perform
maintenance checks on irrigation systems to see if broken heads are present or
check for adequate coverage of each zone. Please consider removing the time limit
in this requirement so that it reads as follows:
"The controller shall be capable of allowing for a manual operation troubleshooting
test cycle. The window for manual operation shall be user adjustable, and the
controller shall automatically return to default mode, even if the switch is still
positioned for manual operation".
If you have any questions or require additional information, please do not hesitate to
contact us at 866-880-4030.
WaterOptimizer, Inc.
Loc P. Truong
cc: File
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EPA
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
Commenter: Brian Vinchesi
Affiliation: Irrigation Association
Comment Date: March 21, 2011
Please accept these comments on behalf of Bran Vinchesi, chair of the Irrigation Association SWAT
Initiative.
John Farner
John R. Farner, Jr.
Federal Affairs Director
Irrigation Association
6540 Arlington Blvd
Falls Church, VA 22042-6638
T: 703.536.7080
F: 703.536.7019
iohn@irriaation.ora
www.irriaation.ora
Template for Public Comment Submission on WaterSense Documents
Date of Comment Submission: March 21, 2011
Topic: 1.0 Scope and Objectives - Data Sources and Use
Comment:
The revised specification has evolved significantly in its recognition that not all technologies
must rely on ET. However, the lA's SWAT Initiative believes that there is still too much
language throughout the specification invoking of the concept of ET within the scope.
Examples of this bias include "...this specification applies to controllers that create or modify
irrigation schedules based on evapotranspiration (ET) principles by...using onsite sensors as a
basis for calculating ET... using a central weather station as a basis for ETc," etc.
Commenter Name:
Brian Vinchesi
Commenter Affiliation:
Chair, Irrigation Association SWAT Initiative
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EPA
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
The revised draft of the weather-based irrigation controller specification currently places a bias
towards ET. The IA SWAT Initiative recommends using terms like "weather-based controllers
using a water balance approach" or something similarly generic in nature.
The EPA should recognize that ET is only used as the benchmark for determining the
effectiveness and performance of the controller in modeling landscapes' need for water. The
actual approaches or mechanisms manufacturers may develop should be left to their
discretion.
Rationale:
Controllers that use sources of weather data other than ET can perform at a very efficient level.
Suggested Change (or Language):
This specification applies to controllers that create or modify irrigation schedules that
adequately supply water without excess compared to a soil moisture balance that is calculated
using crop evapotranspiration rates based upon the ASCE Standardized Penman-Monteith
equation by:
• Storing historical crop water use data characteristics of the site and modifying these
data with an onsite sensor;
• Using onsite sensors as a basis for calculating real time plant water requirement
• Using a central weather station as a basis for determining plant water requirements
and transmitting the data to individual users from remote sites; or
• Using onsite weather, climate or environmental sensors.
Topic: 1.0 Scope and Objective - Station Count Requirement
The original concept of the SWAT testing protocol for "smart controllers" is for residential and
light commercial controllers. The application of the protocol for commercial controllers is valid;
however it is insufficient to adequately test products that have been developed to be centrally
controlled when connected to a computer system, therefore the IA SWAT Initiative believes that
this specification should not apply to central control systems. The controllers for the
WaterSense label should be able to function as stand alone units and that station count should
not exceed 48 stations.
Rationale:
Stating a maximum station count in the scope and objective section will define the intent of the
testing protocol.
Suggested Change (or Language):
This specification applies to controllers for use in residential or commercial settings, not to
exceed a maximum of 48 stations. Irrigation control systems that are often referred to as
"central control" systems are excluded for labeling.
Comment:
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EPA
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
Add to definitions section:
Irrigation Central Control System: A computerized system that manages the operation of
multiple controllers at one or more sites.
Topic: Performance Criteria - 3.1.1: Minimum Runtimes
Comment:
While the IA SWAT Initiative acknowledges that a minimum runtime may be desirable, three
minutes may not be the ideal minimum time for an irrigation cycle. The ideal runtime is based
upon the precipitation rate and the landscape characteristics, such as soil texture class, slope
and the water requirement of the vegetation. Smart controllers should have the flexibility to
calculate the runtime without (what appears to be) a random restriction that could disrupt an
appropriate irrigation strategy of "cycle and soak," which minimizes runoff.
Rationale:
A reasonable programming instruction (whether calculated by the individual or by the
algorithms within the controller) may lead to cycles of less than three minutes. The protocol as
written will exclude such run events from the moisture balance calculation.
Suggested Change:
Irrigation days shall have a minimum of three minutes of run time, either as a single application
or applied in a "cycle and soak" strategy, so that a minimum of three minutes of run time is
achieved and the soak time does not exceed 30 minutes between cycle starts.
Topic: Performance Criteria - 3.1.2: Missing Data from the Reference Weather Station
Comment:
The IA SWAT Initiative supports the proposed approach for dealing with missing data sources.
Rationale:
Suggested Change (or Language):
None
Topic: Performance Criteria - 3.1.3: Root Zone Working Water Storage Starting Point
Comment:
The Irrigation Association SWAT Initiative recognizes that assuming a full RZWWS will be
easier for licensed certifying bodies to implement. Selecting the first day for irrigation to
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EPA
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
happen would require the licensed certifying body to do some calculations depending on the
average ETC for the time of year, which could be any number of days. By starting with a full root
zone, depending on the time of year, there could be sufficient rainfall to refill some root zones,
thus leading to no irrigation events for those zones during the testing period.
The IA SWAT Initiative believes that beginning the RZWWS at half-full is a better option, as it
most accurately simulates real-world conditions (most root zone starting points are neither full
nor empty).
Rationale:
SWAT recognizes the reasons behind the change, but believes that every zone should have at
least one irrigation event occur during the testing period in order to qualify for product labeling.
Suggested Change (or Language):
All zones should have at least one irrigation event during the testing period.
Topic: Performance Criteria - 3.1.4: Rainfall Requirement
Comment:
The lA's SWAT Initiative generally supports this requirement. However the requirement may
lengthen the time the controllers will be in testing mode to meet the minimum ET and rainfall
requirements set forth by the specification.
Rationale:
N/A
Suggested Change (or Language):
None
Topic: Performance Criteria - 3.1.5: Order of Operations
Comment:
While the EPA recognizes correctly that the order of calculations do impact the scores, it is
worth noting that the neither approach can be considered perfect or erroneous, rather they
represent differing philosophies.
The approach taken in the SWAT protocol is to maximize the effectiveness of rainfall first.
Irrigation is meant to be supplemental, meaning that irrigation takes place when there is
insufficient precipitation to meet the water need of plants. As responsible irrigation managers
and stewards of water resources, the IA SWAT Initiative believes that the effectiveness of
rainfall should be maximized.
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EPA
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
The IA SWAT Initiative also believes that controllers tested under the revised draft
specification's order of operations will achieve a label easier than under the current SWAT
protocol, as the use of rainfall is minimized during the testing period.
The IA SWAT Initiative also believes that the use of rainwater harvesting should be used
wherever possible. The current SWAT protocol allows the controller to maximize this use of
rainwater.
Rationale:
Irrigation is meant to be supplemental, meaning that irrigation takes place when there is
insufficient precipitation to meet the water need of plants.
Suggested Change (or Language): Change the order of operations to count rainfall before
irrigation. [Consistent with the most recent SWAT protocol].
Topic: Supplemental Capability Requirements - 4.2
Comment:
The Irrigation Association SWAT Initiative recommends that the controller should either be
capable of independent, zone-specific programming, or storing a minimum of three different
programs to allow for separate schedules for zones with differing water needs.
Rationale:
The language used to determining the controller's capabilities is vague.
Suggested Change (or Language):
"The controller shall either be capable of independent, zone-specific programming, or storing a
minimum of three different programs to allow for separate schedules for zones with differing
water needs."
Topic: Supplemental Capability Requirements - 4.5
Comment:
There are no provisions within the current SWAT testing protocol to use a flow sensor/flow
meter to help initiate or alter an irrigation decision by the controller, such as low or excessive
flow rates, which would indicate a problem, or to measure a specific amount of water being
applied by a particular station. Since there are not any criteria within this draft protocol to
validate the usefulness of what a flow sensor/flow meter would do, the flow sensor/flow meter
requirement is beyond the scope of the protocol. The Irrigation Association SWAT Initiative
recommends the elimination of this requirement.
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EPA
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
Rationale:
There are currently no set definitions or protocols in place for determining the effectiveness of a
flow sensor/flow meter. The IA SWAT Initiative believes that the current testing protocol, with a
maximum 48 station count will achieve the goals set forth by the EPA's WaterSense program.
Suggested Change (or Language):
Remove the requirements set forth in section 4.5 and refer to station count in Section 1.0
Scope and Objectives.
Topic: Section 8.0 Definitions - Flow Sensor
Comment:
The Irrigation Association SWAT Initiative is recommending the removal of the flow sensor
requirement.
Rationale:
See previous comments re: use of flow sensor.
Suggested Change (or Language):
Remove the flow sensor definition.
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EPA
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
Commenter: Dan Nourian
Affiliation: National Diversified Sales, Inc.
Comment Date: March 21, 2011
Attached are comments related to January 20, 2011 WaterSense draft specification for Weather-Based
Irrigation Controllers.
Best Regards,
~Dan
NDS: We Put Water In Its Place
(Powered by Our Core Values: Teamwork • Communication • Results • Customer Focus • Integrity and Trust)
Dan Nourian
Director of R&D
National Diversified Sales, Inc.
Template for Public Comment Submission on WaterSense Documents
Commenter Name: Dan Nourian
Commenter Affiliation: NDS, Inc.
Date of Comment Submission: March 21, 2011
Topic:
Weather-Based Irrigation Controllers Draft Spec (January 20, 2011)
1.0 Scope and Objective
Comment:
Supported.
Rationale:
Suggested Change (or Language):
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EPA
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
Topic:
Weather-Based Irrigation Controllers Draft Spec (January 20, 2011)
2.0 Summary of Criteria
Comment:
See comments related to 3.0 Performance Criteria below.
Rationale:
Suggested Change (or Language):
Revise in response to section 3.0 Performance Criteria below.
Topic:
Weather-Based Irrigation Controllers Draft Spec (January 20, 2011)
3.0 Performance Criteria
• 3.1.1 Minimum Runtimes
• 3.1.3 Root Zone Working Water Storage Starting Point
• 3.2 Performance Requirements
Comment:
A combination of three "Testing Modification to the IA SWAT Protocol"
requirements are too restrictive:
1) A minimum runtime of three minutes;
2) Starting with a full root zone; and
3) Requiring "each zone" to pass adequacy and excess requirements.
Rationale:
• It will be a confusing requirement that undercuts the credibility of the
WaterSense specification if testing requires three minutes but actual field
applications do not. Actual field applications and conditions could exist
where slopes, plant species, and soil types require less than three minutes
of irrigation to prevent run-off. For water conservation, I'm confident the
EPA does not want to mandate a three minute minimum for testing that may
also impact longer field irrigation application when not necessary.
• There is no experiential or scientific data supporting the full RZWWS change
requirement to the SWAT protocol. A half-full RZWWS starting point is a
good starting point as actual conditions in the field will vary and the extreme
of either full or empty RZWWS in the field is likely unrealistic.
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Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
• Each zone and real life field landscape designs vary. The IA SWAT test
protocol mixes various soil types and is just one representation of many
potential landscape applications mixed together. The test is to rate the
performance of the controller as a whole ... not one specific zone or one
specific set of landscape parameters. Using an average of the six zones is a
better representation of performance when actual real life landscape
designs, irrigation method/components, and scheduling methods vary. Also,
EPA reported that many who commented recommended the average of six
zones be used to meet the performance criteria. These recommendations
are from professionals that have been in the irrigation industry for many
years and have a passion for water conservation and a desire to make smart
controllers and the WaterSense program successful.
Suggested Change (or Language):
• Revise 3.1.1 language to one minute minimum runtime.
• Remove 3.1.3 RZWSS section.
• Revise 3.2.1 and 3.2.2 to reflect "average irrigation adequacy" and "average
irrigation excess".
Topic:
Draft Supplemental Guidance for WaterSense Certification and Labeling of
Weather-Based Irrigation Controllers (January 20, 2011)
3.2.2.2 General Controller Testing Configuration
• Manufacturers must have no interaction with the device during testing ...
Comment:
Manufactures should be allowed some interaction with the device and certifying
body before start of testing and during testing.
• Interaction should be allowed to validate the controller was set-up and
programmed correctly as people can make mistakes or interpret instructions
differently than what was intended.
• Electronics and components (controller and test equipment) are not 100%
fail proof and could experience a failure at anytime.
• As smart controller technology is not an exact science and varying climates
and/or geographic conditions can produce differing results, manufacturers
Rationale:
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EPA
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
should be given the accessibility to fine tune irrigation schedules for the
specific test location prior to the formal start of testing.
• Manufacturers have invested a lot of time and resources in developing smart
controllers. It would be a waste of time and money for the manufacturer
and LCB if the controller was not set-up or programmed correctly or if an
electronic failure occurred during testing.
Suggested Change (or Language):
Revise 3.2.2.2 to allow the manufacturer the ability to:
• Check and accept set-up and programming parameters;
• Provide for a scheduling fine-tune period; and
• Review periodic test reports to monitor performance.
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EPA
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
Commenter: Kent Sovocool
Affiliation: Southern Nevada Water Authority
Comment Date: March 21, 2011
Hello,
Enclosed are SNWA's comments on EPA's WaterSense Revised Draft Specification for Weather-Based Irrigation
Controllers. If you have any questions or needs for clarification please contact me.
Sincerely,
Kent
(See attachedfile: public comment SNWA.doc)
Kent Sovocool
Senior Conservation Research Analyst
Southern Nevada Water Authority
Phone: 702-862-3738
E-mail: kent.sovocool(@,snwa.com
PHYSICAL ADDRESS
100 City Parkway, Suite 700
Las Vegas, NV 89106
CORRESPONDENCE ADDRESS
Southern Nevada Water Authority
P.O. Box 99956
Las Vegas, NV 89193-9956
The Southern Nevada Water Authority and the Las Vegas Valley Water District operate on a four-day work week.
Business Hours are Mondays - Thursdays 7 AM to 6 PM. Closed on Fridays - Sundays.
Template for Public Comment Submission on WaterSense Documents
Commenter Name: Kent Sovocool
Commenter Affiliation: Southern Nevada Water Authority
Date of Comment Submission: 3/21/2011
Topic: EPA's development of a WaterSense Specification for weather-based controllers
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EPA
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
Comment: SNWA is broadly supportive and appreciative of EPA's efforts to develop such a
specification.
Rationale: A specification is necessary to highlight to customers the value of smart controllers,
especially to the typical single-family customer who may not have an advanced understanding
of plant water requirements. Furthermore, such a specification will provide for a standardized
testing regime to assure customers and utilities that claims of performance are justified and
meaningful and that products can be differentiated as potentially more efficient than others.
Suggested Change (or Language):
Topic: Section 1.0 Scope and Objective
Comment: The revised specification has evolved significantly in its recognition that not all
technologies must rely on ET. That said, there is still too much invoking of the concept of ET
within the scope as written. Some examples of these include the phrases "This specification
applies to controllers that create or modify irrigation schedules based on evapotranspiration
(ET) principles by", "Using onsite sensors as a basis for calculating ET", "Using a central
weather station as a basis for ETc", etc. SNWA perceives the EPA is still implying a bias,
probably inadvertently, towards ET. EPA would be better served using more generic
terminology.
Rationale: The EPA should recognize that ET is only used as the benchmark for determining
the effectiveness and performance of the controller in modeling landscapes' need for water.
The actual approaches or mechanisms manufacturers may develop to approximate this should
be left wholly to manufacturers' creativity and discretion. Also, the only "or" option appears in
the third bullet possibly implying that the first two bullets are linked as requirements.
Suggested Change (or Language): Multiple - see below (any other references that imply
bias towards ET throughout the document should also be checked and resolved using more
neutral language):
". . based on evapotranspiration (ET) weather-based irrigation scheduling principles . . ."
"Storing historical crop evapotranspiration data on weather or irrigation needs and
characteristics of the site and modifying these data with an onsite sensor; or"
"Using onsite sensors as a basis for calculating real time Ete-irrigation need; or".
"Systems using a central remote weather station as a basis for ETe irrigation calculations and
the transmission ef data to individual users controllers from remote sites; or"
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Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
"Because rain sensors do not modify £Te-irri gat ion schedule programming but interrupt. .
Topic: Section 1.0 Scope and Objectives and throughout.
Comment: Though SNWA agrees the protocol should work for controllers sold for use in the
light commercial market, SNWA perceives that both the original SWAT protocol and this
specification are insufficient in testing scope to measure the performance characteristics of
central control systems.
Rationale: Central control systems and the irrigation configurations used with these are more
complex and diverse and the protocol developed by SWAT was not intended to evaluate these.
Suggested Change (or Language): Delete all references to central control throughout the
protocol. As a practical means of doing this, here in the scope SNWA suggests the following
language change :
"The specification applies to controllers capable of accommodating no more than 48
irrigation stations designed for use in residential and/or light commercial settings."
Topic: Section 3.1.1 Minimum Runtimes
Comment: Though the desire for a three minute runtime to more closely approximate real-
world conditions is understandable, whether three minutes is an ideal minimum runtime is
unknown.
Rationale: In clay soils, especially on slopes, it is reasonable to expect that three minutes may
result in runoff conditions with fixed pop-up sprays. Thus reasonable programming instruction
may lead to cycles of less than three minutes ideally. The protocol as written though would
exclude such run events from the moisture balance calculation.
Suggested Change (or Language): It is suggested EPA consider alternatively either a
shorter run time minimum or deleting the requirement.
Topic: Section 3.1.2 Missing Data
Comment: SNWA supports WaterSense's proposed approach for dealing with missing data
sources.
F.PA
*
WaterSense
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EPA
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
Rationale: Some type of standardized approach for dealing with missing data is needed for a
national protocol. While CIT typically relied upon the quality controls associated with CIMIS
this is probably unreasonable for a WaterSense Specification.
Suggested Change (or Language):
Topic: Section 3.1.3 Root Zone Working Water Storage (RZWWS)
Comment: SNWA recognizes that the change to assuming full RZWWS at the start of the test
will likely make it easier for the testing labs to practically implement the testing regime. That
stated, EPA must use caution in this approach.
Rationale: The revised assumption may cause some zones to never require irrigation during
the testing period. A test in which certain zones never required irrigation may lead to
erroneous conclusions and such a test would be non sequitur with the declared specification
intent. SNWA is especially concerned about this possibility with respect to zones 4 and 5.
A full initial RZWSS may also not be consistent with the practical background assumptions
manufacturers make with respect to the initial setup of smart controllers. If this is the case then
the testing over this timeframe may be a poor indicator of real performance over longer time
periods.
Suggested Change (or Language): At the least EPA should add the following statement, or
something similar, to section 3.0:
"At a minimum every virtual zone must cycle at least twice during the performance
period before a test may be deemed completed. The test must continue until this
threshold is achieved."
Beyond the above language which appears to resolve the first concern, the EPA is encouraged
to interview manufacturers regarding their assumptions that are made about initial conditions
before the decision to implement a full initial RZWWS assumption is finalized.
Topic: Section 3.1.5 Order or Operations
Comment: The order of operations change is among the more controversial aspects of the
revised specification. While the EPA recognizes correctly that the order of calculations do
impact the scores, it is worth noting that the neither approach should considered perfect nor
erroneous, rather they represent differing philosophies. SNWA can be supportive of either
approach but feels EPA's initial understanding of the dynamics of this issue could be lacking
and thus wanted to provide more clarity.
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Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
Rationale: SWAT's order of operations was designed to stress that the controller had to
manage to allow room for rainfall in the water balance. The University of Florida in contrast
observes that many controllers had "unfairly" negatively impacted scores because rainfall
would occur later in the day (by extension this means that approach is more tolerant of
overwatering). Ultimately SWAT was trying to push the envelope of the technology such that
manufactures are encouraged to consider probability of future rainfall occurrences. U. of
Florida was trying to determine if the calculation method was fair given the current state of
smart controller technology.
It is important to recognize that everything else being equal this change is expected to improve
the scores of controllers relative to SWAT testing.
Suggested Change (or Language):
Topic: Section 3.2 Performance Requirements
Comment: SNWA strongly supports the approach suggested in this draft that each zone must
make the performance criteria.
Rationale: In many parts of the country irrigation of turfgrass does not represent the majority
use for an irrigation system (ex. parts of the desert southwest). It is reasonable for both utilities
and customers to expect that a WaterSense labeled product be able to perform in this type of
environment as in any other.
Suggested Change (or Language):
Topic: Section 4.1 Supplemental Capabilities
Comment: It is unclear how long the controller must be capable of preserving the settings.
Rationale: This would appear to have to be defined if this is a specification.
Suggested Change (or Language): The language development should be straightforward
once EPA determines how long it wants to have the reserve power / program memory last.
Two-weeks seems like a reasonable minimum (if battery operated this would be per a new /
fully-charged battery).
Topic: Section 4.5 Supplemental Capabilities
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EPA
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
Comment: The suggested requirement that controllers with more than 48 stations have to be
able to include or be capable of interfacing with a sensor seems unsupportable.
Rationale: As mentioned, SNWA's preference is to limit the specification to those with no
more than 48 stations. If though EPA is committed to controllers with unlimited numbers of
stations, it should be clarified that the SNWA considers the sentence portion "shall either
include a flow sensor or be capable of interfacing with a flow sensor" to be vague to the point of
uselessness and insufficient to assure a flow sensor capable central control unit or, for that
matter, a quality central control product.
Suggested Change (or Language): Delete Section 4.5.
Topic: Section 4.6 Supplemental Capability Requirements
Comment: The SNWA appreciates EPA's attempts to assure WaterSense Weather-Based
Irrigation Controllers will work well practically in field installations. Especially noteworthy is
EPA's attempts to accommodate jurisdiction's varied watering restrictions as demonstrated in
this section.
Rationale: In practical terms, utilities and other jurisdictions have and will have watering
restrictions in response to possible water shortage conditions. EPA has made a strong effort to
try to assure these products will align with these by covering essentially all of the common
types of restrictions in this supplemental capabilities section. This is much more feasible than
expecting jurisdictions to implement special exemptions for those with smart controllers.
Suggested Change (or Language):
Topic: Section 5.2 Add-on Devices
Comment: This is one of the controversial aspects of the proposed specification. SNWA's
view on this depends on how EPA interprets the language. If the text means that the device
may be labeled as WaterSense and that the manufacturer need only declare with packaging
notes which product(s) the device was actually tested with using unbiased language then
SNWA can be supportive of the approach.
If the marking of the package creates the impression on the customer that the device is only a
WaterSense product when used with the devices WaterSense tested with then SNWA
considers this to essentially exclude manufacturers of such products practically from the
marketplace, slowing down significantly adoption of smart technology, and thus opposes this.
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EPA
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
Rationale: In the United States there are countless existing irrigation controllers in the
residential sector alone. So called add-on controllers that essentially make a traditional
controller "smart" at a fraction of the cost should be of interest to utilities as they may be more
readily adoptable by the property owner than the, on average, more expensive stand-alone
controllers. Thus it should be of interest to EPA to attempt to facilitate these into the
WaterSense program. Sections 5.1 and 5.2 suggest EPA recognizes the validity of this
argument and is making a good faith effort to attempt to resolve it and accommodate it, but that
EPA also has concerns with respect to these technologies.
SNWA's understanding of EPA's concerns with respect to add-ons is that just because an add-
on achieved a particular level of performance with a given base controller, that performance
level is in no way guaranteed or evenly necessarily proximal to that which might be achieved
with a different base controller. SNWA agrees that EPA's concerns have validity, but believes
that the approach outlined here will essentially be impractical to implement as a manufacturer
of add-ons may have to test with every possible base controller/add-on combination to assure
broad applicability of the label. The outcome will be that essentially these products will be
severely disadvantaged versus stand-alone controllers and more importantly that the adoption
of smart controllers will be seriously hampered by the language in the section. A different
approach is needed.
SNWA suggests that EPA was generally on the right track with development of the prospective
outlined here, but that it needs further tuning to be practical and effective to facilitating
marketplace transformation. SWAT has never evaluated possible interactions between the
base controllers and tested add-on products, but in logically considering the issue, there are
three areas of capabilities of the base controller where interactions may cause significant
issues:
The number of programs a base controller has,
The number of stations a base controller has, and
The number of start times the controller has per irrigation station.
These three aspects delimit the fundamental way an add-on smart controller can be configured
to work with a base controller.
SNWA can foresee no other meaningful interactions (differing time increment capabilities could
create minor interactions, but these are deemed de minimis in overall performance measures).
So SNWA's following suggestion builds off these observations.
Suggested Change (or Language):
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EPA
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
"The add-on device is not required to be packaged with base controller(s) that it was tested
with to meet the requirements of this specification. However the product must include
documentation on the outside packaging stating the base controller the add-on device
was tested with and the number of programs, stations and start times per station of said
baseline controller. The language must be as follows:
"This is an add-on type of WaterSense Weather-based Irrigation Controller that was
tested with a
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EPA
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
Commenter: Chris Brown
Affiliation: California Urban Water Conservation Council
Comment Date: March 22, 2011
Attached please find my comments on the WBIC spec. I have recieved a request by a Board
member that the Council be given two weeks to gather a consensus position which can be made
on behalf of the entire organization. This request is made due to the fact that the Council was left
off the immediate notifaction of the comment process and workshop opportunity, despite being on
the EPA's contact list, and that I had submitted comments in the first round.
If you see fit to give us the additional time, i commit to organizing a conference call meeting and
working up comments which will incorporate all of the ouncil's diverse points of view: Water
agencies, environmental advocacy organizations, and manufacturers/service providers.
thanks for your consideration.
*Chris Brown
*Executive Director
CUWCC
716 10th St. Suite 200
Sacramento, CA 95814
Template for Public Comment Submission on WaterSense Documents
Commenter Name: Chris Brown
Commenter Affiliation: Executive Director at CUWCC
Date of Comment Submission: 3/21/2011
Topic: Request for two weeks to submit a comment on behalf of CUWCC
Comment: Board members of the CUWCC, the largest standing statewide water
conservation organization in the U.S. are requesting an opportunity to submit comments
on behalf of the organization.
Rationale: the Executive Director and staff of the organization were not notified directly
of the workshop opportunities or comment period by the EPA. This was verified in a
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Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
conversation with EPA staff who indicated that there was no evidence of delivery of
notice to the CUWCC in the email program which was used to notify interested parties -
despite the fact that the Executive Director has been on the list for a number of years.
Suggested Change (or Language): This will be developed by a committee of the Board
which represents environmental organizations, water utilities, and manufacturers.
Topic: Test protocol
Comment: the SWAT test protocol is not robust enough for this labeling process as it is
a bench test of the cpu, and not a field test of the actual equipment in the field.
Rationale: EPA's own analysis has pointed out the problems with the lack of specificity
in the SWAT protocol, and
Suggested Change (or Language): Include a field test protocol of the irrigation
controller.
Topic: 20% savings over existing technology
Comment: the WBIC technology has not shown in field studies the consistent ability to
deliver the 20% water savings over existing technology that is the hallmark of the water
sense label.
Rationale: The largest field study of WBIC technology completed in 2009 in California
indicated that a significant portion of study sites saw water use increase with a WBIC.
This most likely had to do with operational, maintenance, and installation issues. The
Need for clear communication with potential end users that this technology will not deliver
water savings unless it is properly used is paramount.
Suggested Change (or Language): include package labeling that clearly indicates that
savings are not guaranteed, and that proper installation, operation and maintenance are
required for water savings to be realized.
Topic:
Comment:
Rationale:
Suggested Change (or Language):
F.PA
*
WaterSense
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A
Comments on the Revised Draft Specification for
FPA '
"WaterSense Weather-Based Irrigation Controllers
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EPA
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
Commenter: Derres Catalano
Affiliation: Hunter Industries
Comment Date: March 22, 2011
Hello, Stephanie. I hope you received my voicemail regarding the submission of our notes on the Water
Sense Specification draft. Please find Hunter's comments in the attached Word file.
Thank you and, again, I apologize for the late submission.
Derres Catalano
Product Manager, Controllers & Sensors
Hunter Industries
760-304-7278 office
760-521-3791 mobile
derres.catalano@hunterindustries.com
(See attached file: Hunter Industry Comments - Water Sense Draft Spec.docx)
Water Sense Draft Specification
• Section 2.0: "Irrigation Adequacy for each zone shall be greater than or equal to 80 percent
as specified in Section 3.0"
"Irrigation excess for each zone shall be less than or equal to 5 percent, as specified in
Section 3.0"
Comment: This requirement does not match SWAT protocol, which states that the average
of all station must be greater to or equal to 80 percent. It would be difficult to achieve 80%
or more efficiency and 5% or less excess.
• Section 3.1.4: "...there shall be at least four days during the test period with ,1 inches or
greater of precipitation...."
Comment: This may prove to be a difficult requirement to achieve, depending on the test
lab location and the time of year. The comment was made during the last conference call
that the manufacturer submitting the controller for testing has no input as to the location of
the test lab. If it is the middle of the summer, for example, and the test is performed in
Fresno, CA, there is a very low probability of passing this requirement.
• Section 3.1.5: "order of operations"
Comment: This requirement puts all ET sensors that do not measure rainfall at a
disadvantage.
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EPA
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
• Section 4.8: "The window for manual operation shall be limited to two hours, and the
controller shall automatically return to default mode, even if the switch is still positioned for
manual use."
Comment: This requirement would be very difficult to implement in controllers, specifically
the part about automatically returning to default mode. Currently Hunter's irrigation
controllers
(and most others) use a physical switch to program various functions. In order to comply
with this requirement irrigation controllers would require software based switch that could
be programmed with logic to automatically return to default mode after a set period of time.
Currently the"dial" is used my many manufacturers as the way to scroll through the different
programming functions. This requirement would add cost to the product, and would change
the design of current irrigation controllers significantly.
• Section 5.2 & 5.3 "...that the product documentation for the add-on (or plug-in) device must
list each base controller that the device was tested with the meet the requirements of the
specification and with which the manufacturer intends to be connected."
Comment: We support the current draft documentation. It makes complete sense that, in
order to enjoy the benefits of the WaterSense label, the product must be confirmed (through
actual testing) to meet the standards outlined in the test protocol with each controller.
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EPA
Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
Commenter: Mary-Ann Dickinson
Affiliation: Alliance for Water Efficiency
Comment Date: March 30, 2011
Dear Veronica and Stephanie:
Thank you once again for giving the Alliance for Water Efficiency an extension to file comments on
the Revised Draft WBIC Specification. Our board has now officially approved the attached set of
comments which we are hereby formally transmitting to you. If you need any further information
please let me know.
Mary Avuv
Mary Ann Dickinson
President and CEO
Alliance for Water Efficiency
300 W. Adams, Suite 601
Chicago, IL 60606
773-360-5100 Phone
866-730-A4WE Toll free
773-345-3636 Fax
www.a4we.org
Commenter Name: Mary Ann Dickinson, President and CEO
Commenter Affiliation: Alliance for Water Efficiency, Chicago, IL
Date of Comment Submission: Monday, March 21, 2011
Topic: Appropriateness of Labeling Weather-Based Irrigation Controllers at this Time
Comment: The Alliance for Water Efficiency (AWE) supports labeling of weather-based irrigation
controllers.
Rationale: AWE views weather-based control as an important technological improvement. In addition to
several studies regarding water savings, the Bonneville Power Administration has launched a two -year
study in 2010 to quantify expected energy savings due to reduced water distribution pumping as a result of
Public Comment Submission on
WaterSense® Revised Draft Specification for
Weather-Based Irrigation Controllers
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Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
the use of weather-based irrigation controllers. Establishing these product specifications at this time
positively influences technology development, and adds a key water-and energy-efficiency resource for
professionals and consumers alike.
Suggested Change (or Language): None.
Topic: Definition of Weather Based Irrigation Controller: Exclude Soil Moisture Sensors
Comment: In our previous comments submitted January 2010 we suggested clarification of the definition
of weather based irrigation controllers. Clarifying language in several sections of the January 2011 draft
specification accomplishes this goal. However, soil moisture sensors are not specifically excluded as we
suggested in January 2010.
Rationale: During our committee discussions we concluded that since soil moisture is not a component of
weather, language excluding soil moisture sensors is not needed. The language in section 1.0 excluding rain
sensors when used alone is sufficient clarification regarding weather related sensors.
Suggested Change (or Language): None.
Topic: 1.0 Narrowing Scope to Controllers that use ET
Comment: Unfortunately the introductory text of section 1.0 continues to narrow the scope to include
only devices that utilize ET.
Rationale: AWE believes it is in the interest of all concerned that the doors remain open for currently
unknown technology to earn the WaterSense label if it can be tested and proven to perform according to
this specification.
Suggested Change (or Language): 1.0 First paragraph, last sentence: This specification applies to
controllers that create or modify irrigation schedules reliably comparable to evapotranspiration (ET)
principles and methods such as: (followed by the bullet list in section 1.0 with "or" after each bullet)
Topic: 1.0 Application of Specification
Comment: The January 2011 draft specification partially addresses AWE concerns regarding application of
the specification as determined by number of zones by not specifying any number of zones. However, the
current text "this specification applies to controllers for use in residential or commercial settings" is open to
wide interpretation.
Rationale: The SWAT protocol "was developed to test products designed and sold for use at homes and
similar scale light commercial and institutional properties." The protocol "may not be suitable for products
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Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
using larger more demanding systems used at parks, golf courses, etc." It might make sense to include
SWAT scope language because it is consistent with the intent of the protocol on which this WaterSense
specification is based.
Suggested Change (or Language): Replace last sentence in 1.0 with: This specification applies to
controllers used at homes and similar scale light commercial and institutional properties. This specification
does not apply to central control systems.
Change stand-alone controller definition:
This includes a single controlling device (i.e. the irrigation controller) and all of the on-site sensors and/or
on-site receiver for direct climatological data without intermediary hardware/software.
Add to definitions section:
Central control system: A system of one or more controllers connected to a central processing unit or
other intermediary hardware/software interface between the controller and a weather station.
Topic: Section 4.0
Comment: The January 2010 AWE comments specifically pointed out that 4.2 and 4.4 of the
November 2009 draft specification were nearly identical. AWE also suggested performance based criteria
rather than restrict innovation due to prescribed criteria. AWE applauds most of the January 2011 draft
specification changes to 4.0 Supplemental Capability Requirements.
Rationale: The table format of the January 2011 draft specification is concise, readable and easy to
understand. The current language in 4.0 is for the most part performance based.
Suggested Change (or Language): See following comments regarding section 4.0
Topic: 4.3 Indicating to the User when the Controller is not Receiving a Signal or Local Sensor Input
Comment: The table titles for columns make it unclear whether the capability is required when the
controller interface indicates that the controller should be in smart/standard mode or whether the
capability is required when the controller is actually operating in smart/standard mode. For example if a
dial on a controller is set for smart mode on the controller and the weather sensor connection is lost, the
controller interface says that the controller is in smart mode, but the controller is operating in standard
mode. Adding an "X" to the smart mode column assures the capability for indicating to the user when the
controller is not receiving a signal or local sensor input regardless of interface settings.
Rationale: User notification that a device is not adjusting irrigation based on current weather conditions
due to an interruption in receiving signals and/or local sensor inputs is important for assuring water saving
potential.
Suggested Change (or Language): Add a second 'X' under "Required in Smart Mode".
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Comments on the Revised Draft Specification for
FPA
"WaterSense Weather-Based Irrigation Controllers
Topic: 4.5 Definition of Large Commercial Controller
Comment: Reinserting language regarding number of stations at this juncture, especially a large number
of stations such as 48, creates ambiguity regarding whether this specification might apply to central control
irrigation systems.
Rationale: While 1.0 defines the controller as stand-alone, it may be clearer to add language to exclude
central control systems from testing and labeling using this specification.
Suggested Change (or Language): See AWE March 2011 comments regarding 1.0 Application of
specification.
Topic: 4.5 Flow Sensor
Comment: Delete 4.5 in its entirety.
Rationale: 4.5 specifies a sensor unrelated to weather. In addition, while a flow sensor could very well
save water, there is no testing protocol within this specification nor does AWE know of a third party testing
protocol available or in development intended to assure flow sensor performance as there is with rain
sensors.
Suggested Change (or Language): Delete 4.5 in its entirety.
Topic: 4.8 Manual Operation Limited to Two Hours
Comment: 4.8 appears to be written in response to AWE January 2010 comments (and perhaps the
comment of others): "Manual operation - the controller shall allow for manual operation and
troubleshooting test cycle at the physical location of the controller installation"
The manual operation of the controller runs each zone and then defaults to the original program.
Total run time of all zones may be longer than two hours.
A troubleshooter test function runs each zone for a short prescribed amount of time to allow for
visual/field inspection of operation of the equipment in each zone.
Rationale: The language of 4.8 can be construed to confuse the manual operation and the
troubleshooting functions. The manual operation function can be used for troubleshooting therefore the
language could be simplified.
Suggested Change (or Language): The controller shall be capable of allowing for manual operation.
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Comments on the Revised Draft Specification for
Weather-Based Irrigation Controllers
WaterSense
The window for manual operation shall be limited, and the controller shall automatically return to default
mode, even if the switch is still positioned for manual operation.
Topic: 5.1 Packaging and Product Documentation Requirements: General
Comment: The Alliance for Water Efficiency (AWE) supports specifying that any controller sold with a
transformer or power supply align with external power supply requirements for ENERGY STAR labeled
product. As of December 31, 2010 ENERGY STAR discontinued labeling of power supplies and instead
requires that external power supplies for ENERGY STAR labeled products (such as computers, displays and
televisions) meet Level V as designated under the International Efficiency Marking Protocol.
Reference:
http://www.energystar.gov/ia/partners/prod_development/revisions/downloads/eps_eup_sunset_decision
July2010.pdf
Reference:
http://www.energystar.gov/ia/partners/prod_development/revisions/downloads/lnternational_Efficiency_
Marking_Protocol.pdf
Rationale: Water and energy efficiency should be addressed simultaneously in specifications whenever
possible.
Suggested Change (or Language): Any external power supply intended for use with the controller
shall be tested and labeled in accordance with the most recent version of ENERGY STAR specification for
end-use products using external power supplies.
Topic: 5.1 Packaging and Product Documentation Requirements: General
Comment: The product should be packaged or marked to encourage initial adjustments of the default
settings to maximize the potential water savings of smart controllers. An instruction or operator manual for
a WaterSense labeled weather based irrigation controller would align this specification with the
homeowner education requirement (5.1 Operating Manual) in the WaterSense Homes specification.
Rationale: Efficient irrigation programming is complex and complicated by many variables including the
plant water requirement, irrigation equipment and layout, routine maintenance, soil type, slope, sun
exposure to name a few. In a practical sense the defaults provided by Smart controller manufacturers must
cover a range of conditions. To maximize the potential water savings the initial settings need to be
adjustments or calibrated to the unique conditions of the site. It is unrealistic to expect that the initial
settings can hit the bull's-eye without initial fine tuning.
Suggested Change (or Language): The product packaging shall include an instruction manual that
lists how the default settings can be adjusted to apply more or less water to each zone if, after operating
for two weeks, the root zone is determined to be too wet or too dry.
87
May 19, 2011
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