EPA

Water Sense

Comments on the December 2014 WaterSense®
Draft Specification for Flushometer-Valve Water

Closets

April 23, 2015


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WaterSense

Comments on Draft Specification for
Flushometer-Valve Water Closets

Table of Contents

Sandra Cannon, U.S. Department of Energy Sustainable Acquisition Program	3

Doug Broad, Unaffiliated	4

Maribel Campos, ICC Evaluation Service, LLC	5

Jun Batoon, Hocheng Philippines Corporation	6

Thomas Schumann, ecoBETA U.S.A	7

Peter Langes, Sewer Smart	8

David Schwartzkopf, Willoughby Industries	9

Matt Sigler, Plumbing Manufacturers International	16

Shabbir Rawalpindiwala & Thomas Kramer, Kohler Company	24

John Bertrand, Moen Incorporated	30

Shirley Dewi, International Association of Plumbing and Mechanical Officials Research

and Testing (IAPMO R&T) 	31

Daniel Gleiberman, Sloan Valve Company	32

Peter DeMarco, The IAPMO Group	62

John Watson, Elkay	68

Daniel Gleiberman, Sloan Valve Company	71

Dave Bracciano, Tampa Bay Water	78

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April 23, 2015


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WaterSense

Comments on Draft Specification for
Flushometer-Valve Water Closets

Commenter: Sandra Cannon

Affiliation: U.S. Department of Energy Sustainable Acquisition Program
Comment Date: December 19, 2014

Email Text:

Dear WaterSense Team

We know you are aware of this but just want to confirm that all components of the
proposed WaterSense flushometer-valve toilet standard will meet commercial code
required in states with the strictest standards. Federal agencies in those states will be
required to meet the code in their state as well as being required to purchase
WaterSense labeled products. They would appreciate not having a conflict.

Appreciate your consideration—Sandra

Sandra Cannon, Technical Support

U.S. Department of Energy Sustainable Acquisition Program
Tel. 509-529-1535

Avoid Waste, Purchase Smart - EcoPurchasing

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April 23, 2015


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WaterSense

Comments on Draft Specification for
Flushometer-Valve Water Closets

Commenter: Doug Broad
Affiliation: Unaffiliated
Comment Date: December 20, 2014

Email Text:

Sirs:

The language of the standard contains reference standards to other publications which
are not freely available. ASME A112.19.2, for example, costs $110 to obtain. It is, in my
opinion, inappropriate to hide requirements of Federal law inside publications written by
private organizations that must be purchased. Therefore, it is imperative that either the
referenced publications be made freely available or the language should be changed
from a reference standard to an inclusive standard where all specifications are part of
the law itself.

This draft standard is not alone in this deficiency. Most building codes and federal
regulations contain reference standards that must be purchased. The net effect of this is
that most stakeholders are completely ignorant of everything in the laws other than the
specific requirements that are freely available. In this case, that means what is
unreferenced, such as the maximum flush rate. Every other referenced requirement is
opaque to most readers, except those with extremely deep pockets.

Regards,

Doug Broad

D. C. Broad, Jr. Architect
109 Bramblebush Ct
Rocky Mount, NC 27804
252-937-4691

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April 23, 2015


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WaterSense

Comments on Draft Specification for
Flushometer-Valve Water Closets

Commenter: Maribel Campos
Affiliation: ICC Evaluation Service, LLC
Comment Date: January 15, 2015

Email Text:

Hi Robbie,

When looking at the draft online, I noticed that you are referencing IAPMO/ANSI Z124.4
for plastic plumbing fixtures. This standard was discontinued when CSA harmonized the
B45.5 standard with all the Z124 plastic fixture standards. Please update your document
to correctly referenced that standard as CSA B45.5/IAPMO Z124. The current version is
2011.

Thanks.

Sincerely,

Maribel Campos

Director of Standards, ICC-ES PMG

ICC Evaluation Service, LLC
Western Regional Office
3060 Saturn Street, Suite 100
Brea, CA 92821
Tel: 562-699-0543 x3578
mcampos@icc-es.org

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April 23, 2015


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WaterSense

Comments on Draft Specification for
Flushometer-Valve Water Closets

Commenter: Jun Batoon

Affiliation: Hocheng Philippines Corporation

Comment Date: January 21, 2015

Email Text:

In the FVtoilet factsheet i noticed the phrase "WaterSense labeled models must pass
additional tests, such as the ability to flush a toilet seat cover." I think this is an
unintentional error that needs to be corrected since there is no toilet that can flush a seat
and cover. Thanks

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April 23, 2015


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WaterSense

Comments on Draft Specification for
Flushometer-Valve Water Closets

Commenter: Thomas Schumann
Affiliation: ecoBETA U S A
Comment Date: February 6, 2015

Email Text:

Dear Ladies & Gentlemen,
dear Mrs. McCarthy,

it is time for EPA WaterSense to seriously consider a Draft WaterSense Specification for
Component Water Conservation Devices- Toilet Valve.

Wth >40 million U.S. households living below the poverty line and/or depending on
government programs, an affordable water conservation device such as a proven toilet
valve (http://www.ecobeta.com/usa) for $25.00 makes not only economical and
environmental, but water sense.

Why replacing costly toilets when a simple component at a fraction of a toilet cost fixes
leaking and conserves water and money?

Thomas Schumann

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April 23, 2015


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WaterSense

Comments on Draft Specification for
Flushometer-Valve Water Closets

Commenter: Peter Langes
Affiliation: Sewer Smart

Comment Date: February 7, 2015 and February 12, 2015

Email Text (February 7, 2015):

There are no national plumbing codes or OSHA regulation requiring that the public be
alerted when and where a sewer back up overflow has occurred. Hundreds of gallons of
potable water is wasted in the clean up of sewer backup overflows. Increased response
time can effectively save water and reduce damage to the eco system and community
health.

	Flushometers are cost effective and sanitary

Oct thru Apr is the rain season and sewers back up more frequently and there is surface
water contamination the same months for Cold and Flu.

Email Text (February 12, 2015):

The one thing I am concerned with is maintaining volume to the Flushometers that
require 3/4" inlet per fixture. The line pressure is 45psi min. Some buildings will require
increasing pipe size for using flushometers. Water less Urinals are not selling good,
plumbers don't like those fixture because of contamination.

Plumbers are not trained for exposure to biohazards from bodily fluids in drain systems
and should be 29 cfr 1019 1030 (b)

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April 23, 2015


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WaterSense

Comments on Draft Specification for
Flushometer-Valve Water Closets

Commenter: David Schwartzkopf
Affiliation: Willoughby Industries, Inc.
Comment Date: February 26, 2015

Email Text:

In the January 15, 2015 webinar, I said that I would provide you with feedback
concerning the two families of flushometer toilets being split apart in the current draft
specification. Please find comments on that topic attached to this email. Note that we are
small-to-medium sized plumbing manufacturer, and well over 90% of all toilets that we
manufacture are blow-out type. We supply stainless steel plumbing fixtures to the
correctional market.

I also have other thoughts about other elements of the proposed specification. I will
attempt to respond further on those other items at a later time if time permits. However,
since I committed to this one in the webinar, I wanted to make sure I provided it.
Thankfully, the deadline for comments was extended to accommodate my slowness. ~

Thanks for hosting the webinar. It was my first opportunity to know of them and to
arrange participation.

David Schwartzkopf
Engineering Manager
Willoughby Industries, Inc.

5105 W. 78th Street
Indianapolis, IN 46268
Phone 317-875-0830

Email Attachment:

Topic: Application Scope of Standard for "Flushometer Valve Toilets"

Comment: The standard indicated that it is for "flushometer valve toilets." However, in
the webinar, it was revealed that blow-out toilets that are also "flushometer valve toilets"
will be excluded from the standard. (Slide from webinar is shown below.)

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April 23, 2015


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cr«

WaterSense

Comments on Draft Specification for
Flushometer-Valve Water Closets

•	The draft specification criteria for high-efficiency
flushometer-valve water closets applies to:

-	Water closet fixtures (e.g., bowls) receiving liquid and solid waste
and use water from a flushometer valve to convey the waste
through a trap seal into a gravity drainage system

-	Single- and dual-flush flushometer valves

-	Any other flushometer-valve-type technology meeting the
specification criteria

•	The draft specification does not apply to:

-	Tank-type Toilets

-	Blow-out Toilets

-	Retrofit or aftermarket devices or systems (e.g., flushometer-valve
handles)

rt 5/2015

During the webinar, when the query what made as to where the exclusion of blow-out
flushometer toilets was indicated in the specification, no one could find it. It is not there.
The word "blow" is nowhere used in the current draft of the standard, and it was only
used once in the presentation slides of the Jan. 15, 2015 webinar.

Rationale:

Industry standards to date have made no such distinction except in specifying a different
minimum operating pressure at which the performance tests specified in the standard
will be conducted.

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April 23, 2015


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cr«

WaterSense

Comments on Draft Specification for
Flushometer-Valve Water Closets

© The American Society of Mechanical Engineers
ASMEAll2.19.2-2013/CSA B45.1-13	© 2013 CSA Group

Table 5

Static test pressures for water closets, kPa (psi)

(See Clauses 7.1.1 to 7.1.4, 7.4.3, 7.4.5, and 9.6.2.)







Gravity
flush tank,
electro-hydraulic,
and flushometer
tank water closets

Flushometer valve water closets

Test

sequence
(Note 1)

Clause

Test

Siphonic
bowl

Blowout bowl

1

7.2

Trap seal depth
determination

140 (20)

240 (35)

310 (45)

2

7.3

Trap seal restoration

140 (20)

240 (35)

310 (45)

3

7.4

Water consumption

550 (80),
350 (50), and
140(20)

550 (80) and
240 (35)

550 (80) and
310 (45)

4

7.5

Granule and ball

140 (20)

240(35)

310(45)

5

7.6

Surface wash

140 (20)

240 (35)

310(45)

6

7.7

Mixed media

140 (20)

240(35)

310(45)

7

7.8

Drain line transport
characterization

140 (20)

240 (35)

310(45)

8

7.9

Overflow for gravity tanks

550 (80)

—

—

9

7.10

Waste extraction test

350 (50)

350 (50)

350 (50)

10

7.11

Consistent water level

140 (20),
410 (60), and
550 (80)

"

"

11

7.12

Fill Valve shut off integrity

140 (20), and
550 (80)

—

	

12

7.13*

Adjustability test with
original equipment

140 (20), and
550 (80)

—

	

13

7.14*

Adjustability test with
after-market seals

140 (20), and
550 (80)

—

	

Note: Highlighting and color lines added for clarity.

The current EPA WaterSense® track of producing two separate performance standards
for the same high-efficiency toilet consumption category is a bifurcation of current
standing industry performance standards. In addition, the current track of excluding
blow-out toilets from any WaterSense® performance standards will have the effect of
creating not only two separate categories in the high-efficiency toilet market, but will
actually make three categories of toilets.

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April 23, 2015


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WaterSense

Comments on Draft Specification for
Flushometer-Valve Water Closets

From One to Three Performance Standards Categories

Flushing Technology

Max.
HET
GPF

Performs

Before
EPA
WaterSense®

nee Requirements

After
EPA WaterSense®

Tank-type toilets

1.28

AMSE
A112.19.2/
CSA B45.1

WaterSense®
Specification for Tank-
Type Toilets

Blow out flushometer
toilets

N/A1

Siphonic flushometer
toilets

WaterSenses®
Specification for
Flushometer-Valve Water
Closets

1. No WaterSense® standard will be available; and therefore, no WaterSense® certification will be possible.
ASME/CSA harmonized standard will still apply. It is uncertain how the industry standard-making bodies will respond
to the gap created. They will likely move to incorporate the new WaterSense® flushometer water closet standard as
they did with the earlier WaterSense® standard for tank-type toilets .

This three-way segregation that includes two separate performance standards and
sidelines another category with no option of joining its counterparts in the WaterSense®
tent of products is very troubling to a manufacturer that manufacturers primarily specialty
toilets and toilets that are nearly all blow-out type.

Market preference will be given to toilet technologies that are WaterSense® certified.
LEED v4 already requires use of WaterSense® fixtures if they are available as a
prerequisite to any level of LEED certification. Manufacturers that currently make nearly
exclusively blow-out toilets would be placed in a very awkward situation and possibly
even an untenable one if excluded from the market category being defined by the
WaterSense® program.

Additionally, the "voluntary" status of WaterSense® requirements should be considered
carefully. Any new WaterSense® standards can be expected to be given the weight of
law. They already have.

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April 23, 2015


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WaterSense

Comments on Draft Specification for
Flushometer-Valve Water Closets

Excerpt 1 of 2 from "Georgia State Amendments to the International Plumbing

Code"

CHAPTER 3
GENERAL REGULATIONS

SECTION 301
GENERAL

*Add new Section 301.1.1 'Requirements for high efficiency plumbing fixtures' as follows:

301.1.1 Requirements for high efficiency plumbing fixtures. The installation of high
efficiency plumbing fixtures shall be required in all new construction.

(Effective July 1,2012)

http://www.dca. state. qa.us/development/coristrLictioncodes/proarams/document

High-efficiency plumbing fixtures are WaterSense® certified fixture by definition.

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April 23, 2015


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cr«

WaterSense

Comments on Draft Specification for
Flushometer-Valve Water Closets

Excerpt 2 of 2 from "Georgia State Amendments to the International Plumbing

Code"

*Revise the International Plumbing Code, 2006 Edition, as follows:

CHAPTER 2
DEFINITIONS

SECTION 202
GENERAL DEFINITIONS

*Add new definition of'High Efficiency Plumbing Fixtures and Fittings' to read as follows:

HIGH EFFICIENCY PLUMBING FIXTURES AND FITTINGS.

Dual (lush water closet. A dual flush water closet or toilet that the average llush volume of
two reduced flushes and one full flush does not exceed 1.28 gallons and is listed to the
WaterSense Tank-Type Hiuh Efficiency Toilet Specification.

Kitchen faucet or kitchen faucet replacement aerator. A kitchen faucet or kitchen faucet
replacement aerator that allows a flow of no more than 2.0 gallons of water per minute.

Lavatory faucet or lavatory faucet replacement aerator. A lavatory faucet or lavatory
faucet replacement aerator that allows a flow of no more than 1.5 gallons per minute at a
pressure of 60 pounds per square inch and is listed to the WaterSense High F.fficiency
Lavatory Faucet Specification.

Nonwater urinal. A urinal that is designed to receive and convey only liquid waste through
a trap seal into the gravity drainage system without the use of water for such function.

Single flush water closet. A single flush water closet or toilet, including gravity, pressure
assisted, and electro-hydraulic tank types, that the average Hush volume does not exceed 1.28
gallons and is listed to the WaterSense Tank-Type High Efficiency Toilet Specification.

Shower head. A shower head that allows a flow of no more than the average of 2.5 gallons
of water per minute at 60 pounds per square inch of pressure.

Urinal. A urinal and associated flush valve that uses no more than 0.5 gallons of water per
flush and is listed to the WaterSense Specification for Flushing Urinals.

(Effective July 1,2012)

*Add new definition of'Lavatory Faucet' to read as follows:

LAVATORY FAUCET. A faucet that discharges into a lavatory basin in a domestic or
commercial installation.

(Effective July 1,2012)

CiA International Plumbing Code Amendments 2012

http://www.dca.state.qa.us/development/constructioncodes/proarams/document

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April 23, 2015


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WaterSense

Comments on Draft Specification for
Flushometer-Valve Water Closets

The planned move to exclude one family of "flushometer valve toilets" from the
WaterSense® specification for "flushometer valve toilets" will at a minimum be confusing
and at maximum will inadvertently select winners and losers in the market place based
purely on a past choice driven by market demand to develop a slightly different in
technology.

Suggested Change (or Language):

Three possibilities (in order of preference based on my input):

1.	Place all toilets under the same standard as the ASME A112.19.2/CSA B45.1
(The way it is today. See my comments under a separate topic of "Extending
WaterSense® Performance Requirements BEYOND Existing and Well-
established Industry Plumbing Standards.")

2.	Place the blow-out toilets under the same specification as the gravity tank toilets.

3.	Treat both versions of flushometer water closets (siphon and blow-jet) the same.

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April 23, 2015


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WaterSense

Comments on Draft Specification for
Flushometer-Valve Water Closets

Commenter: Matt Sigler

Affiliation: Plumbing Manufacturers International (PMI)
Comment Date: March 4, 2015

Email Text:

To Whom It May Concern:

Attached are PMI's comments in regards to the EPA WaterSense Draft Specification for
Flushometer-Valve Water Closets. Please do not hesitate in contacting me if you have
any questions.

Regards,

Matt Sigler

Technical Director

Plumbing Manufacturers International
Cell: 847-217-7212
Email: msigler@safeplumbing.org
www.safeplumbing.org

Email Attachment:

See pages 17 through 23.

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April 23, 2015


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pmi

PLUMBING
MANUFACTURERS
INTERNATIONAL »

March 4, 2015

PMI Board of
Directors

EXECUTIVE
COMMITTEE
Fernando Fernandez,
TOTO USA

President

Paul Patton, Delta
Faucet Company

Vice-President

Peter Jahrling, Sloan
Valve Company

Treasurer

Tim Kilbane, Symmons
Industries

Immediate Past President

DIRECTORS AT LARGE
C.J. Lagan, American
Standard Brands

Scott McDonald,
Fluldmaster

Rick Reles,
Kohler Company

Nate Kogler,
Bradley Corporation

U.S. Environmental Protection Agency
Office of Water - WaterSense Program
1200 Pennsylvania Avenue, N.W.

Washington, D.C. 20460
watersense-products (Serg.com

RE: EPA WATERSENSE DRAFT SPECIFICATION FOR FLUSHOMETER-VALVE WATER CLOSETS

Dear EPA Office of Water:

Plumbing Manufacturers International (PMI) appreciates this opportunity to provide comments to the
U.S. Environmental Protection Agency (EPA) regarding the WaterSense Draft Specification for
Flushometer-Valve Water Closets. PMI is the international, U.S.-based trade association representing
90% of U. S. plumbing products sold in the United States. It has made the promotion of water safety
and efficiency a top priority and has included it in its mission statement1. PMI's members are industry
leaders in producing safe, reliable and innovative water efficient plumbing technologies and have
supported the WaterSense program since its inception. In addition, PMI and its member companies
are longstanding partners in EPA's WaterSense program.

The EPA held a teleconference and webinar on January 15, 2015, to discuss the proposed draft
specification. During the event, the need for this specification was not made clear. It should be
pointed out that requests have been made to the EPA at several ASME/CSA standards development
meetings for proof that the current consensus standards do not already provide water efficiency
requirements for flushometer-valve water closets that are comparable to what is being proposed in
the draft specification. Furthermore, evidence has been requested in regards to failures with
flushometer-valve water closets in the marketplace. As of the date of this letter, EPA has not provided
a response to either of the requests of the standard development committees.

If the EPA chooses to continue with the development of the proposed specification, PMI believes
the following issues should be resolved before publication:

Topic: The installation of high-efficiency plumbing fixtures and fittings in older commercial structures.
Comment: PMI believes that a statement should be added to the specification that provides guidance
to building owners, managers, or designers to have a qualified engineer determine if their specific
structure can accommodate the installation of high-efficiency plumbing fixtures and fittings.

Rationale: In WaterSense's supporting documentation it is noted that 28 percent of existing
flushometer- valve water closets that are installed in commercial structures have flush volumes that
exceed the current federal standards. Even though most newer commercial structures will not have
any issues with 1.28 gpf water closets, there are those structures with aging sanitary drainage systems
that could prove to be a maintenance nightmare, and therefore be a risk to public health/safety. PMI

1PMI's Mission: To promote the water efficiency, health, safety, quality and environmental sustainability of plumbing products
while maximizing consumer choice and value in a fair and open marketplace. To provide a forum for the exchange of information
and industry education. To represent openly the members' interests and advocate for sound environmental and public health
policies in the regulatory/legislative processes. To enhance the plumbing industry's growth and expansion.


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believes it is in the EPA's best interest to include the proposed statement to protect the WaterSense
brand.

Suggested Change/Action: The following text should be added to the draft specification factsheet and
other applicable documents on the website:

"For renovations and/or retrofits where the use of high-efficiency plumbing fixtures and fittings are
being considered, the structure should first be assessed by a qualified plumbing engineer to determine
if the sanitary system can accommodate such fixtures and fittings."

Topic: EPA has stated that based on the results of PERC I, drainline blockages are not of significant
concern at 1.28 gpf.

Comment: EPA should be cautious in basing their entire rationale for a maximum 1.28 gpf on PERC I.
PERC I began the conversation on "How low can we go?" PERC I did not conclude that all plumbing
systems can operate safely at 1.28 gpf, but instead cautioned against basing any decisions on the
results. The fact is that PERC has only begun to identify the impact of low flow fixtures and fittings in
the building environment and their impact on drainline carry.

Rationale: Though the PERC TC did make a recommendation to the EPA to expand their WaterSense
program to include commercial, flushometer-valve toilets, they also made a recommendation for the
EPA to carefully review and consider the results of PERC II as well2.

Suggested Change/Action: The proposed specification should not be finalized until after the results of
PERC II have been documented and reviewed by the EPA and plumbing industry.

Topic: In Section 1.0, the term "flushometer-valve-type technologies" is not defined.

Comment: This term is not clear to the end user, and therefore further clarification is necessary in
order for proper application and enforcement.

Rationale: The proposed text will assist the end user in not misinterpreting the scope of the draft
specification.

Suggested Change/Action: Revise the text of Section 1.0 as follows:

"Any other technology that serves the function of a flushometer-valve, falls within the scope ofASSE
1037/ASME A112.1037/CSA B125.37, and which meet these performance specifications." "Any other
flushomotor valve typo technologies that moot those performance specifications."

Topic: In Section 2.0 (Water Efficiency Criteria), there is not a minimum threshold for water
consumption.

Comment: Throughout the plumbing industry, it has been acknowledged that an "unknown yet to be
determined" minimum threshold exists where health/safety and performance would be negatively
impacted. In fact, it was indicated by the PERC TC that flush volumes between 1.28 gpf and 0.8 gpf
need to be further evaluated to better understand drainline performance2. Therefore, PMI strongly
recommends that the specification contain a minimum flush volume requirement.

Rationale: The PERC I study showed how flush volumes of 0.8 gpf resulted in chaotic and highly
inconsistent drainline transport results. This is a red flag that drainline efficacy is at risk using such
low flush volumes. We recommend that the specification call for a minimum flush volume
requirement of no less than 1.0 gpf for all flush levels, including the reduced flush on dual flush
models. Creating an incentive to design and market water closets or flushometer valves that flush
less than 1.0 gpf severely risks high profile drainline blockage failures in commercial buildings and the
success of the specification.

Suggested Change/Action: Revise the text of Section 2.1.1 as follows:

2Plumbing Efficiency Research Coalition, 2012. "FAQ's - Phase 1 Drainline Transport Study Report." Website:
http://www.plumbingefficiencvresearchcoalition.org/proiects/drainline-transport-of-solid-waste-in-buildings/faqs-drainline-

transport-study/


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"The manufacturer shall specify a rated flush volume ef for the flushometer valve or water closet
fixture, which must shall be equal to or loss than 1.28 gallons per flush (gpf) (4.8 liters per flush [Lpj])L
and not less than l.Ogpf (3.8 Lpf)."

Topic: In Section 2.1.3, the water efficiency requirement of 1.28 gpf maximum for dual-flush water
closets.

Comment: It is not a reasonable approach to only accept a maximum flush volume for dual-flush
water closets. The decision to use the 2 small flushes and 1 large flush for dual-flush water closets was
made several years ago with the concurrence of manufacturers, regulators, and non-government
organizations based on the same research now being quoted to dismiss this metric. Furthermore, the
behavioral studies that have been conducted on dual-flush water closets have been "limited in scope"
and "do not form the basis for such a significant change" as pointed out by the Alliance for Water
Efficiency (AWE) in their comments submitted to the EPA on June 5, 2014 in regards to the EPA's
WaterSense NOI to develop a draft specification for flushometer-valve water closets.

Rationale: The fact is that the 2:1 flush ratio was set as the reference for tank type WaterSense
ratings and legislation in California, Texas, Georgia, Florida, Colorado, New York City, Los Angeles as
well as the green plumbing codes. Considerable resources have gone into the design, marketing and
installation of dual-flush water closets to inform and promote this considerable water savings
innovation in the residential and commercial markets and cannot be disregarded. Work needs to
continue to communicate the appropriate use of dual-flush technologies and their inherent water
savings. A move to only consider the maximum flush volume will only work to hinder this innovation
from the marketplace. A redefinition of dual-flush performance that only recognizes the maximum
flush rate may push the small flush design of water closets with a 1.28 gpf maximum into an area of
questionable system performance. Without any solid evidence to change the performance aspect of
dual-flush water closets which would significantly disrupt the overall marketplace, the 2:1 flush ratio
for dual-flush water closets must be maintained.

Based on the information from the supporting document for the draft specification, Watersense
indicates that replacing older (pre-1992 EPACT averaging 3.5 gpf) water closets can save 5,400 gallons
per fixture annually as compared to only 780 gallons annually when a EPACT (1.6 gpf) fixture is
replaced. Elimination of the currently accepted and published dual flush option of 1.6 full flush/1.1
reduced flush may have a deleterious effect on the potential replacements of these pre-1992 EPACT
water closets. It has been established that these older water closets will yield 85% greater water
savings if they are replaced with Watersense labeled products. Because these older existing fixtures
all occur in commercial buildings with older infrastructure (drainlines and water supplies), the dual
flush option is necessary for these building owners and operators if Watersense is to achieve the 41
billion gallons of projected water savings. If dual flush as it is currently allowed in the Tank Type
specification and numerous plumbing codes and legislation previously cited is prohibited in this
specification, it will likely result in these older fixtures not being replaced at all.

Finally, PMI believes that the following studies: "Flush: Examining the Efficacy of Water
Conservation in Dual-Flush Toilets, 2010" and "Dual-flush Toilet Project, September 2002" should have
been considered in the development of the draft specification as they contradict the study referenced
within the EPA supporting statement. In the EPA supporting statement for this draft specification,
EPA indicates that "water savings are largely based on user behavior and can be influenced by lack of
user education, as well as design considerations (e.g. whether the reduced-flush mode requires the
user to pull up or push down on the handle)3." EPA cites only a single study conducted by the
University of Missouri which looked at only one type of design consideration. In the 2010 study,
which looked at a dual-flush flushometer valve installation in a commercial building in Portland, it was

3 Source: WaterSense® Draft Specification for Flushometer-Valve Water Closets Supporting Statement. Document can be found at:
http://www.epa.gov/watersense/docs/FVtoilets supportstat508.pdf


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indicated a 1.9 to 1 reduced flush to full flush ratio4. Additionally, in the study from 2002 sponsored
by the Canada Mortgage and Housing Corporation, it analyzed tank-type dual-flush water closets in
commercial settings such as municipal buildings, secondary schools, and institutional settings. From
all of these data points the study found that on average for these commercial settings the ratio of
reduced flushes to full flushes was 1.7 to l5. Therefore, WaterSense should consider these studies in
addition to the one cited in the supporting statement.

Suggested Change/Action: Revise the text of Section 2.1.3 as follows:

"The effective flush volume shall not exceed 1.28 gallons 14.8 liters) when evaluated in accordance
with the sampling plan contained in 10 CFR 429.30. For dual-flush toilets, the effective flush volume is
the average flush volume of two reduced flushes and one full flush. Flush volumes shall be tested in
accordance with ASME A112.19.2/CSA B45.1 and ASME A112.19.14. For flushomctcr valves with dual
flush capabilities, those water efficiency requirements shall apply to the full flush mode."

Topic: In Sections 2.1 and 3.3, IAPMO/ANSI Z124.4 Plastic Plumbing Fixtures is no longer the most
current standard for plastic plumbing fixtures.

Comment: The proposed specification should reference the harmonized standard: CSA B45.5/IAPMO
Z124 Plastic Plumbing Fixtures.

Rationale: The proposed changes bring the standard reference up to the most current version.
Suggested Change/Action: Revise the text in Sections 2.1 and 3.3 as follows:

•	"2.1 Water consumption shall be tested in accordance with the following ANSI standards as
applicable: ASME A112.19.2/CSA B45.1 Ceramic Plumbing Fixtures, ASME A112.19.3/CSA B45.4
Stainless Steel Plumbing Fixtures, or CSA B45.5/IAPMO Z124 IAPMO/ANSI Z124.4 Plastic Plumbing
Fixtures."

•	"3.3 Except as otherwise indicated in this specification, plastic water closet fixtures must conform
to applicable requirements in CSA B45.5/IAPMO Z124 IAPMO/ANSI Z124. <1 when tested with
representative flushometer valves from three different flushometer valve manufacturers that have
the same rated flush volume and that meet the requirements of Sections 2.0, 4.0, and 5.0."

Topic: In Section 3.0, the requirement for manufacturers of water closet fixtures to test their product
with a flushometer valve from three different manufacturers.

Comment: No evidence has been provided by the EPA to demonstrate that by using three different
manufacturer's flushometer valves that are certified to ASSE 1037/ASME A112.1037/CSA B125.37,
and therefore such valves should perform relatively the same, will improve performance and
efficiency beyond the testing requirements contained in the applicable consensus standards for water
closets. In fact, this additional testing requirement will do nothing more than unnecessarily increase
manufacturing costs by threefold.

Rationale: The proposed specification should only reference the applicable consensus standards for
water closets (ASME A112.19.2/CSA B45.1, ASME A112.19.3/CSA B45.4 or CSA B45.5/IAPMO Z124) to
ensure that necessary performance and efficiency requirements are met. PMI's recommendation will
also be consistent with the EPA's own opinion on consensus standards for water closets as stated in
the WaterSense Draft Specification for Flushometer-Valve Water Closets Supporting Statement (page
5): "These national standards have a proven record of ensuring a high level of performance and
durability in toilets, and will serve as a good foundation for a WaterSense specification for
flushometer-valve toilets."

Suggested Change/Action: Revise the text in Sections 3.1, 3.2 and 3.3 as follows:

4Source: Flush: Examining the Efficacy of Water Conservation in Dual-Flush Toilets, 2010, Prepared by Masaye Harrison, University
of Oregon at Portland, Department of Architecture. Study can be found at: http://www.map-testing.com/assets/files/201Q-
commercial dual-flush toilet studv-harrison.pdf

5Source: Dual-flush Toilet Project, Canada Mortgage and Housing Corporation, September 2002, Prepared by: Veritec Consulting
Inc. Study can be found at: http://www.cmhc-schl.gc.ca/odpub/pdf/63042.pdf?lang=en


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•	"3.1 Except as otherwise indicated in this specification, ceramic water closet fixtures must
conform to applicable requirements in ASME A112.19.2/CSA B45.1 when tested with
representative flushometer valves from three different fIushomctcr valve manufacturers that have
the same rated flush volume and that moot the requirements of Sections 2.0, <1.0, and 5.0."

•	"3.2 Except as otherwise indicated in this specification, stainless steel water closet fixtures must
conform to applicable requirements in ASME A112.19.3/CSA B45.4 when tested with
representative fI ushomctcr valves from three different fI ushomctcr valve manufacturers that have
the same rated flush volume and meet the requirements of Sections 2.0, <1.0, and 5.0."

•	"3.3 Except as otherwise indicated in this specification, plastic water closet fixtures must conform
to applicable requirements in CSA B45.5/IAPM0 Z124 IAPMO/ANSI Z124.4 when tested with
representative fI ushomctcr valves from three different fI ushomctcr valve manufacturers that have
the same rated flush volume and that meet the requirements of Sections 2.0, <1.0, and 5.0."

Topic: The new tri-harmonized ASSE 1037 standard.

Comment: The reference made to the new tri-harmonized ASSE 1037 standard in Sections 4.1 and 6.2
has an editorial error.

Rationale: The proposed change will correct the editorial error by adding an "A" before "112.1037."
Suggested Change/Action: Revise the text of Sections 4.1 and 6.2 as follows:

•	"4.1 Except as otherwise indicated in this specification, flushometer valves must conform to ASSE
1037/ASME A112.1037/CSA B125.37. [Note: WaterSense intends to require flushometer valves to
conform to ASSE 1037/ASME A112.1037/CSA B125.37 upon the standard's release.]"

•	"6.2 Flushometer valves shall be marked in accordance with requirements in ASSE 1037/ASME
A112.1037/CSA B125.37. [Note: WaterSense intends to require flushometer valves to conform to
ASSE 1037/ASME A112.1037/CSA B125.37 upon the standard's release.] Additional marking
requirements for flushometer valves are provided in Sections 6.2.1 and 6.2.2 below."

Topic: In Section 4.4, the requirements for interchangeability of replaceable or maintainable parts.
Comment: The intent of Section 4.4 is unclear with respect to EPA's intent.

Rationale: This proposed change will better clarify the intent of the section by aligning with the
clarification statement made by WaterSense in regards to requirements for interchangeability of
replaceable or maintainable parts in the WaterSense Specification for Flushing Urinals. The
clarification can be found within the third tab of the recently updated document, Compendium of
WaterSense Product Specification and Certification and Labeling Clarifications.

Suggested Change/Action: Revise the text of Section 4.4 as follows:

"The manufacturer, at a minimum, must provide product documentation that is clearly marked with
specific maintenance/replacement part instructions and identification of correct replacement parts
that should be used to ensure attest that the flushometer valve is designed such that replaceable or
maintainable parts (e.g., pistons, diaphragms) arc not intended to be interchangeable with parts that
would cause the device to will not exceed the rated flush volume specified in Section 2.1.1.

Topic: Flush performance criteria in Sections 5.1 and 5.2.

Comment: The text in these sections is not clear to the intent nor necessary for proper application
and enforcement of the draft specification.

Rationale: These sections are not necessary as the draft specification already requires testing to be
conducted in accordance with ASSE 1037/ASME A112.1037/CSA B125.37 for flushometer valves.
Suggested Change/Action: Delete the text of Sections 5.1 and 5.2 as follows:

"5.1 Individual flushometer valve samples with average water consumptions greater than their rated
flush volume shall be adjusted, if possible, to their rated flush volume prior to performance testing."
"5.2 Individual flushometer valve samples with average water consumptions loss than their rated flush
volume shall be performance tested at the measured volume and this volume shall be recorded on the
test report."

(Renumber remaining sections accordingly)


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Topic: In Section 5.3, the requirement for one unwaxed paper water closet seat cover to be used
during the waste extraction test for flushometer valves and water closet fixtures.

Comment: PMI is concerned with the proposed testing protocol being presented as it has not been
vetted through the applicable standard development process.

Rationale: The current testing requirements in ASME A112.19.2/CSA B45.1 are the standard for
performance for all water closets. No evidence has been provided by the EPA to show that such
requirements should be changed for the products covered by this specification.

Suggested Change/Action: Revise the text in Sections 5.3 through 5.3.3 as follows:

"5.3 Flush performance testing for flushometer valves and water closet fixtures shall be conducted in
accordance with the waste extraction test protocol provided in Section 7.10 of ASME A112.19.2/CSA
B45.1 and the additional test media and procedural steps for the waste extraction test protocol
provided in Sections 5.3.1, 5.3.2, and 5.3.3 below.

5.3.1	Test media used during the waste extraction test shall include one unwaxed paper water
closet scat cover. The scat cover must have a width of 14.0 ± 1.0 inches (356 ± 25 mm) and a length
of 16.5 ± 1.0 inches (<119 ± 25 mm). The scat cover shall be included in the test media specified in
Section 7.10.2 of ASME A112.19.2/CSA B45.1.

5.3.2	Following step "g" of the waste extraction test procedure in Section 7.10.3 of ASME
A112.19.2/CSA B45.1, the following procedural stop shall be applied."

5.3.2.1 Immediately after adding crumpled toilot paper, frooly drop ono unfolded, unwaxod
water closet seat cover onto the fixture water surface such that the center of the seat cover is
approximately at the center of the water surface.

5.3.3	After completion of the procedural step identified in Section 5.3.2.1 of this specification, the
test protocol shall continue with step "h" of the waste extraction test procedure in Section 7.10.3 of
ASME A112.19.2/CSA B45.1."

Topic: In Section 5.4, the requirement for one unwaxed paper water closet seat cover to be included
in the toilet paper test of ASME A112.19.14 for flushometer valves with dual-flush capabilities, in the
reduced-flush mode.

Comment: PMI is concerned with the proposed testing protocol being presented as it has not been
vetted through the applicable standard development process. EPA did not provide any evidence to
show that the testing requirements in ASME A112.19.14 are flawed.

Rationale: The proposed specification should remain consistent with the testing requirements found
in ASME A112.19.14, and the additional test media requirement should be deleted from the proposed
draft specification.

Suggested Change/Action: Revise the text in Sections 5.4 through 5.4.2.3 as follows:

"5.4 For flushometer valves with dual-flush capabilities, the following flush performance criteria shall

apply:

5.4.1	For the full-flush mode, the flush performance testing shall be conducted in accordance with
Section 5.3.

5.4.2	For the reduced-flush mode, flush performance testing shall be conducted in accordance with
Section 3.2.4 of ASME A112.19.14. Testing shall also include additional test media and revised
procedural steps for the toilet paper test protocol specified in Section 3.2.4 of ASME A112.19.14, as
provided in Sections 5.4.2.1, 5.4.2.2, and 5.4.2.3 below.

5.4.2.1	Test media used during the toilet paper test shall also include one unwaxed paper
water closet scat cover. The scat cover must have a width of 14.0 ± 1.0 inches (356 ± 25 mm)
and a length of 16.5 ± 1.0 inches (419 ± 25 mm).

5.4.2.2	Section 3.2.4.2 of ASME A112.19.14 shall be modified as follows:

"The four 2.0 to 3.0 inch (51 mm to 76 mm) balls of paper that comply with paragraphs
3.2.4.1.1 and 3.2.4.1.2 shall be dropped into the water directly above the well and shall be
allowed to wot out completely. Immediately after adding the balls of paper, freely drop one
unfolded, unwaxed water closet scat cover onto the fixture water surface such that the center
of the scat cover is approximately at the center of the water surface. Within five seconds of


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adding the scat cover, the bowl shall be flushed. This procedure shall be repeated until three
sets of data are obtained. Note whether any paper or scat cover are left in the bowl. Flush
again and collect any paper or scat cover that discharges from the outlet."

5.4.2.3 Section 3.2.4.3 ofASME A112.19.14 shall be modified as follows:

"No paper or scat cover shall remain in the well after each initial flush."

Topic: The product documentation requirements in Section 6.2.2.

Comment: In Section 6.2.2, the same requirement for product documentation is stated twice within
this section, and therefore is confusing to the end user.

Rationale: Section 6.2.2 provides redundant requirements. There is no need for the 2nd sentence of
Section 6.2.2 as the first sentence already states that manufacturers shall provide specific
maintenance/replacement part instructions and identification of correct replacement parts so that
the flushometer-valve will not exceed its rated flush volume.

Suggested Change/Action: Revise the text in Section 6.2.2 as follows:

"Product documentation shall be clearly marked with specific maintenance or replacement part
instructions and identification of correct replacement parts that should be used to ensure that the
device will not exceed its rated flush volume. Under no circumstances can manufacturers provide
maintenance instructions or advertise the use of any replacement parts that would cause the
flushometer valve to exceed its rated flush volume."

Topic: Missing definition from Section 9.0.

Comment: CSA standards are referenced throughout the draft specification.

Rationale: The proposed change is necessary in order to define all of the standard organizations

referenced throughout the draft specification.

Suggested Change/Action: The following text should be added to Section 9.0:

"CSA: Canadian Standards Association"

In closing, PMI continues to support the WaterSense voluntary efficiency program and encourages the
development of additional areas of certification based on potential efficiency gains, performance
criteria referencing consensus national standards and independent third party certification. We look
forward to continuing to work with EPA WaterSense in its future endeavors.

Matt Sigler
Technical Director

Plumbing Manufacturers International
Office 847-217-7212
msigler@safeplumbing.org

Sincerely,

Plumbing Manufacturers International | 1921 Rohlwing Road | UnitG | Rolling Meadows, IL 60008
Tel: 847-481-5500 - Visit us at www.safeplumbing.org


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WaterSense

Comments on Draft Specification for
Flushometer-Valve Water Closets

Commenter: Shabbir Rawalpindiwala; Thomas Kramer
Affiliation: Kohler Company
Comment Date: March 13, 2015

Email Attachment:

Kohler Co. 444 Highland Drive Kohler, Wisconsin 53044 920-457-4441 kohler.com

KOHLER.

March 13, 2015

U.S. Environmental Protection Agency
Office of Water - WaterSense Program
1200 Pennsylvania Avenue, N.W.

Washington, DC 20460
watersense-products@erq.org

RE: EPA WaterSense Draft Specification for Flushometer-Valve Water Closets
Dear EPA Office of Water:

As a WaterSense Partner, Kohler Company has made a commitment of working towards
sustainability, and has pledged to a philosophy of environmental, social, and economic
responsibility. We appreciate the opportunity to provide comments to the U.S.
Environmental Protection Agency (EPA) regarding the WaterSense Draft Specification
for Flushometer-Valve Water Closets, and would encourage EPA to carefully consider
these comments as they relate to further development of this specification.

Topic: General

Comment: Specification not needed

Rationale: It is with good intention that EPA has taken the lead and created the
WaterSense Draft Specification for Fiushometer Valve Toilets, as continued water
savings are important to our industry. Unfortunately however, little evidence has been
presented to the manufacturers or the ASME/CSA technical committees that has proven
a significant amount of water could be saved by instituting such a specification, and that
existing standards do not sufficiently address efficiency and performance requirements
EPA has proposed. EPA quoted the results of PERC I as justification for this
specification, though the PERC technical committee explicitly recommended that EPA
consider the results of PERC II before making a final decision on the requirements of
this specification.

24

April 23, 2015


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WaterSense

Comments on Draft Specification for
Flushometer-Valve Water Closets

Suggested Change (or Language): Kohler Company believes that more data is
required to justify the need for this specification, and should wait until the results of
PERC II are published before moving forward with this specification.

Topic: 1.0 Scope and Objective

Comment: Dual-flush flushometer valves should not be included in this specification
Rationale: Kohler Company has concerns with the inclusion of dual-flush flushometer
valves in this specification. While dual-flush flushometer valves have been available for
several years, they are still considered to be relatively new to the market, a fact that EPA
eludes to in the WaterSense Draft Specification for Flushometer-Valve Water Closets
Supporting Statement by acknowledging that "To date, water savings from dual-flush
flushometer-valve toilets has not been fully researched or documented." It is concerning
that we would move forward with requirements in a specification that does not yet have
adequate data supporting its efficiency.

While this specification will mandate that the rated flush volume of a dual-flush valve
must not exceed 1.28 GPF, EPA has failed to put flush volume requirements in place for
the reduced flush, which would serve as an additional assurance of efficiency.
Additionally, EPA has acknowledged that user behavior and familiarity is crucial to the
water efficiency of dual-flush products, however even with increased user knowledge,
inadvertent selection of the small flush for bulk waste removal could come at a cost of
catastrophic plumbing system failures. Further, because the water efficiency
requirements proposed in this specification are different than those which are found
within the WaterSense Specification for Tank-Type Toilets, we believe that EPA has
potentially created a situation where the varying requirements could be confusing to
building designers, product specifiers, and manufacturers - many of whom currently
advertise their 1.6/1.1 GPF dual-flush valves as HET products as their effective flush
volume does not exceed 1.28 GPF.

Suggested Change (or Language): Kohler Company recommends that EPA remove
reference to dual-flush valves from this specification, including Sections 2.1.3, and 5.4.

Topic: 1.0 Scope and Objective

Comment: "Other flushometer-valve-type technologies" must be defined
Rationale: While the definition of single and dual flush flushometer valves is intuitive,
"Other flushometer-valve-type technologies" is not.

Suggested Change (or Language): Kohler Company would recommend that EPA
either provide a definition for "other flushometer-valve-type technologies" that aligns with
the existing definitions found within the newly tri-harmonized ASSE 1037/ASME
A112.1037/CSA B125.37, or remove this covered equipment from this specification.

Topic: 2.0 Water Efficiency Criteria

25

April 23, 2015


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WaterSense

Comments on Draft Specification for
Flushometer-Valve Water Closets

Comment: 2.1 makes reference to an invalid standard
Rationale: Currently, Section 2.1 of the WaterSense Draft Specification for
Flushometer-Valve Water Closets references IAPMO/ANSI Z124.4 Plastic Plumbing
Fixtures. This standard was harmonized with CSA B45.5 in 2011 and is no longer
current.

Suggested Change (or Language): Kohler Company recommends that in Section 2.1
EPA reference CSA B45.5/IAPMO Z124 - Plastic Plumbing Fixtures.

Topic: 2.0 Water Efficiency Criteria

Comment: 2.1.1 does not indicate the minimum flush volume

Rationale: The EPA WaterSense program has, in part, been successful because it has
gone to great lengths to ensure that end users benefit from saving water while not
effecting the performance of the product. Kohler Company believes that EPA has set
aside that key metric while developing this specification by including the words "or less"
while describing the Water Efficiency Criteria in Section 2.1.1. At this time, the plumbing
industry has not determined what a safe low-end limit is for flushing performance beyond
that of the 1.28 GPF high-efficiency toilets on the market today. While we understand
that products may successfully meet the requirements set forth in Section 5.0 - Flush
Performance Criteria, that does not mean that a toilet that flushes less than 1.28 GPF
can safely be installed in all applications, not only risking performance but also
consumer confidence.

Suggested Change (or Language): Kohler Company recommends that EPA change
the language in Section 2.1.1 to read, "The manufacturer shall specify a rated flush
volume of the flushometer valve or water closet fixture to be equal to 1.28 gallons (4.8
liters) per flush." This will provide users with a 20 percent water savings, while
maintaining a performance requirement at a level the industry is confident will provide an
effective flush.

Topic: 2.0 Water Efficiency Criteria

Comment: 2.1.3 should have the same requirements as dual-flush tank-type toilets
Rationale: While Kohler Company is not in agreement EPA's inclusion of dual-flush
valves and fixtures in this specification, we believe that if dual-flush valve are included in
the specification the Water Efficiency Criteria must be in alignment with the requirements
found within the WaterSense Specification for Tank-Type Toilets.

Suggested Change (or Language): Kohler Company recommends that EPA change
the language in Section 2.1.3 to read, "For flushometer valves with dual-flush
capabilities, these water efficiency requirements shall apply to the effective flush volume.
The effective flush volume is the average flush volume of two reduced flushes and one
full flush."

Topic: 3.0 General Water Closet Fixture Requirements

26

April 23, 2015


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WaterSense

Comments on Draft Specification for
Flushometer-Valve Water Closets

Comment: No basis for requiring testing with multiple valves
Rationale: EPA has included in this specification a requirement to test water closets
with three different flushometer valves. While the intention of this requirement may be
worthy, no data has been provided by EPA as to why it is needed, only to state in their
supporting statement that this will "ensure consistent performance." We believe that this
requirement will add a significant amount of time and cost to testing these products,
while providing little benefit. The manufacturer is being forced to repeat a requirement
for the valve found in ASSE 1037 Pressurized Flushing Devices, and by nature is
already ensuring the consistent performance EPA is seeking. Further, this is a testing
requirement that exceeds well beyond the requirements that have been vetted and
agreed upon in the national consensus standards. Because no data related to
inconsistent performance has been included, Kohler Company would suggest that EPA
present this data to the appropriate ASME task group for consideration of the inclusion
of this requirement in the appropriate standards.

Suggested Change (or Language): Kohler Company recommends that EPA remove
the requirement for testing water closet fixtures with multiple flush valves throughout
Section 3.0 - General Water Closet Fixture Requirements.

Topic: 3.0 General Water Closet Fixture Requirements

Comment: 3.3 makes reference to an invalid standard
Rationale: Currently, Section 3.3 of the WaterSense Draft Specification for
Flushometer-Valve Water Closets references IAPMO/ANSI Z124.4 Plastic Plumbing
Fixtures. This standard was harmonized with CSA B45.5 in 2011 and is no longer
current.

Suggested Change (or Language): Kohler Company recommends that in Section 3.3
EPA reference CSA B45.5/IAPMO Z124 - Plastic Plumbing Fixtures.

Topic: 4.0 General Flushometer Valve Requirements
Comment: 4.1 requires editorial correction

Rationale: Currently, Section 4.1 of the WaterSense Draft Specification for
Flushometer-Valve Water Closets references ASSE 1037/ASME 112.1037/CSA
B125.37, which is incorrect.

Suggested Change (or Language): Kohler Company recommends that in Section 4.1
EPA reference ASSE 1037/ASME A112.1037/CSA B125.37.

Topic: 4.0 General Flushometer Valve Requirements

Comment: The intent of the words "must attest" in Section 4.4 is unclear
Rationale: These same words "must attest" have created controversy previously for
EPA in the WaterSense Specification for Flushing Urinals. Based on the clarification
that was published 1/24/2013 to help industry understand the requirement, Kohler

27

April 23, 2015


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WaterSense

Comments on Draft Specification for
Flushometer-Valve Water Closets

Company believes that this section is meant to deter the manufacturer from providing
the end customer with replacement parts or instructions on how to alter the flush volume
of a valve. We do not believe that EPA intends to require that manufacturers must have
physical differences within the valve body which would prevent parts from being
interchangeable, as such a requirement would be cost prohibitive for the producer in
today's manufacturing environment.

Suggested Change (or Language): Kohler Company recommends that EPA remove
Section 4.4. Based on the previous clarification for WaterSense Specification for
Flushing Urinals, we believe that the intent of this section is covered in Section 6.2.1.

Topic: 5.0 Flush Performance Criteria

Comment: No basis for requiring additional test media in Sections 5.3 and 5.4
Rationale: EPA has included in this specification a requirement to add additional test
media that exceeds testing requirements that have been vetted and agreed upon in the
national consensus standards. While the intention of this requirement may be worthy,
no data has been provided by EPA as to why it is needed, only to state in their
supporting statement that the addition of this additional media represents some
additional level or assurance for flushometer-valve toilet performance. Kohler Company
would suggest that EPA present data which supports the inclusion of additional test
media to the appropriate ASME task group for consideration of this requirement in the
appropriate standards.

Suggested Change (or Language): Kohler Company recommends that EPA remove
the requirement for testing water closet fixtures with one unwaxed paper water closet
seat cover throughout Section 5.0- Flush Performance Criteria, and as a result can
remove Section 5.0 in its entirety, as the flush performance requirements are already
covered in Sections 3.0 and 4.0.

Topic: 6.0 Product Marking

Comment: Section 6.2.2 should be added to 6.2.1

Rationale: Sections 6.2.1 and 6.2.2 both state the same requirement, which makes the
requirements unclear to the reader.

Suggested Change (or Language): Kohler Company recommends that EPA delete
section 6.2.2 and change the language in 6.2.1 to read, "The flushometer valve and its
included product documentation must not provide instruction directing the user to
specific maintenance or replacement parts that would cause the flushometer valve to
exceed its rated flush volume specified in Section 2.1.1."

Topic: 9.0 Definitions

Comment: A definition for CSA has been excluded

Rationale: While CSA does reference Canadian Standards Association, it may seem
that it would not apply to the requirements of a U.S. EPA specification, however because

28

April 23, 2015


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WaterSense

Comments on Draft Specification for
Flushometer-Valve Water Closets

many of the standards referenced within this document have been harmonized with the
CSA standard, it is important that a definition be included.

Suggested Change (or Language): Kohler Company recommends that EPA include
the following definition within Section 9.0, "CSA: Canadian Standards Association."

Again thank you for the opportunity to comment. As a leading manufacturer of kitchen
and bath plumbing products worldwide, Kohler Co. applauds EPA WaterSense for their
efforts and focus on water efficiency. We share this same commitment to environmental
stewardship and look forward to continuing to work with EPA WaterSense in the future.

Respectfully submitted,

Shabbir Rawalpindiwala

Manager - Engineering, Codes & Standards

Kohler Company

SR/tk

29

April 23, 2015


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WaterSense

Comments on Draft Specification for
Flushometer-Valve Water Closets

Commenter: John Bertrand
Affiliation: Moen Incorporated
Comment Date: March 13, 2015

Email Attachment:

Topic: Scope and Objective

Comment: This WaterSense specification provides no user benefit above current
products and therefore is unnecessary. Furthermore, because of local jurisdiction
requirements, this specification may force some property owners to retrofit a high-
efficiency model on to an older system ill-equipped to handle it.

Rationale: Currently, there are flushometer valve toilets certified to the same national
performance standards referenced in this draft specification at the same WaterSense
maximum flush volume of 1.28 gpf. As noted by the EPA in the NOI, these products "are
already subject to rigorous national performance standards" and "these national
standards have a proven record of ensuring a high level of performance". The only
notable difference between the current certification requirements and this draft
specification is the addition of the toilet seat cover in the waste extraction test. Currently
certified products are able to process this additional media in the field every day, and
therefore, this slight testing difference does not create "a high level of user satisfaction"
any different than current products. This specification would only burden manufacturers
with additional testing, certification and annual compliance costs with no added benefit to
the consumer.

WaterSense labeled products have become mandatory in some jurisdictions for new and
retrofit construction and this specification will effectively limit a property owner's ability to
select the proper device for the installation. Some older installations may not function
properly with lower flush volumes resulting in costly maintenance and repairs, and
compromising the public health and safety.

Suggested Change (or Language): Discontinue development.

Respectfully submitted,

John Bertrand
Manager - Compliance
Moen Incorporated

30

April 23, 2015


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WaterSense

Comments on Draft Specification for
Flushometer-Valve Water Closets

Commenter: Shirley Dewi

Affiliation: International Association of Plumbing and Mechanical Officials
Research and Testing (IAPMO R&T)

Comment Date: March 18. 2015

Email Attachment:

Topic: Appendix A section 3.0

Comment: For a complete system, how do you identify the bowl/valve combinations
when they are from different manufacturers?

Rationale: Draft product notification template does not reflect this information.

Suggested Change (or Language): Clarify Appendix A section 3.0 and Product
Notification template to accommodate this information.

31

April 23, 2015


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WaterSense

Comments on Draft Specification for
Flushometer-Valve Water Closets

Commenter: Daniel Gleiberman
Affiliation: Sloan Valve Company
Comment Date: March 20, 2015

Dear EPA Watersense-

Attached please find Sloan Valve Company's comments on the EPA Watersense Draft
Specification. The Appendix A is referenced in our comments so we ask that it be
included.

Thank you for your consideration.

Please do not hesitate to contact me if you have any questions or need any additional
information.

Sincerely,

Daniel Gleiberman

Manager-Product Compliance and Government Affairs

SLDAN

WATER CONNECTS US

14505 Astronautics Lane|Huntington Beach, CA 92647
Office: 714-934-1196
Mobile: 310-980-5062
www.sloanvalve.com

Email Attachment:

See pages 33 through 61.

32

April 23, 2015


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SUDAN

March 20, 2015

U.S. Environmental Protection Agency
Office of Water-WaterSense Program
1200 Pennyslvania Avenue N.W.

Washington, D.C. 20460
Watersense-products@erq.com

RE: EPA WATERSENSE DRAFT SPECIFICATION FOR FLUSHOMETER VALVE WATER CLOSETS
Dear EPA Office of Water:

Sloan Valve Company has supported the WaterSense program since its inception, and we are proud to
be a WaterSense partner. As the industry leader in the development, design, manufacture, and
maintenance of flushometer valves for water closets, we greatly appreciate the opportunity to provide
comments on the above referenced draft specification.

We note that EPA WaterSense uses several factors in determining which products to label. Per the
WaterSense guidelines, products must:

1.	Offer equivalent or superior performance;

2.	Be about 20 percent more efficient than standard models;

3.	Realize water savings on a national level;

4.	Provide measurable results;

5.	Achieve water efficiency through several technological options;

6.	Be effectively differentiated by the Watersense label; and

7.	Be independently certified.

Attached are our detailed comments which follow the template as provided by EPA, identifying the topic,
providing comment and rationale, and then offering modifications where needed. All of our proposed
changes to the draft specification relate directly back to the 7 factors noted above and will improve the
practical use of this specification by manufacturers, water utilities, and consumers and all other
stakeholders. Our proposed changes, specifically as it relates to dual-flush flushometers, will ensure
that the water savings estimates of up to 41 billion gallons of water calculated in the EPA Watersense
supporting statement can be achieved. Without our proposed changes, however, it is likely that very few
older inefficient (3.5 gpf or greater) fixtures will be replaced and therefore these ambitious and important
water savings will not be realized.

Thank you for the opportunity to provide comments.

Sincerely,

*Da#icel

Daniel Gleiberman

Manager, Product Compliance and Government Affairs

10500 Seymour Avenue*Franklin Park, Illinois 60131-1259*Phone 847-671-4300*Fax 847-671-6944


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Template for Public Comment Submission on WaterSense Draft Specification

for Flushometer Valve Toilets

Commenter Name: Daniel Gleiberman
Commenter Affiliation: Sloan Valve Company
Date of Comment Submission: March 20, 2015

Topic: EPA has stated that based on the results of PERC I, drainline blockages are not of significant
concern at 1.28 gpf.

Comment: EPA should be cautious in basing their entire rationale for a maximum 1.28 gpf on PERC I.
PERC I began the conversation on "How low can we go?" PERC I did not conclude that all plumbing
systems can operate safely at 1.28 gpf, but instead cautioned against basing any decisions on the
results. The fact is that PERC has only begun to identify the impact of low flow fixtures and fittings in the
building environment and their impact on drainline carry.

Rationale: Though the PERC TC did make a recommendation to the EPA to expand their WaterSense
program to include commercial, flushometer-valve toilets, they also made a recommendation for the EPA
to carefully review and consider the results of PERC II as well1. Because EPA WaterSense has identified
that the majority of water savings will be realized through the replacement of older, inefficient (3.5 gpf or
greater) fixtures, it is imperative that these issues of drainline blockages be reviewed prior to this
specification being finalized.

Suggested Change/Action: The proposed specification should not be finalized until after the results of
PERC II have been documented and reviewed by the EPA and plumbing industry and the applicability to
existing building drain line systems is better understood.

Topic: The installation of high-efficiency plumbing fixtures and fittings in older commercial structures.
Comment: Because EPA WaterSense has identified that most of the projected water savings will be
realized through the replacement of older, inefficient (3.5 gpf or greater) fixtures with WaterSense
certified fixtures, we believe that a statement should be added to the specification that provides guidance
to building owners, managers, or designers to have a qualified engineer determine if their specific
structure can accommodate the installation of high-efficiency plumbing fixtures and fittings. We also
believe that in those instances a dual-flush flushometer valve with flush volumes of 1.6/1.1 may be the


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most responsible high efficiency option available to guarantee that these older structures do not
experience catastrophic drain line blockages or failures.

Rationale: In WaterSense's supporting documentation it is noted that 28 percent of existing flushometer-
valve water closets that are installed in commercial structures have flush volumes that exceed the current
federal standards. Even though most newer commercial structures will not have any issues with 1.28 gpf
water closets, there are those structures with aging sanitary drainage systems that could prove to be a
maintenance nightmare, and therefore be a risk to public health/safety. Sloan Valve Company believes it
is in the EPA's best interest to include the proposed statement to protect the WaterSense brand.
Suggested Change/Action: The following text should be added to the draft specification factsheet and
other applicable documents on the website Section 1.0:

"For renovations and/or retrofits where the use of high-efficiency plumbing fixtures and fittings are being
considered, the structure should first be assessed by a gualified plumbing engineer to determine if the
sanitary system can accommodate such fixtures and fittings."

Topic: In Section 1.0, the term "flushometer-valve-type technologies" is not defined.

Comment: This term is not clear to the end user, and therefore further clarification is necessary in order

for proper application and enforcement-

Rationale^ The proposed text will assist the end user in not misinterpreting the scope of the draft
specification.

Suggested Change/Action: Revise the text of Section 1.0 as follows:

"Any other technology that serves the function of a flushometer-valve, falls within the scope ofASSE
1037/ASME A112.1037/CSA B 125.37, and which meet these performance specifications." "Any other
flushometer-valve-type technologies that meet these performance specifications."

Topic: In Section 2.0 (Water Efficiency Criteria), there is not a minimum threshold for water consumption.
Comment: Throughout the plumbing industry, it has been acknowledged that an "unknown yet to be
determined" minimum threshold exists where health/safety and performance would be negatively
impacted. In fact, it was indicated by the PERC TC that flush volumes between 1.28 gpf and 0.8 gpf need
to be further evaluated to better understand drainline performance2. Therefore, PMI strongly
recommends that the specification contain a minimum flush volume requirement.

Rationale: The PERC I study showed how flush volumes of 0.8 gpf resulted in chaotic and highly
inconsistent drainline transport results. This is a red flag that drainline efficacy is at risk using such low
flush volumes. We recommend that the specification call for a minimum flush volume requirement of no
less than 1.0 gpf for all flush levels, including the reduced flush on dual flush models. Creating an
incentive to design and market water closets or flushometer valves that flush less than 1.0 gpf severely
risks high profile drainline blockage failures in commercial buildings and the success of the specification.
Suggested Change/Action: Revise the text of Section 2.1.1 as follows:

" The manufacturer shall specify a rated flush volume of for the flushometer valve or water closet fixture,
which must shall be equal to or less than 1.28 gallons per flush (gpf) (4.8 liters per flush ILpfl). and not
less than 1.0 gpf (3.8 Lpf)."

Topic: In Section 2.1.3, the water efficiency requirement of 1.28 gpf maximum for dual-flush water
closets.

Comment: This specification should not have a different definition or criteria for dual flush flushometer
water closets as compared to dual flush tank-type water closets. Not only is this approach not
reasonable, it is not supported by fact. EPA has incorrectly relied on anecdotal information and an
extremely limited behavioral study to conclude that water savings of about 20 percent will not be realized.
Using the composite average of 2 small flushes and 1 large flush to calculate water consumption for


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dual-flush water closets was made several years ago with the concurrence of manufacturers, regulators,
and non-government organizations based on the same research now being quoted to dismiss this metric.
Comments from both the Alliance for Water Efficiency on this specification's NOI and from PMI (both
during the NOI and currently for the draft specification) urge EPA WaterSense to adopt language in this
specification that is identical to the language in the Tank-Type Water Closet Specification. These two
organizations represent a wide array of WaterSense partners and interested stakeholders and we concur
with their comments.

Rationale: In addition to being accepted by EPA WaterSense in the Tank-Type Water Closet
Specification, the 2:1 flush ratio is utilized and relied upon as an indicator of efficiency in legislation in
California, Texas, Georgia, Florida, Colorado, New York City, Los Angeles as well as the green plumbing
codes. None of these laws or plumbing codes draw a distinction between residential or commercial
applications. These policymakers and technical experts that comprise these code bodies have
recognized that these fixtures can achieve water savings as compared to 1992 EPACT levels.
Considerable resources have gone into the design, marketing and installation of dual-flush water closets
to inform and promote this considerable water savings innovation in the residential and commercial
markets and these should not be disregarded.

As proposed by the draft specification, a redefinition of dual-flush performance that only recognizes the
maximum flush rate may push the small flush design of water closets with a 1.28 gpf maximum into an
area of questionable system performance. We have already stated above and it has been acknowledged
by the PERC I research that there is lower limit of water consumption in commercial settings that will lead
to catastrophic drain blockages. Without any solid evidence to change the performance aspect of dual-
flush water closets which would significantly disrupt the overall marketplace, the 2:1 flush ratio for dual-
flush water closets must be maintained.

Based on the information from the supporting document for the draft specification, Watersense indicates
that replacing older (pre-1992 EPACT averaging 3.5 gpf) water closets can save 5,400 gallons per fixture
annually as compared to only 780 gallons annually when a EPACT (1.6 gpf) fixture is replaced. The total
water savings number discrepancy is astounding- 42 billion gallons of water savings from the
replacement all pre-1992 EPACT water closets compared to 14 billion gallons of water savings from the
replacement of 1.6 gpf water closets. Simply stated, replacing the 28 percent of older water closets will
yield 3 times as much water savings and this should be encouraged by EPA WaterSense. In fact, this is
going on now in drought stricken and water scarce areas around the United States. Attached as
Appendix "A" are sample rebate applications and criteria from various water utilities (all of which are EPA
Watersense Partners as well) that currently provide financial incentives for commercial customers to
replace 3.5 gpf or greater fixtures with High Efficiency fixtures. These include San Francisco PUC, East
Bay MWD, MWD of Southern California, Portland Water Bureau, Denver Water, Soquel Water, and Rock
River Texas. This is intended as a sampling of those WaterSense Partners/Water Agencies which
provide these incentives and is not an exhaustive list. These financial incentives are only offered for the
replacement of pre-1992 EPACT fixtures for good reason. These will yield more water savings for both
the customer and the water agency, by EPA estimates 5,400 gallons a year compared to only 780
gallons. All of these water agencies consider a dual flush flushometer valve to be an HE fixture.
This also is for good reason. All of these water agencies have considered and are aware that older
fixtures are in older structures, with drain lines that may be very large in diameter, may have a sag or
interruption in the slope, or may have considerable build-up that has occurred over time. The dual-flush
option at 1.6/1.1 still offers efficiency and water savings but it also provides the additional water that may
be necessary to overcome these adverse conditions in the old drainage system. Therefore, we believe
that the draft specification needs to retain the full range of efficient products available as suitable fixture
replacements within these older buildings.

Elimination of the currently accepted and published dual flush option of 1.6 full flush/1.1 reduced flush
may have a deleterious effect on the potential replacements of these pre-1992 EPACT water closets. It
has been established that these older water closets will yield 85% greater water savings if they are
replaced with Watersense labeled products. Because these older existing fixtures all occur in


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commercial buildings with older infrastructure (drainlines and water supplies), the dual flush option is
necessary for these building owners and operators if Watersense is to achieve the 41 billion gallons of
projected water savings. If dual flush as it is currently allowed in the Tank Type specification and
numerous plumbing codes and legislation previously cited is prohibited in this specification, it will likely
result in these older fixtures not being replaced at all. Evidence from existing rebate programs
established to encourage these replacements verifies this fact.

Sloan Valve Company also submits that EPA WaterSense has inexplicably ignored two studies that
relate directly to calculated water savings of dual flush water closets in commercial settings. These two
studies directly refute the statements by EPA in the supporting document. Both of these studies
(("Flush: Examining the Efficacy of Water Conservation in Dual-Flush Toilets, 2010" and "Dual-flush
Toilet Project, September 2002") are easily found through an internet search and should have been
considered in the development of the draft specification as they contradict the study referenced within the
EPA supporting statement. In the EPA supporting statement for this draft specification, EPA indicates
that"water savings are largely based on user behavior and can be influenced by lack of user education,
as well as design considerations (e.g. whether the reduced-flush mode requires the user to pull up or
push down on the handle)2." EPA cites only a single study conducted by the University of Missouri which
looked at only one type of design consideration. In the 2010 study, which looked at a dual-flush
flushometer valve installation in a commercial building in Portland, it was indicated a 1.9 to 1 reduced
flush to full flush ratio3. Additionally, in the study from 2002 sponsored by the Canada Mortgage and
Housing Corporation, it analyzed tank-type dual-flush water closets in commercial settings such as
municipal buildings, secondary schools, and institutional settings. From all of these data points the study
found that on average for these commercial settings the ratio of reduced flushes to full flushes was 1.7 to
14. Therefore, WaterSense should consider these studies in addition to the one cited in the supporting
statement and conclude that in commercial settings water savings can be about 20 percent more efficient
than standard models.

For all of these reasons, the specification should be amended to include the same language pertaining to
dual flush that is in the current EPA Watersense Tank-Type Specification.

Suggested Change/Action: Revise the text of Section 2.1.3 as follows:

"The effective flush volume shall not exceed 1.28 gallons (4.8 liters) when evaluated in accordance with
the sampling plan contained in 10 CFR 429.30. For dual-flush toilets, the effective flush volume is the
average flush volume of two reduced flushes and one full flush. Flush volumes shall be tested in
accordance with ASME A112.19.2/CSA B45.1 and ASME A112.19.14. For flushometer valves with dual
flush capabilities, these water efficiency requirements shall apply to the full-flush mode."

Topic: In Section 3.0, the requirement for manufacturers of water closet fixtures to test their product with
a flushometer valve from three different manufacturers.

Comment: No evidence has been provided by the EPA to demonstrate that by using three different
manufacturer's flushometer valves that are certified to ASSE 1037/ASME A112.1037/CSA B125.37, and
therefore such valves should perform relatively the same, will improve performance and efficiency
beyond the testing requirements contained in the applicable consensus standards for water closets. In

2 Source: WaterSense® Draft Specification for Flushometer-Valve Water Closets Supporting Statement. Document can be
found at: http://www.epa.gov/watersense/docs/FVtoilets supportstat508.pdf

3Source: Flush: Examining the Efficacy of Water Conservation in Dual-Flush Toilets, 2010, Prepared by Masaye Harrison,
University of Oregon at Portland, Department of Architecture. Study can be found at: http://www.map-
testing.com/assets/files/2010-commercial dual-flush toilet studv-harrison.pdf

4Source: Dual-flush Toilet Project, Canada Mortgage and Housing Corporation, September 2002, Prepared by: Veritec
Consulting Inc. Study can be found at: http://www.cmhc-schl.gc.ca/odpub/pdf/63042.pdf?lang=en


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fact, this additional testing requirement will do nothing more than unnecessarily increase manufacturing
costs by threefold.

Rationale: The proposed specification should only reference the applicable consensus standards for
water closets (ASME A112.19.2/CSA B45.1, ASME A112.19.3/CSA B45.4 or CSA B45.5/IAPMO Z124)
to ensure that necessary performance and efficiency requirements are met. PMI's recommendation will
also be consistent with the EPA's own opinion on consensus standards for water closets as stated in the
WaterSense Draft Specification for Fiushometer-Vaive Water Closets Supporting Statement (page 5):
"These national standards have a proven record of ensuring a high level of performance and durability in
toilets, and will serve as a good foundation for a WaterSense specification for flushometer-valve toilets."
Suggested Change/Action: Revise the text in Sections 3.1, 3.2 and 3.3 as follows:

•	"3.1 Except as otherwise indicated in this specification, ceramic water closet fixtures must conform to
applicable requirements in ASME A112.19.2/CSA B45.1 when tested with representative flushometer
valves from three different flushometer valve manufacturers that have the same rated flush volume
and that meet the requirements of Sections 2.0, 4.0, and 5.0."

•	"3.2 Except as otherwise indicated in this specification, stainless steel water closet fixtures must
conform to applicable requirements in ASME A112.19.3/CSA B45.4 when tested with representative
flushometer valves from three different flushometer valve manufacturers that have the same rated
flush volume and meet the requirements of Sections 2.0, 4.0, and 5.0."

•	"3.3 Except as otherwise indicated in this specification, plastic water closet fixtures must conform to
applicable requirements in CSA B45.5/IAPMO Z124 IAPMO/ANSI Z124.4 when tested with
representative flushometer valves from three different flushometer valve manufacturers that have the
same rated flush volume and that meet the requirements of Sections 2.0, 4.0, and 5.0."

Topic: The new tri-harmonized ASSE 1037 standard.

Comment: The reference made to the new tri-harmonized ASSE 1037 standard in Sections 4.1 and 6.2

has an editorial error.

Rationale: The proposed change will correct the editorial error by adding an "A" before "112.1037."

Suggested Change/Action: Revise the text of Sections 4.1 and 6.2 as follows:

•	"4.1 Except as otherwise indicated in this specification, flushometer valves must conform to ASSE
1037/ASME A112.1037/CSA B125.37. [Note: WaterSense intends to require flushometer valves to
conform to ASSE 1037/ASME A112.1037/CSA B125.37 upon the standard's release.]"

•	"6.2 Flushometer valves shall be marked in accordance with requirements in ASSE 1037/ASME
A112.1037/CSA B125.37. [Note: WaterSense intends to require flushometer valves to conform to
ASSE 1037/ASME A112.1037/CSA B125.37 upon the standard's release.] Additional marking
requirements for flushometer valves are provided in Sections 6.2.1 and 6.2.2 below."

Topic: In Section 4.4, the requirements for interchangeability of replaceable or maintainable parts.
Comment: The intent of Section 4.4 is unclear with respect to EPA's intent.

Rationale: This proposed change will better clarify the intent of the section by aligning with the
clarification statement made by WaterSense in regards to requirements for interchangeability of
replaceable or maintainable parts in the WaterSense Specification for Flushing Urinals. The clarification
can be found within the third tab of the recently updated document, Compendium of WaterSense Product
Specification and Certification and Labeling Clarifications.

Suggested Change/Action: Revise the text of Section 4.4 as follows:

"The manufacturer, at a minimum, must provide product documentation that is clearly marked with
specific maintenance/replacement part instructions and identification of correct replacement parts that
should be used to ensure attest that the flushometer valve is designed such that replaceable or
maintainable parts (e.g., pistons, diaphragms) are not intended to be interchangeable with parts that
would cause the device to will not exceed the rated flush volume specified in Section 2.1.1.

Topic: Flush performance criteria in Sections 5.1 and 5.2.


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Comment: The text in these sections is not clear to the intent nor necessary for proper application and
enforcement of the draft specification.

Rationale: These sections are not necessary as the draft specification already requires testing to be
conducted in accordance with ASSE 1037/ASME A112.1037/CSA B125.37 for flushometer valves.
Suggested Change/Action: Delete the text of Sections 5.1 and 5.2 as follows:

"5.11ndividual flushometer-valve samples with average water consumptions greater than their rated flush
volume shall be adjusted, if possible, to their rated flush volume prior to performance testing."
"5.2 Individual flushometer valve samples with average water consumptions less than their rated flush
volume shall be performance tested at the measured volume and this volume shall be recorded on the
test report."

(Renumber remaining sections accordingly)

Topic: In Section 5.3, the requirement for one unwaxed paper water closet seat cover to be used during
the waste extraction test for flushometer valves and water closet fixtures.

Comment: PMI is concerned with the proposed testing protocol being presented as it has not been
vetted through the applicable standard development process.

Rationale: The current testing requirements in ASME A112.19.2/CSA B45.1 are the standard for
performance for all water closets. No evidence has been provided by the EPA to show that such
requirements should be changed for the products covered by this specification.

Suggested Change/Action: Revise the text in Sections 5.3 through 5.3.3 as follows:

"5.3 Flush performance testing for flushometer valves and water closet fixtures shall be conducted in
accordance with the waste extraction test protocol provided in Section 1.10 of ASME A112.19.2/CSA
B45.1 and the additional test media and procedural steps for the waste extraction test protocol provided
in Sections 5.3.1, 5.3.2, and 5.3.3 below.

5.3.1	Test media used during the waste extraction test shall include one unwaxed paper water closet
seat cover. The seat cover must have a width of 14.0 ± 1.0 inches (356 ± 25 mm) and a length of 16.5
± 1.0 inches (419 ± 25 mm). The seat cover shall be included in the test media specified in Section
7.10.2 of ASME A112.19.2/CSA B45.1.

5.3.2	Following step "g" of the waste extraction test procedure in Section 7.10.3 of ASME
A112.19.2/CSA B45.1, the following procedural step shall be applied."

5.3.2.1 Immediately after adding crumpled toilet paper, freely drop one unfolded, unwaxed water
closet seat cover onto the fixture water surface such that the center of the seat cover is
approximately at the center of the water surface.

5.3.3	After completion of the procedural step identified in Section 5.3.2.1 of this specification, the test
protocol shall continue with step "h" of the waste extraction test procedure in Section 7.10.3 of ASME
A112.19.2/CSA B45.1."

Topic: In Section 5.4, the requirement for one unwaxed paper water closet seat cover to be included in
the toilet paper test of ASME A112.19.14 for flushometer valves with dual-flush capabilities, in the
reduced-flush mode.

Comment: PMI is concerned with the proposed testing protocol being presented as it has not been
vetted through the applicable standard development process. EPA did not provide any evidence to show
that the testing requirements in ASME A112.19.14 are flawed.

Rationale: The proposed specification should remain consistent with the testing requirements found in
ASME A112.19.14, and the additional test media requirement should be deleted from the proposed draft
specification.

Suggested Change/Action: Revise the text in Sections 5.4 through 5.4.2.3 as follows:

"5.4 For flushometer valves with dual-flush capabilities, the following flush performance criteria shall

apply:

5.4.1	For the full-flush mode, the flush performance testing shall be conducted in accordance with
Section 5.3.

5.4.2	For the reduced-flush mode, flush performance testing shall be conducted in accordance with
Section 3.2.4 of ASME A112.19.14. Testing shall also include additional test media and revised


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procedural steps for the toilet paper test protocol specified in Section 3.2.4 of ASME A112.19.14, as
provided in Sections 5.4.2.1, 5.4.2.2, and 5.4.2.3 below.

5.4.2.1	Test media used during the toilet paper test shall also include one unwaxed paper water
closet seat cover. The seat cover must have a width of 14.0 ± 1.0 inches (356 ± 25 mm) and a
length of 16.5 ± 1.0 inches (419 ± 25 mm).

5.4.2.2	Section 3.2.4.2 of ASME A112.19.14 shall be modified as follows:

"The four 2.0 to 3.0 inch (51 mm to 76 mm) balls of paper that comply with paragraphs 3.2.4.1.1
and 3.2.4.1.2 shall be dropped into the water directly above the well and shall be allowed to wet
out completely. Immediately after adding the balls of paper, freely drop one unfolded, unwaxed
water closet seat cover onto the fixture water surface such that the center of the seat cover is
approximately at the center of the water surface. Within five seconds of adding the seat cover, the
bowl shall be flushed. This procedure shall be repeated until three sets of data are obtained. Note
whether any paper or seat cover are left in the bowl. Flush again and collect any paper or seat
cover that discharges from the outlet."

5.4.2.3	Section 3.2.4.3 of ASME A112.19.14 shall be modified as follows:

"No paper or seat cover shall remain in the well after each initial flush."

Topic: The product documentation requirements in Section 6.2.2.

Comment: In Section 6.2.2, the same requirement for product documentation is stated twice within this
section, and therefore is confusing to the end user.

Rationale: Section 6.2.2 provides redundant requirements. There is no need for the 2nd sentence of
Section 6.2.2 as the first sentence already states that manufacturers shall provide specific
maintenance/replacement part instructions and identification of correct replacement parts so that the
flushometer-valve will not exceed its rated flush volume.

Suggested Change/Action: Revise the text in Section 6.2.2 as follows:

"Product documentation shall be clearly marked with specific maintenance or replacement part
instructions and identification of correct replacement parts that should be used to ensure that the device
will not exceed its rated flush volume. Under no circumstances can manufacturers provide maintenance
instructions or advertise the use of any replacement parts that would cause the flushometer valve to
exceed its rated flush volume."


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APPENDIX "A"

Sample Water Agency Rebate Forms
for Dual-Flush Flushometer Water
Closets from:

l.San Francisco Public Utilities Commission

2.	Metropolitan Water District of Southern
California

3.Portland	Water Bureau
4.Soquel Water District
5.Santa Fe Water

6.	Denver Water

7.East	Bay Municipal Water District

8.	Round Rock Texas Water


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San Francisco

Water Power Sew ?t

Services of the San Francisco Public Utilities Commission

Application Valid From: 7/1/14- 6/30/15

High-Efficiency
Toilet Rebate Application

The San Francisco Public Utilities Commission is offering up to $125 rebate per tank style toilet and up to
$500 per flushometer type toilet for the replacement of toilet(s) using 3.5 gallons per flush (gpf) or more,
with qualifying high efficiency toilets that use-i;28 (gpf) or less. Rebates are no longer provided for
the purchase or replacement of 1.6 gpf toilets.

Tank Style Toilets - Typically found in residential homes and light commercial settings and consist of a
water tank and a bowl. Tank style toilets must be WaterSense certified to receive a rebate. The
qualifying list can be found at http://conserve.sfwater.org

Flushometer Style Toilets - Typically found in commercial settings and consist of a flush valve and a
bowl. Flushometer style toilets must be MAP tested to receive a rebate. The qualifying list can be found
at littp://conserve.sfwater.org. Up to $500 rebate amount applies only to purchases from 7/1/14 - 6/30/15.

IMPORTANT: PLEASE READ THE PROGRAM RULES AND REBATE GUIDELINES BEFORE SUBMITTING YOUR APPLICATION

Account Information (please print)

Name on Water Account	10-digit Account Number *

Property or Installation Address	Daytime Phone Number	Email

Type of Property in Which Toilet(s) Are Installed (E.G. Single-Family House, Multi-Family Dwelling, Etc.) Toilet Type Installed (Tank Type/ Flushometer)

Total # of Toilets in Property	# of Rebates Requested	Year Property Built	Year Property was Purchased

Applicant Information: * Must match the name and address on required W-9 form.

* * Rebate check will be sent only to the W-9 contact. If W-9 name and address is the same as account name
and address, note "same as above" under applicant information.

* First Name	. * Last Name

** Address (as noted on applicant's W-9)	City	State	Zip Code

Your Signature

I certify I have read, understand and agree to the terms and conditions of this rebate program. The undersigned expressly
agrees that the SFPUC may inspect all qualifying toilet installations; that installation of qualifying toilet models may not result in
lower water bills; and that the SFPUC does not warrant any toilet or installation to be free of defects, the quality of
workmanship, or the suitability of the premises for toilet installation. The undersigned further agrees to defend, indemnify and
hold harmless the SFPUC, their directors, officers, and employees, against all loss, damage, expense, claims, suits and liability,
including attorneys fees resulting from the loss, destruction or damage to property arising out of or in any way connected with
the toilet or installation.

Signature (Must be signed with color ink other than black)	Print Name	Date

ADMIN ONLY

APPROVED ~
REVIEWED BY

REJECT

~

"REFER TO YOUR MOST RECENT WATER BILL OR CALL (415) 551-3090 FOR YOUR ACCOUNT NUMBER INFORMATION


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High-Efficiency Toilet Rebate Application

Program Rules

1.	Rebates are only for 1.28 gpf toilets (or lower) purchased to replace existing high-volume toilets
(3.5 gpf or higher); toilets installed during the addition of a new bathroom are not eligible.

2.	Single family homes are limited to three (3) rebates per home. There is no limit for multi-unit or commercial
properties,

3.	Properties built in or after 1994 are not eligible to participate as federal requirements mandate any toilet
purchased or installed in or after 1994 to have a maximum flush volume of 1.6 gallon per flush.

4.	Residential properties purchased after July 1st 2009 are not eligible for rebate as the Residential Energy and
Water Conservation Ordinance (76-09) requires high efficiency toilet retrofit at the time of sale.

5.	The approved toilet must be installed at an SFPUC service address and toilet must be installed prior to rebate
request. A separate application must be submitted for each metered address.

6.	Retail account holders with service addresses outside San Francisco may be eligible for rebates and should
contact the Water Conservation Section before submitting an application.

7.	Tank style toilets must be new and on the current EPA's WaterSense Certified Toilet List. Only the exact
model numbers listed will qualify for a rebate; please confirm that both the tank model number and the bowl
model number appear on this list. List of qualifying models are subject to change. Visit
http://conserve.sfwater.org for a list of qualifying models.

8.	Flushometer style toilets must be new and on the current MAP tested list. Only the exact model numbers
listed will qualify for a rebate; please confirm that both the valve model number and the bowl model number
appear on this list. List of qualifying models are subject to change. Visit http://conserve.sfwater.org for a list
of qualifying models.

9.	Rebate amount is not to exceed the purchase price of the bowl and tank/valve (not including tax, labor,
other related costs). The proof of payment submitted must indicate the itemized cost of the toileUs).

Receipts and/or invoices that do not include the itemized cost of the toiletCs") will be rejected.

10.	A pre-purchase inspection is required for any site where 10 or more toilets are being replaced, have
previously received toilet replacement incentives or are planning on remodeling entire building. Please call
(415) 551-4730 to schedule an appointment.

11.	The SFPUC reserves the right to verify the installation of the toilet(s). Failure to allow an inspection of the
installed toilet(s) within 30 days of request or to install the toilet(s) will result in refusal of rebate.

12.	An IRS W-9 form must be completed by all applicants to receive a rebate. The Social Security or Tax ID
number requested in the Rebate application process is in compliance with exemptions to the Federal Privacy
Act of 1974, 42 UCS 405 (c) (2)(c). The Internal Revenue Service requires rebate program participants
receiving $600 or more in rebates to be issued an IRS Form 1099 unless exemptions apply. Social Security
numbers provided as part of the application process are held in confidence under terms of the Privacy Act
and are not divulged or otherwise conveyed to individuals or organizations outside the Rebate Program.

13.	Rebate application and W-9 must be completed and returned with the original proof of payment
postmarked within 60 days of purchase. See Rebate Guidelines for details on acceptable proof of payment.

14.	Please make copies for your records. Original receipts will not be returned.

15.	Incomplete or illegible applications will be denied.

16.	Fixtures that are rebated through another water agency program are not eligible to receive an SFPUC rebate.

17.	The SFPUC reserves the right to alter this program at any time, Funding is limited and rebates are available
on a first come, first serve basis until funds run out or program terminates. Rebate amounts may change;
check the website for current rebate amounts.

18.	Applications will only be accepted by mail at the address below. Please allow approximately 12 weeks for
processing after all applicant requirements have been met.

19.	Installations of toilets funded by SFPUC rebates are subject to post-inspection. Flushometer valve/bowl
combination assemblies must be installed and maintained not to exceed the flush volume and performance
specified by the manufacturers. SFPUC rebate recipients found to have tampered, replaced, or adjusted the
piston or diaphragm valves to increase flush volumes of their fixtures or swapped out high efficiency bowls
with less efficient models will be subject to repayment of the full amount of funding received from the
SFPUC.

Please mail applications to:

SFPUC - Water Conservation Section
525 Golden Gate Avenue
San Francisco, CA 94102

Email: waterconservation@sfwater.org Website: http://conserve.sfwater.org Phone: (415) 551-4730


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WATER



BEVERLY HILLS

METROPOLITAN'S
MEMBER AGENCIES

CLEVELAND

NEWPORT
BEACH

Department of Water Resources' California Aqueduct
Metropolitan's Colorado River Aqueduct
Water Treatment Plants

Vk«ot«


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Metropolitan's Member Agencies and

Communities Served

The mission of the
Metropolitan Water District

of Southern California
is to provide its service area
with adequate and reliable
supplies of high-quality water to
meet present and future needs

in an environmentally and
economically responsible way.

THE METROPOLITAN WATER DISTRICT
OF SOUTHERN CALIFORNIA

Post Office Box 54153
Los Angeles, CA 90054-0153

www.mwdh2o.com
www.bewaterwise.com

n/n 30m

Anaheim
Beverly Hills
Burbank

Calleguas Municipal Water District

Camarillo
Camarillo Heights
Foirview
Lake Sherwood
Las Posas Valley
Moorpark

Naval Base Ventura County

Newbury Park

Oak Park

Oxnard

Port Hueneme

Santa Rosa Valley

Simi Valley

Somis

Thousand Oaks
Central Basin Municipal Water District

Artesia
Bell

Bellfiower

Beil Gardens

Carson

Cerritos

Commerce

Compton

Cudahy

Downey

East Los Angeles
Florence-Graham
Hawaiian Gardens
Huntington Park
La Habra Heights
Lakewood
La Mirada
Los Nietos
Lynwood
Maywood
Montebello
Monterey Park
Norwalk
Paramount
Pico Rivera
Santa Fe Springs
Signal Hill
South Gate
South Whittier
Vernon
Walnut Park
West Whittier
Whittier
Willowbrook

Compton

Corona Del Mar

Rainbow

Vaiinda

Eastern Municipal Water District

Costa Mesa

Ramona

West Covina

French Valley

Coto De Caza

Rancho San Diego

West Basin Municipal Wat

Good Hope

Cypress

Rancho Santa Fe

Alondra Park

Hemet

Dana Point

San Diego

Carson

Homeland

Fountain Valley

San Marcos

Culver City

Juniper Fiats

Garden Grove

Santee

Del Aire

Lakeview

Huntington Beach

Solana Beach

El Camino Village

Mead Valley

Irvine

Spring Valley

El Segundo

Menifee

Laguna Beach

Valley Center

Gardena

Moreno Valley

Laguna Hills

Vista

Hawthorne

Murrieta

Laguna Niguel

San Fernando

Hermosa Beach

Murrieta Hot Springs

Laguna Woods

San Marino

Howard

Nuevo

La Habra

Santa Ana

Inglewood

North Canyon Lake

Lake Forest

Santa Monica

Ladera Heights

Perris

Las Flores

Three Vaiieys Municipal Water District

Lawndale

Quail Valley

La Palma

Azusa

Lennox

Romoland

Los Alamitos

Charter Oak

Lomita

San Jacinto

Mission Viejo

Claremont

Malibu

Sun City

Monarch Beach

Covina

Manhattan Beach

Temecula

Newport Beach

Covina Hills

Marina Del Rey

Valle Vista

Orange

Diamond Bar

Palos Verdes Estates

Winchester

Placentia

Glendora

Rancho Palos Verdes

Foothill Municipal Water District

Rancho Santa Margarita

Industry

Redondo Beach

Aitadena

Rossmoor

La Verne

Rolling Hills

La Canada Flintridge

San Clemente

Pomona

Rolling Hills Estates

La Crescenta

San Juan Capistrano

Rowland Heights

Ross-Sexton

Montrose

Seal Beach

San Dimas

San Pedro

Fulierton

• Stanton

South San Jose Hills

Topanga. Canyon

Glendale

Tustin

Walnut

Torrance

inland Empire Utilities Agency

- Tustin Foothills

West Covina

View Park

Chino

Villa Park

Torrance

West Athens

Chino Hiils

Westminster

Upper San Gabriel Valley

West Hollywood

Fontana

Yorba Linda

Municipal Water District

Westmont

Montciair

Pasadena

Arcadia

Windsor Hills

Ontario

San Diego County Water Authority

Avocado Heights

Western Municipal Water 1

Rancho Cucamonga

Alpine

Azusa

of Riverside County

Upland

Bonita

Baldwin Park

Canyon Lake

Las Virgenes Municipal Water District

Bonsall

Bassett

Corona

Agoura

Camp Pendleton

Bradbury

Eagle Valley

Agoura Hills

Carlsbad

Covina

Eastvaie

Calabasas

Chula Vista

Duarte

El Sobrante

Chatsworth

Del Mar

El Monte

Eisinore

Hidden Hills

El Cajon

Glendora

Jurupa

Lake Manor

Encinitas

Hacienda Heights

Lake Eisinore

Malibou Lake

Escondido

Industry

Lake Mathews

Monte Nido

Fallbrook

Irwindale

Lee Lake

Westiake Village

Jamul

La Puente

March Air Reserve Base

West Hills

Lakeside

Monrovia

Murrieta

Long Beach

La Mesa

North Whittier

Norco

Los Angeles

Lemon Grove

Rosemead

Perris

Municipal Water District

Leucadia

San Gabriel

Riverside

of Orange County

Mount Helix

South El Monte

Rubidoux

Aliso Viejo

National City

South Pasadena

Temecula

Brea

Oceanside

South San Gabriel

Temescai Canyon

Buena Park

Pauma Valley

Spy Glass Hill

Woodcrest

Capistrano Beach

Poway

Temple City




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High-Efficiency Toilets

High-Efficiency Toilet (HET) flushes at 20 percent below a ULFT which flushes at 1.6 gallons
per flush, equating to 1.28 gallons per flush or less. The average water savings for HETs is
estimated to be 19,000 gallons per year when replacing an average, non-efficient toilet and
4,000 gallons per year when replacing a ULFT. This equals an estimated saving of 38 gallons
per day (gpd) when replacing a non- ULFT and 7 gpd when replacing an existing ULFT.

High-Efficiency Toilets are available in Gravity-Fed, Pressure Assist and Dual-Flush models.
Dual-Flush toilets which offer a choice of either a 1,6-gallon flush or a 0.8-gallon flush qualify as
High-Efficiency Toilets.

Please call 1-888-376-3314 to verify eligibility in your area.

Ultra-Low-Flush Toilet (1.6 gpf) rebates are no longer available.

High Efficiency Toilet rebates must have a matching bowl & tank or matching bowl &
flushometer valve. Modification of existing valves or use of valve kits does not qualify for a
rebate.

For more information on how to purchase qualified products, contact your local plumbing
retailer.

Rebates vary by water agency and are subject to change.

Make your reservation High Efficiency Toilets

a

Download the list of Qualified Toilets

1 12


-------
Portland Water Bureau

CommercialToilet
& Urinal Rebate

Replacing older toilets and urinals are a great way to
save water and money! The Portland Water Bureau is
offering a $50 rebate for replacing older fixtures with
WaterSense-labeled tank-style toilets and urinals, and
approved flushometer toilets. Commercial accounts
including businesses, restaurants, schools and
others are eligible for up to 20 rebates per active
domestic water account.

Follow these steps:

O Select eligible toilets or urinals:

WaterSense-labeled tank style toilets which flush at 1.2£ uallons per
flush or less are eligible. A complete list of approved models can be found at
www.epa.gov/watersense.

WaterSense-labeled urinals which flush at 0.5 gallons per flush or less
are eligible. A complete list of approved models can be found at
www.epa.gov/watersense.

Flushometer (commercial) style toilets that flush at 1.28 gallons per flush or
less AND are indicated by the Maximum Performance Test standard to exceed
350 grams of waste removal. The results of the Maximum Performance Test
Standard can be found at www.maBJesting.com

0 Save receipts. A copy of the dated sales receipt (or invoice) is required.

4

WaterSense

€>

Install new toilets or urinals. The toilets or urinals must be installed at the property
associated with Portland Water Bureau account. Random inspections may occur.

Recycle old toilets or urinals and save receipts. Old toilets or urinals must be
recycled at one of the approved recycling centers (listed below). Be sure to get a
receipt for the recycling.

Clackamas Compost Products • Fee: $10 minimum; $10 per cubic yard
11620 SE Capps Rd., Clackamas, 503-557-1028

Fee: $7.50 per toilet

0

0

E.C.R., Environmentally Conscious Recycling

12409 NE San Rafael St., Portland, 503-253-0867

Landscape Products & Supply • Fee: $10 minimum; $10 per cubic yard
1748 NE 25th Ave., Hillsboro, 503-846-0881

Metro Transfer Stations • Fee: Minimum $28 transaction cnarge for
340 pounds or less. Request that toilet recycling be specified on receipt.
Central: 6161 NW 61st Ave., Portland, 503-234-3000
South: 2001 Washington St., Oregon City, 503-234-3000

S&H Landscape • Fee: $10 minimum fee, $7 per cubic yard
20200 SW Stafford Rd., Tualatin, 503-638-1011

Complete and sign Commercial Toilet & Urinal Rebate Form (see reverse).

Attach the following:

1.	Commercial Toilet & Urinal Rebate Form (completed and signed).

2.	Sales receipt or invoice (a copy is acceptable).

3.	Proof of recycling.

3. W-9 Form.

Mail to: Portland Water Bureau	Email to:

WaterSense Toilet Rebate	conserve@portlandoregon.gov

1120 SW 5th Avenue, Room 600
Portland, OR 97204

Receive rebate check. Approximately 4-6 weeks after receiving your completed
application and verifying eligibility, the Portland Water Bureau will send a rebate check.
We are currently unable to credit your Portland Water Bureau account.

LOOK FORTHE LOGO

WaterSense-labeled tank-style toilets
and urinals are eligible for the $50
rebate. WaterSense-labeled fixtures
are 20% more efficient than average
products in that category and perform
as well or better than their less efficient
counterparts.

Toilet Rebate Eligibility
& Requirements

•	Property must have an active Portland Water
Bureau drinking water account in good standing.

•	Application must be for a commercial property.

•	Applicant must purchase a WaterSense-labeled
toilet, urinals or a preapproved flushometer
high-efficiency toilet.

•	Applicant must recycle the old toilet at an
approved recycling center.

•	Limit of 20 toilet or urinal rebates per account.
Each rebate is worth $50.

•	No more than 60 rebates per organization
per program year.

•	Rebates are available on a first-come,
first-served basis.The program will end
when funds are depleted.

•	Rebate applications for more than $600 must
include a completed W-9 form.

•	Application must be received within
one year of toilet purchase date.

Rebate Questions?

(503)823-4527

conserve@portlandoregon.gov
www.portlandoregon.gov/water/rebate

Saving water
makes cents!

PORTLAND

WTER

BUREAU

FROM FOREST TO

Portland Water Bureau

WATER EFFICIENCY PROGRAM

1120 SW Fifth Avenue, Room 600
Portland, OR 97204

Page 1 of 2

To help ensure equal access to City programs, services and
activities, the City of Portland will reasonably modify policies/
procedures and provide auxiliary aids/services to persons with
disabilities. Call (503)823-4527 with such requests.


-------
Portland Water Bureau Commercial Toilet & Urinal Rebate Form

I

See eligibility requirements on the reverse side of this form.

Portland Water Bureau Account #

(Can be found on your water/sewer bill)

Name of Business	

Property Address	

	 Type of Business

Property Owner	 Contact Person	

Mailing Address			 ZIP code

Contact E-mail Address			 Contact Daytime Phone	

Applicants are eligible for up to 20 rebates per account. Please attach an additional form if you need more space.

Toilet/Urinal
Brand Name

Toilet/llrinal
Model Name

Toilet/Urinal
Model Number

Quantity

Purchase
Price

Purchase
Date

Estimated age or
flush volume of toilet
you are replacing

PWB
Internal
Use Only





































































































































































Rebate Agreement / Release of Liability

The Portland Water Bureau may deny any application that does not meet all of the WaterSense Toilet Rebate Program Eligibility and Requirements. Portland Water Bureau
reserves the right to alter or cease this program at any time.The undersigned agrees to allow the Portland Water Bureau, with notification, to enter upon the property to
inspect the installation of the toilet(s) to assure program requirements are met. The Portland Water Bureau is not responsible for the quality of the toilet purchased and does
not warranty any toilet, or any fixture comprising a component in any toilet, or the installation of any toilet. The Portland Water Bureau does not guarantee lower water bills
as a result of participating in the WaterSense Toilet Rebate Program. The Portland Water Bureau is not responsible for any damage that may occur to applicant's property as a
result of removing the old toilet or installing the new toilet under this program. The undersigned agrees to hold harmless the City of Portland and the Portland Water Bureau
from and against all loss, damage, expense and liability resulting from or otherwise relating to the purchase, installation, use or removal of a toilet. By signing this form I
agree that I have read, understand, and agree to the Rebate Agreement / Release of Liability (above) and the WaterSense Toilet Rebate Program Eligibility and Requirements.

By signing this form I agree that I have read, understand, and agree to the Rebate Agreement/Release of Liability (above) and the
WaterSense Toilet Rebate Program Eligibility and Requirements.

Signature of Property Owner or Owner's Representative	 Date	

Note: Toilet/Urinal Rebate Forms that are incomplete, lacking required documents, or missing a signature will be
returned. The Portland Water Bureau is not responsible for items lost or delayed in the mail.

Questions? Contact us at (503) 823-4527 or conserve@portlandoregon.gov.

* FOR INTERNAL USE ONLY *

PORTLAND

mTER

BUREAU

FROM FOREST TO FAUCET

Oate Received

Acct. in Good Standing

Toilet Wate&e$&

Proof Recycle

Proof Purchase

Internal Order#











8WAC00000527

Page 2 of 2


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SOQUEL CREEK	Commercial Toilet

WATER DISTRICT	Rebate Application

1

—S



High-Efficiency & Ultra-High Efficiency Toilets: Soquel Creek Water District offers rebates
for qualifying high-efficiency toilets (HETs) that use 1.28 gallons per flush (gpf) or less, and
ultra-high efficiency toilets (UHETs) that use only 0.8 gpf. Replacement toilets must be EPA
WaterSense-approved to qualify for a rebate. Please see our website at
www.soquelcreekwater.org for links to WaterSense approved toilets, or contact us at (831)

475-8500 for assistance.

Please
rebate

Check the applicable toilet rebate(s), indicate the number of toilets replaced, the purchase price of qualified
parts (i.e. tank, bowl and seat), and the manufacturer name(s) and model number(s) of the new toilet(s) in-
stalled. Complete the Account & Applicant Information below. Use additional sheets of paper if necessary.

Toilet Rebate Type

Rebate
Amount

# of
Toilets

Purchase price of
qualified parts

Manufacturer name(s) & model
number(s) of toilet(s)

~

Replace 3.5 gpf toilet with High-
Efficiency Tank Toilet
(1.28 gpf or less)

Up to

$175







~

Replace 3.5 gpf toilet with Ultra-
High Efficiency Tank Toilet
(0.8 gpf)

Up to
$300







~

Replace 1.6 gpf toilet with Ultra-
High Efficiency Tank Toilet
(0.8 gpf)

Up to

$200







~

Replace 3.5 gpf toilet with High-
Efficiency Flushometer Toilet
(1.28 gpf or less)

Up to
$300







Account & Applicant Information

Property address (where rebated product is installed)	City	Zip Code

Applicant name	Name on water account (if different from applicant)

Account Number	Assessor's Parcel Number (APN)

Applicant mailing address (if different from property address)	City	State	Zip Code

read the Rebate Program Requirements on the backside of this Application. All
applications require the signature of the property owner (if different than the applicant).

Daytime phone number	Alternative phone number	e-mail address (optional)

Complete both sides of application. See other side for rebate program rules, requirements and signature.


-------
Application No.

Commercial, Industrial and Institutional
= Toilet and Urinal Rebate Program Application
•mTj- July 1, 2014 to June 30, 2015

look for



m

Please read all the information on this application, including page 2.

1. Applicant Information

Business Name:

Applicant/Contact Name:

Mailing Address:

City:

State:

Zip:

Installation Address:

Telephone ( )

A	1

Water Account No.

2. Fixture Information

Tank Toilets Installed High Efficiency Toilet must be EPA WaterSense labeled

Manufacturer

Model Name

Model Number (s)

Number Replaced

















Date purchased:

Date installed:

Rebate amount is up to $100 per tank toilet. Both the tank and the bowl must be replaced.

Flushometer Toilets Installed Flushometer toilet must be from qualified list provided by Coastside County Water District

M

anufacturer

Model Name

Model Number (s)

Number Replaced

Bowl











Valve











Date purchased:

Date installed:

The combined rebate (valve and bowl) is up to $300 per toilet. Both the valve and bowl must be replaced.

Urinals Installed High efficiency urinal must be EPA WaterSense labeled

Manufacturer

Model Name

Model Number (s)

Number Replaced

Bowl











Valve











Date purchased:

Date installed:

The combined rebate (valve and bowl) is up to $300 per urinal. Both the valve and bowl must be replaced.

3. Signature(s)

I understand and agree to the terms and conditions of the rebate program.
Applicant signature:

Date:

Property owner signature:

Date:

If the applicant is not the property owner, the owner must co-sign the application



4. Please attach original sales receipt(s) or invoice(s) and return completed application to:	

	Coastside County Water District • 766 Main Street • Half Moon Bay, CA • 94019

For Official Use Only

Inspection Date:

Comment:

Inspector:

Business Type:

Application: DApproved (uDenied

Rebate Amount: $

(650) 726-4405 • www.coastsidewater.org

Page 1


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save
water
sa\Ata Fe

High-Efficiency Toilet
Rebate Application

The high-efficiency toilet (HET) rebate applies to new HETs purchased
after May 1,2011. Please ensure you have read the terms and conditions
before you complete the application below.

NOTE: Original receipt(s) are required. Photocopies will not be accepted.

Applica

nt details

(please p

rint clearly)

Water Utility account number:



Name:







Telephone number:



Installation address:

Address:







Zip code:



Mailing address: (if different from above)

Address:







City:



State:



Zip code:



Declaration:

Your new HET details:

Brand:

Model Name:
Purchase date:

Model #:
Installation Date:
Purchase price (individual price with no tax):	$

Number of fixtures replaced:

Residential Toilets:

Com. Hotel/Motel HETs:
Com.TankType HETs:
Com. Flushometer HETs:

@$175 each	$

@$125 each	$

@$250 each	$

@$500 each	$

Total Rebate	$

Amount:

Installed by: (please check one)

I- Homeowner I~ Plumber P In-House Maintenance Staff

I have read and accept the terms and conditions of this agreement and the information contained in this application is truthful and
correct to the best of my knowledge. I hereby certify that I am the customer authorized to replace the fixtures at the address listed
above.

Applicant's signature: X

Date:

Office use only:

Service Address:

Cycle

O

Case #:

Meter Position: ~ Date Entered:

City of Santa Fe Water Division, Water Conservation Office, PO Box 909, Santa Fe, New Mexico 87504-0909

Phone: (505) 955-4225, www.savewatersantafe.com


-------
Terms and Conditions

To qualify for a rebate:

1.	Purchase and install a new, qualifying high-efficiency toilet (HET) after May 1, 2011.

2.	Applicant must be a water customer of City of Santa Fe Water Division with an account in their name at the service
address where the fixture is installed and at time of purchase.

3.	Tank type HETs must have an effective flush volume of 1.28 gallons or less as determined by EPA's WaterSense
Program, visit http://www.epa.gov/WaterSense/product_search.html for the WaterSense labeled HET qualifying
product list.

4.	Flushometer type HETs must have an effective flush volume of 1.28 gallons or less as rated by MaP testing, visit
http://www.alliancefowaterefficiency.org/Maximum_Performance_(MaP)_Testing.aspx for the CommerciaI
Flushometer Valve/Bowl Combination Listing qualifying product list.

5.	Conversions to "Low Flow Toilets" (1.6 gallons per flush) do not qualify for a rebate.

6.	To receive the rebate, City of Santa Fe Water Division requires an original receipt.

7.	The completed application must be received no later than 90 days after purchase date.

1.	The program offers rebates for the retrofit of efficient technologies, and does not apply to purchases for new
construction and development.

2.	City of Santa Fe Water Division reserves the right to conduct inspections to verify installations of fixtures.

3.	Multi-family, mixed-use communities, home offices, and businesses operated out of the home are considered
residential customers for applicable rebates.

4.	City of Santa Fe Water Division does not warrant, endorse, or assume liability for the quality or performance of the
installed equipment related to purchase under this program.

5.	Applications will be processed until funds are depleted.

6.	City of Santa Fe Water Division reserves the right, at its sole and absolute discretion and at any time, to change any
or all of the Terms and Conditions for the rebate program or to cancel the rebate program without prior notice.

7.	Incomplete applications will not be processed. Do not mail application with utility payment.

8.	You will be required to repay the rebate if any of these terms and conditions is found to have been breached.

Rebate amount:

1.	The value of the high-efficiency toilet rebate is:

$175 Residential and Multi-Family HET
$125 Commercial Hotel/Motel HET
$250 Commercial Tank Type HET
$500 Commercial Flushometer Valve HET

2.	Rebate payments will be issued as a credit on the customer's utility bill for the installation address.

3.	Allow up to 90 days for your completed application to be processed and receive a credit.

For more information on this program, visit www.savewatersantafe.com, or contact the Water Conservation
Office at (505) 955-4225.

Submit to:

City of Santa Fe Water Division
HET Rebate
PO Box 909

Santa Fe, New Mexico 87504-0909

City of Santa Fe Water Division, Water Conservation Office, PO Box 909, Santa Fe, New Mexico 87504-0909
Phone: (505) 955-4225, www.savewatersantafe.com


-------
~) DENVER WATER

Residential Customer

3

Use Only What You Need
Tips & Tools

Your Water Consumption History
Water Use Rules & Regulations
Rebates

Residential Rebates
Commercial Rebates
FAQs

Qualifying Water Providers
Incentive Programs
Water Budget Program
Audits

Car Wash Certification Program
Conservation Plan
WaterSense

Soil Amendment Program
Xeriscape
Weather Reporting
Resource Links


-------
•	Home »

*	Conservation »

*	Rebates »

•	Commercial Rebates
Commercial Rebates

•	Rebate rules

•	WaterSense-labeled toilets: 1.28 gallons per flush (up to a $75 rebate); 1.0 gallon per flush or less (up to
a $150 rebate)

What is

WaterSense®?

• WaterSense-labeled high-efficiency urinal rebate (up to $100 each)

What is
WaterSense?

• Flushometer bowl and valve combination rebate (up to $125 per set)
o Bowl and valve must both be rated to flush 1.28 gallons per flush or less,
o Rebate applies to replacement of both the bowl and the valve,
o Retrofit kits are not eligible at this time.


-------
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LlSt Of LOCdl Retell I Stores* that stock or special order WaterSense toilets

This list of local retail stores is not inclusive and should not be considered an endorsement of retailers.

Alamo Ace

Alamo

925-837-2420

Manufacturer Customer Service



Albert Nahman Plumbing

Berkeley

510-843-6904

American Standard

1-800-442-1902

Ashby Lumber Co.

Berkeley

510-843-2225

Caroma

1-800-605-4218

Ehret Co.

Berkeley

510-528-4292

Crane

1-800-442-1902

University Plumbing & Hardware

Berkeley

510-848-2523

Duravit

1-888-387-2848

Baths & Kitchens 2000

Concord

925-671-9700

Eljer

1-800-442-1902

Heieck Supply

Concord

925-671-0800

Gerber

1-866-538-5536

Lowe's

Concord

925-566-9000

Kohler

1-888-783-7546

Ferguson Enterprises Inc.

Corte Madera

415-924-3200

Mansfield

1-877-850-3060

Olivero Plumbing

El Cerrito

510-233-3511

ProFlo (Ferguson)

1-800-221-3379

Cal Steam

Emeryville

510-594-0400

Toto

1-888-295-8134

The Lunt Marymore Co.

Emeryville

510-985-2889

Vortens-Lamosa

1-866-821-2811

Fairfax Lumber & Hardware

Fairfax

415-453-4410

Zurn

1-877-987-6669

Goodman Building Supply

Mill Valley

415-388-6233





Home Depot

Multiple Locations

800-466-3337





OSH Orchard Supply Hardware

Multiple Locations

888-746-7674





CTW Designs .

Novato ,

415-883-8861

Toilet Disposal Sites



Pini Ace Hardware

Novato

415-892-1577

Berkeley Transfer Station

1201 Second Street, Berkeley

American Emperor

Oakland

510-536-6868



510-981-7270

Foothill Hardware Inc.

Oakland

510-638-9317

Davis Street Transfer Station

2615 Davis Street, San Leandro

Globe Plumbing Supply Co.

Oakland

510-569-6566



510-638-2303

Granite Expo

Oakland

510-652-8882

Marin Resource Recovery

565 Jacoby Street, San Rafael

Jack London Kitchen & Bath Gallery

Oakland

510-832-2284

Center (MRRC)

415-485-5647

Meyer Plumbing Supply

Oakland

510-832-3324

Pleasanton Transfer Station

3110 Busch Road, Pleasanton

Moran Supply

Oakland

510-652-7437



925-846-2042

Reed Supply Co.

Oakland

510-436-7171

Republic Service Vasco Road

4001 N. Vasco Road, Livermore

Rubenstein Supply Co.

Oakland/San Rafael

510-444-6614 / 415-454-1174

Landfill

925-447-0491

Sincere Plumbing and Hardware

Oakland

510-832-2838





Style Bath and Kitchen Inc.

Oakland

510-638-8818

The cost of disposing of an old toilet is about S10-

-40. EBMUD does not reimburse the



disposalfee.



Richert Lumber Co.

Pleasanton

925-846-5040



Valley Plumbing

Pleasanton

925-462-1639





New Century Kitchen & Bath

San Leandro

510-347-1818





Reed's Kitchen & Bath

San Leandro

510-352-2174





Jackson's Hardware

San Rafael

415-454-3740





Pace Supply Corp.

San Rafael

415-454-8282





Rafael Lumber

San Rafael

415-453-3043





WHCI Plumbing Supply Co.

Union City/Dublin

510-471-5757 / 925-999-1818





General Plumbing Supply Co.

Walnut Creek

925-939-4622





Leapfrog Plumbing

Walnut Creek

925-933-1245





• This list was compiled by recent visits and/or phone calls to individual stores. Any retail stores selling approved toilets that would like to be added should
contact EBMUD's Water Conservation Division at 1-866-403-2683.


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High-Efficiency Toilet Rebate Program Application

Complete application, print, and mail with original receipts) to:	A separate application must be submitted for each metered address.

EBMUD Water Conservation, P.O. Box 24055, MS 109, Oakland, CA 94623-1055	Restrictions apply. See Terms and Conditions for details.

PLEASE PRINT:

APPLICANT FIRST NAME 					 LAST NAME __					 	 _ 	

tB.MUD ACCOUNT NUMBER 						„				 _ 		PHONE

BUSINESS OR HOA NAME (IF APPLICABLE; 									 EMAIL

INSTALLATION ADDRESS 						_ CITY _	ZIP

NEW TOILET INFORMATION {If the information does not fit below, please attach a separate sheet of paper with the requested information.;

MAKEiSj AND MODEL NUMBERS INSTALLED 												_ _	 NUMBER OF REBATES REQUESTED

APARTMEN i NUMBER FOR MULI :-UN! I RESiDtN i lAL AND NUMBER OF IOILE TS INSTALLED IN EACH APARTMEN f (Attach additional sheet of paper, if necessary;

APT.	QTY.	I APT.	QTY.	I	APT. QTY.	I	APT. QTY.	I	APT. QTY.	|	APT. QTY.

OLD TOILET INFORMATION (This section must be completed for eligibility.!
NUMBER OF TOILETS AT INSTALLATION ADDRESS 				

PROVIDE i HE AGE IN YEARS OR THE DATE Or MANUFACTURE OF THE TOILET'S; BEING REPLACED. THIS IS SOMETIMES FOUND ON THE INSIDE SURFACE OF THE TOILET TANK OR UD.

OR, IF AGE IS UNKNOWN, REFER TO THE SECTION DETERMINING YOUR EXISTING TOILET'S FLUSH VOLUME AND INDICATE VOLUME HERE 								_		

CHECK PAYEE INFORMATION (required only when (he applicant does not pay the wafer oil
MAKE CHECK PAYABLE TO __					_		

MAIL CHECK TO 											_			 CITY 		__			_				 Zip 	

DISCLAIMER:

The undersigned expressly agrees that EBMUD may inspect all properties participating in the WaterSmart High-Efficiency Toilet Rebate Program; that EBMUD does not guarantee the performance of
any toilet; and that EBMUD does not warrant any toilet or installation to be free of defects; the quality of workmanship, or the suitability of the premises or the toilet for the installation. The
undersigned further agrees to defend, indemnify and hold harmless EBMUD, its directors, officers, agents, and employees, from and against any and all loss, damage, expense, claims suits and
liability, including attorneys fees arising out of or in any way connected with the toilet(s) and its (their) installation. Applicant has read, understands and agrees to the terms and conditions listed on
the WaterSense Toilet Rebate Program application. Applicant understands that installation of a qualifying high-efficiency toilet may not result in lower water bills. E8MUD reserves the right to add or remove
eligible high-efficiency toilets from the list or change the terms of the incentive offer at any time.

PLEASE REVIEW THE APPLICATION CHECKLIST (NEXT PAGE! BEFORE SIGNING THE APPLICATION.

I HAVE READ, UNDERSTAND AND AGREE TO THE TERMS AND CONDITIONS OF THIS REBATE PROGRAM.

SIGNATURE OF APPLICANT 			DATE

Official Use Only:	g(-£.

WCV:	Pending:		_	 Approved:			 QTY:

BY:	 Denied:		By:	 AMT:

4


-------
Determining Your Existing Toilet's Flush Volume

Application Checklist

~	Did you check that your old toilet meets
eligibility rules?

~	Did you enclose an original paid receipt
showing applicant's name and/or
installation address?

~	Is the toilet model number printed and
legible on the receipt?

(UPC and SKU #s accepted)

~	Is the EXACT MODEL NUMBER of the
toilet you purchased on the qualifying
WaterSense list of HETs?

~	Have you completely filled out &
signed the application form?

~	Did you include your water service
account number on the application?

~	Did you install your HET and mail in the
rebate application within 90 days

of purchase?

Mail application & receipt(s) to:

EBMUD
Water Conservation
P.O. Box 24055, MS 109
Oakland, CA 94623-1055


-------
Ground rock,texas

PURPOSE. PASSION. PROSPER!! Y.

Commercial Property Efficient Toilet Rebate
Application & Guidelines

QUALIFICATION:

•	Property must be a direct water customer of the City of Round Rock, in good standing.

•	Property must have been built prior to January 1, 2005.

•	New tank-type toilets must be WaterSense approved. The list is at www.epa.watersense

•	New flushometer toilets must be MaP tested; search list at www.map-testinR.com

•	Applications for toilets purchased prior to program start date of March 31, 2014, will be
denied.

APPLICATION PROCEDURE:

1.	A pre-inspection is not required. Proceed with purchase and installation of new equipment.

2.	When project is completed, submit application, signed agreement, and itemized receipts within 60-days of
installation.

3.	Submit a separate application for each water account, if applicable.

4.	You may be contacted to schedule a final inspection.

5.	The rebate check will be mailed 2-4 weeks after final inspection is completed.

APPLICANT INFORMATION: (please print clearly, otherwise application will be denied)

Property Name (on utility bill):	Water Account #:

Installation Address:	 Zip : _

Rebate Mailing Address (if different):	

Contact Person:	Title:	

Email:	 Phone#:	

PROPERTY INFORMATION

Type of property: J~]_Restaurant ~ Service Station ~ Office building ~ Church J~]_Retail ~ Apartments
~ School/Childcare ~ Medical Office ~ Hotel/Motel |~1 Other:	

Year property was built*:	 Total # of tank-type toilets:	 Total # of flush-valve toilets:	

*Qualifying properties must have been built before January 1, 2005.

# of Employees:	 Average # of Visitors/Day:	

TOILET INFORMATION

NewToilet(s) Brand Name & Model Number(s)**:	

**Qualifying toilet(s) must be WaterSense certified www.eoa.aov/watersense

Total # of tank-type toilets replaced:	 Total # flush-valve toilets replaced:	

Itemized Price of new toilet(s):	

Toilet(s) Installed by: ~ Property Staff D Contractor/Plumber D Other:	



CORR USE ONLY



Date received

Rebate Amount

Approved

Application #

Date Rebate Issued

Bv

Inspection Date

Acct # 20041200-5422

Finance Apvl. '






-------
Ground rock, texas

PURPOSE. PASSION PROSPERITY

COMMERCIAL TOILET REBATE PROGRAM AGREEMENT:

•	Program participant must be a direct water customer of the City of Round Rock in good
standing.

•	Property must have been built prior to January 1, 2005, to qualify for a rebate.

•	New tank-type toilets will only be approved from the EPA's WaterSense Certified efficient
toilets and must use 1.28 gallons per flush or less. Search list at: epa.gov/watersense Toilet
packaging is clearly marked with the WaterSense label.

•	New flushometer toilets (includes bowl and flush-valve) must be rated by MaP to qualify AND
use less than 1.28 gallons per flush. Search the MaP list for toilets meeting this criteria at http://www.map-
testing.com/downloads.html

•	Rebate applications for toilets purchased and installed prior to program start date of March 31, 2014, will be
denied.

•	Rebate amount is 50% of the cost of the toilet (not plumber costs or tax) up to a maximum of $100 per toilet, if

the toilet is purchased from a plumber or retailer with a Round Rock address. If the vendor has a non-Round
Rock address, the rebate amount will be 50% of the toilet cost, up to $50 per toilet.

•	Number of toilets rebated will not exceed the number of toilets at the property.

•	Total maximum rebate amount is $600 per water account. Irrigation-only accounts do not qualify for any
rebate.

•	A dated and itemized sales receipt must be submitted with the program application within 60-days of
installation date to qualify. Receipt must include date, name of business purchased from and address, toilet(s)
price, toilet brands, and model number.

•	The City does not endorse specific brands, nor is not responsible for the performance or repair of the new
equipment.

•	Program applicant is responsible for disposal of old toilet(s). Per state law they cannot be reused.

•	A final inspection may be conducted.

•	Rebate check will be mailed 2-4 weeks after completed application is processed and approved.

•	Rebates are available until funds have been expended. Program is subject to change or end without notice.
Check funding status at: www,roundrocktexas.aov/waterconservation or call 512-671-2872.

I have read and agree to the terms stated above. Signed:				 Date:	

SUBMIT COMPLETED APPLICATION & PURCHASE RECEIPT TO:

fax #512-218-5536,

mail: Water Conservation, 2008 Enterprise.Dr., Round Rock, TX 78664, or

email: iwoods(a)roundrocktexas.gov

QUESTIONS? Call Jessica Woods at 512-671-2872 or email jwoods(5)roundrocktexas.gov

City of Round Rock Commercial Toilet Rebate Application
FY 2014


-------
Comments on Draft Specification for
Flushometer-Valve Water Closets

WaterSense

Commenter: Peter DeMarco
Affiliation: The IAPMO Group
Comment Date: March 20, 2015

Email Attachment:

Topic: Scope and Objective

Comment:

(1)	It is suggested that section 1.0 be revised to better clarify that the specification
applies to both HETs and flushometer-valves.

(2)	Clarification and perhaps examples should be provided to clarify the meaning of
"Any other flushometer-valve technologies" in the last bullet point. This will assist
manufacturers, test labs and certifiers in determining the applicability of emerging
technologies to the scope of the specification.

Suggested Change (or Language):

1.0 Scope and Objective

This specification establishes the criteria for a high-efficiency flushometer-valve

water closet fixture and a high-efficiency flushometer-valve under the U.S.

Environmental Protection Agency's (EPA's) WaterSense program. It is applicable to:

•	Water closet fixtures that receive liquid and solid waste and use water
from a flushometer valve to convey the waste through a trap seal into a
gravity drainage system.

•	Single-flush flushometer valves that deliver water to water closet
fixtures.

•	Dual-flush flushometer valves that deliver water to water closet fixtures.

•	Any other flushometer-valve-type technologyies that serves the function
of a flushometer-valve. falls within the scope of ANSI/ASSE 1037, and
which meet these performance specifications.

The specification is designed to ensure both sustainable, efficient water use and a
high level of user satisfaction with flushing performance.

Topic: Section 2.0 Water Efficiency Criteria

Comment: Subsection 2.1 references an outdated standard title.

62

April 23, 2015


-------
WaterSense

Comments on Draft Specification for
Flushometer-Valve Water Closets

Rationale: Currently, Section 2.1 of the WaterSense Draft Specification for
Flushometer-Valve Water Closets references IAPMO/ANSI Z124.4 Plastic Plumbing
Fixtures. This standard was harmonized with CSA B45.5 in 2011 and is no longer
current.

Suggested Change (or Language): IAPMO recommends that in Section 2.1 EPA
reference CSA B45.5/IAPMO Z124 - Plastic Plumbing Fixtures.

Topic: Section 2.0 Water Efficiency Criteria

Comment: IAPMO strongly recommends that the specification contain a minimum
flush volume requirement.

Rationale: The PERC 1 study showed how flush volumes of 0.8 gpf (3.0 Lpf)
resulted in chaotic and highly inconsistent drainline transport results and a change in
how the waste test media moved in the test apparatus. This is a red flag that
drainline efficacy is at risk using flush volumes that low. We recommend that the
specification call for a minimum flush volume requirement of no less than 1.0 gpf (3.8
Lpf) for all flush levels, including the reduced flush on dual flush models.

Creating an incentive to design and market labeled toilets / or flushometer-valves
that flush less than 1.0 gpf (3.8 Lpf) severely risks high profile drainline blockage
failures in commercial buildings and the success of the specification.

Suggested Change (or Language):

2.0	Water Efficiency Criteria

2.1	Water consumption shall be tested in accordance with the following ANSI
standards as applicable: ASME A112.19.2/CSA B45.1 Ceramic Plumbing Fixtures,
ASME A112.19.3/CSA B45.4 Stainless Steel Plumbing Fixtures, or IAPMO/ANSI
Z 124.4 Plastic Plumbing Fixtures.1

2.1.1	The manufacturer shall specify a rated flush volume of the flushometer valve or
water closet fixture, which must be equal to or less than 1.28 gallons per flush (gpf)
(4.8 liters per flush [Lpf]). Flushometer-valves must also discharge 1.0 gallons per
flush (gpf) (3.8 Lpf) minimum when tested in accordance with the reguirements in

Z0.

2.1.2	The water consumption, determined through testing and when evaluated in
accordance with the sampling plan contained in the Code of Federal Regulations
(CFR) at 10 CFR 429.30, shall not exceed meet the rated flush volumes specified in
Section 2.1.1 and 2.1.2.

2.1.3	For flushometer valves with dual-flush capabilities, these maximum water
efficiency requirements shall apply to the full-flush mode.

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WaterSense

4.2 The flushometer valve must not exceed the rated meet the flush volume of water
requirements specified in Section 2.1.1 even if the primary actuator is maintained in
the flush position (i.e., device's primary actuator must be a non-hold-open design).

Topic: Section 3.0 General Water Closet Fixture Requirements

Comment: IAPMO suggests that testing of commercial HETs with multiple
flushometer-valves is not beneficial.

Rationale: As written, the draft specification includes a requirement to test water
closets with three different flushometer valves. In instances where additional testing
can significantly improve compliance confidence levels, additional testing is generally
helpful. However, in this instance, the additional testing will not significantly increase
compliance confidence levels and the additional testing will only serve to increase
costs. IAPMO recommends that this requirement be deleted.

Suggested Change (or Language):

3.0	General Water Closet Fixture Requirements

3.1	Except as otherwise indicated in this specification, ceramic water closet fixtures
must conform to applicable requirements in ASME A112.19.2/CSA B45.1 when
tested with representative flushometer valves from three different flushometer valve
manufacturers that have the same rated flush volume and that meet the
requirements of Sections 2.0, 4.0, and 5.0.

3.2	Except as otherwise indicated in this specification, stainless steel water closet
fixtures must conform to applicable requirements in ASME A112.19.3/CSA B45.4
when tested with representative flushometer valves from three different flushometer
valve manufacturers that have the same rated flush volume and meet the
requirements of Sections 2.0, 4.0, and 5.0.

3.3	Except as otherwise indicated in this specification, plastic water closet fixtures
must conform to applicable requirements in IAPMO/ANSI Z124.4 when tested with
representative flushometer valves from three different flushometer valve
manufacturers that have the same rated flush volume and that meet the
requirements of Sections 2.0, 4.0, and 5.0.

3.4	For water closet fixtures marked with a dual-consumption or consumption range
marking, as indicated in Section 6.1, the water closet fixture must also conform to
applicable requirements in ASME A112.19.2/CSA B45.1 and the flush performance
criteria identified in Section 5.0 of this specification when tested at the lowest flush
volume marked on the water closet fixture. The water closet fixture shall be tested
with representative flushometer valves from three different flushometer valve
manufacturers.

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WaterSense

Comments on Draft Specification for
Flushometer-Valve Water Closets

Topic: Section 3.0 General Water Closet Fixture Requirements

Comment: Subsection 3.3 references an outdated standard title.

Rationale: Currently, Section 3.3 of the WaterSense Draft Specification for
Flushometer-Valve Water Closets references IAPMO/ANSI Z124.4 Plastic Plumbing
Fixtures. This standard was harmonized with CSA B45.5 in 2011 and is no longer
current.

Suggested Change (or Language): Revise section 3.3 EPA to reference CSA
B45.5/IAPMO Z124 - Plastic Plumbing Fixtures.

Topic: Section 4.0 General Flushometer Valve Requirements

Comment: The wording of subsection 4.4 needs to be clarified.

Rationale: The Alliance supports the intent of Section 4.0. The non-adjustability of
flushometer-valves after installation is critical towards the realization of water saving
efficiencies throughout the life of the valve. We recommend the revision to the
verbiage in subsection 4.4 as shown below.

Suggested Change (or Language):

4.4 The manufacturer must attest that the flushometer valve shall be is designed
such that interchangeable replaceable repair or maintainable parts (e.g., pistons,
diaphragms, repair kits) are not intended to be interchangeable with parts that would
that are offered for sale by the manufacturer do not cause the device flushometer-
valve to exceed the maximum rated flush volume specified in Section 2.1.1.

Topic: Section 5.0 Flush Performance Criteria

Comment: IAPMO does not recommend requiring tests using the unwaxed paper
toilet seat cover media in called out in Sections 5.3 and 5.4.

Rationale: IAPMO is not aware of reports of performance problems with commercial
toilets involving paper toilet seat covers. Further, it is recognized that the
specification as written would allow manufacturers and test labs to procure unwaxed
paper toilet seat covers of various designs (other than length and width) and different
paper stocks. We are not aware of any testing that has been conducted to verify the
repeatability of the testing using the draft test procedure.

Suggested Change (or Language):

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WaterSense

Comments on Draft Specification for
Flushometer-Valve Water Closets

5.3	Flush performance testing for flushometer valves and water closet fixtures shall
be conducted in accordance with the waste extraction test protocol provided in
Section 7.10 of ASME A112.19.2/CSA B45.1.

§r&A—Test media used during the waste extraction test shall include one
unwaxed paper water closet seat cover. The seat cover must have a
width of 14.0 ±1.0 inches (356 ± 25 mm) and a length of 16.5 ±1.0
inches (419 ± 25 mm). The seat cover shall be included in the test media
spocifiod in Soction 7.10.2 of ASME A112.19.2/CSA B45.1.

5.3.2—Following	step "g" of the waste extraction test procedure in Section 7.10.3
of ASME A112.19.2/CSA B45.1, the following procedural step shall be
applied.

5.3.2.1 Immediately after adding crumpled toilet paper, freely drop one
unfolded, unwaxed water closet seat cover onto the fixture water
surface such that the center of the seat cover is approximately at
the center of the water surface.

5.3.3—After	completion of the procedural step identified in Section 5.3.2.1 of this
specification, the test protocol shall continue with step "h" of the waste
extraction test procedure in Section 7.10.3 of ASME A112.19.2/CSA
B45.1.

5.4	For flushometer valves with dual-flush capabilities, the following flush
performance criteria shall apply:

5.4.1	For the full-flush mode, the flush performance testing shall be conducted
in accordance with Section 5.3.

5.4.2	For the reduced-flush mode, flush performance testing shall be conducted
in accordance with Section 3.2.4 of ASME A112.19.14.

5.4.2.1	Test media used during the toilet paper test shall also include
one unwaxed paper water closet seat cover. The seat cover must
have a width of 14 .0 ± 1.0 inches (356 ± 25 mm) and a length of
16.5 ±1.0 inches (419 ± 25 mm).

5.4.2.2	Section 3.2.4.2 of ASME A112.19.U shall be modified as
follows:

"The four 2.0 to 3.0 inch (51 mm to 76 mm) balls of paper that
comply with paragraphs 3.2.4.1.1 and 3.2.4.1.2 shall be dropped
into the water directly above the well and shall be allowed to wet
out completely. Immediately after adding the balls of paper,
freely drop one unfolded, unwaxed water closet seat cover onto
the fixture water surface such that the center of the seat cover is
approximately at the center of the water surface. Within five

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Comments on Draft Specification for
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WaterSense

seconds of adding the seat cover, the bowl shall be flushed. This
procedure shall be repeated until three sets of data are
obtained. Note whether any paper or seat cover are left in the
bowl. Flush again and collect any paper or seat cover that
discharges from the outlet."

5.4.2.3—Section 3.2.4.3 of ASME A112.19.14 shall be modified as

follows: "No paper or seat cover shall remain in the well after
each initial flush."

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WaterSense

Comments on Draft Specification for
Flushometer-Valve Water Closets

Commenter: John Watson

Affiliation: Elkay

Comment Date: March 20, 2015

Email Attachment:

March 20, 2015

U.S. Environmental Protection Agency
Office of Water - WaterSense Program
1200 Pennsylvania Avenue N.W.
Washington, D.C. 20460
watersense-products@erq.com

Subject: Feedback on Draft Specification for Flushometer Valve Water Closets

Dear EPA Office of Water,

Thank you for the opportunity to provide feedback on the draft specification for
flushometer valve water closets. Outlined below are my comments that I trust you'll
consider before finalizing the document.

I'm concerned about the EPA's reputation and the impact this specification could have
on an otherwise successful WaterSense program. In my opinion, the risk is not worth
the reward; that is, the projected 20% savings by moving from 1.6 gpf to 1.28 gpf in a
commercial setting is not worth the potential negative impact that could result from such
a change. Instead, the EPA and the industry should focus their efforts on converting all
the existing 3.5 gpf and greater water consuming commercial flushing devices to 1.6 gpf
- the savings and impact of a plan like that will produce far greater water savings than
moving from 1.6 gpf to 1.28 gpf.

I recognize that it's likely the "train has already left the station" on this, but I urge you to
consider delaying implementation of this product specification until some additional
research on the topic of drain line carry is available; most noteworthy, that would be the
next phase of the PERC study being conducted by the industry. The first phase of the
PERC study produced some interesting information that in my view confirmed the use of
1.28 gpf devices for residential use, but it cautioned against using the data to make
additional decisions until further research could take place.

Here are some additional thoughts to consider:

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WaterSense

Comments on Draft Specification for
Flushometer-Valve Water Closets

1.	There is a general lack of evidence that moving to a 1.28 gpf flush volume is
acceptable in the commercial market. Moreover, based on the limited research
available, PERC has cautioned against using the data they've produced to make
any additional judgments. Additionally, as the EPA has already acknowledged,
there is far more water to be saved by replacing existing 3.5+ flushing devices
than by taking an additional 20% off today's 1.6 gpf devices - so our efforts
should be geared to replacing these older water consuming products.

2.	In additional to the available antidotal evidence, the industry has a general
concern with moving to a 1.28 gpf flush volume for commercial use. Having
some past experience in this area, I support this concern and can tell you that
systems in the commercial market present several challenges not found in the
residential market including, but not limited to, how the products are used
(frequency of use including periods of non-use), the items that are flushed and
the length of drain lines.

3.	As we look at the data that is available, I believe we can draw a conclusion that
as we lower the flush volumes we see a distinct correlation between flush volume
and drain line carry which is more critical to the commercial market where longer
drain runs are utilized. In many cases, this will present problems with drain line
blockage in the commercial market.

4.	If you insist on moving forward with this new specification, I suggest that you
leave the current 1.6/1.1 dual flush product in the specification for several
reasons; (1) the evidence that this product works in today's market, (2) it will
parallel the requirements in the existing WaterSense specification for tank type
toilets and (3) while it may not provide you with as much water savings as you'd
like to project (20%), it allows you the use of 1.6 gpf if necessary. Here again,
the minor additional savings obtained by using a 1.28 gpf (maximum) device is
simply not worth the risk.

5.	There is an incorrect reference made to a standard that should be corrected;
IAPMO/ANSI Z124.4 for Plastic Plumbing Fixtures should be referenced as CSA
B45.5/IAPMO Z124.

In summary, when you take all things into consideration, it hardly seems reasonable to
implement this high efficiency flushometer valve water closet specification at this time.
While I generally support the efforts of the WaterSense program, I feel that waiting until
some additional research information is available would be prudent; or perhaps you can
start the specification at 1.6 gpf and work towards 1.28 gpf as more evidence on the
performance of these devices becomes available.

Thank you again for the opportunity to provide feedback on the draft specification for
flushometer valve water closets. Should you have any questions on my feedback or
wish to discuss it with me, please don't hesitate to contact me.

Respectfully,

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WaterSense

Comments on Draft Specification for
Flushometer-Valve Water Closets

John Watson

Manager, Compliance & Sustainability

2222 Camden Court, Oak Brook, IL 60523 | (630) 574-8484 | elkay.com

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WaterSense

Comments on Draft Specification for
Flushometer-Valve Water Closets

Commenter: Daniel Gleiberman
Affiliation: Sloan Valve Company
Comment Date: March 23, 2015

Email Attachment:

Comment: This specification should utilize the exact same language and water
consumption/efficiency provisions for dual-flush water closets as the current EPA
WaterSense Tank-Type Specification. A wide variety of tank-type water closets
that incorporate different design options for the dual flush mechanism have been
third-party certified to both the ASME A112.19.14 standard and this EPA
WaterSense Specification. While there may be some that feel that buttons work
better than levers or vice versa, or that a particular design is more intuitive to the
user, there is no discrimination against any design that meets the requirements
of the national consensus standard and the EPA WaterSense specification.

Rationale: While EPA WaterSense in both the NOI and the supporting statement
for this draft specification indicates that water savings are "largely based on
...design considerations", the fact is that the referenced standard for these types
of water closets requires proper identification of the flush mode options, or shall
be "intuitively apparent." Therefore, EPA has already acknowledged through the
adoption of the Tank-Type specification which references this standard that there
is a wide variety of designs for these types of water closets and all of these are
acceptable. (Pictorial examples taken from a random Internet search follow this
discussion.) For this flushometers valve specification, EPA is correct to reference
this same standard (ASME A112.19.14) but they should also include the water
efficiency criteria already established in the Tank-Type Specification. It is not
appropriate for EPA to single out one particular design and to utilize a single
study on that design to arrive at this discrepancy. In exactly the same manner
that EPA WaterSense allows for a wide variety of designs for dual flush tank type
water closets that meet the specification to be certified, EPA should include the
full options in this specification. Examples of other dual flush flushometers
designs are included below.

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F. PA

Comments on Draft Specification for
Flushometer-Valve Water Closets

WaterSense

ASME A112.19.14

SIX-LITER WATER CLOSETS EQUIPPED WITH A
DUAL FLUSHING DEVICE

1 GENERAL

1.1 Scope

This Standard establishes physical, material, testing,
and marking requirements for 6 L water closets that
incorporate a water-conserving, dual-flushing feature
into the fixture. The tests specified in this Standard are
for the removal of liquid wastes and toilet tissue or
other comparable waste loads that are expected when
actuating the reduced flush feature of the unit.

4 MARKING

4.1 Identification of Flush Mode Options

Identification of flush mode options shall be depicted
on the actuator. This identification shall be either by
graphic display or lettering, or shall be intuitively
apparent.

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cr«

WaterSense

Comments on Draft Specification for
Flushometer-Valve Water Closets

VARIOUS EXISTING DESIGN CONFIGURATIONS FOR DUAL FLUSH

WATER CLOSETS

TANK-TYPE WATER CLOSETS





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4

EPA

WaterSense

Comments on Draft Specification for
Flushometer-Valve Water Closets

DUAL ACTION HANDLE

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HALF FLUSH

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wat** tar Rqufet waster

FULL FLUSH

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4

EPA

WaterSense

Comments on Draft Specification for
Flushometer-Valve Water Closets

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4

epa	Comments on Draft Specification for

WaterSense	Flushometer-Valve Water Closets

FLUSHOMETER VALVES

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VVaterSense

Comments on Draft Specification for
Flushometer-Valve Water Closets

V

I



l	I



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WaterSense

Comments on Draft Specification for
Flushometer-Valve Water Closets

Commenter: Dave Bracciano
Affiliation: Tampa Bay Water
Comment Date: March 25, 2015

Email Text:

I am in support of the WaterSense decision to develop a specification for flushometer-
valve toilets and flushometer-valves. I do recommend that consideration be given to
insure flush volume requirements meet the intent of moving solid waste through the
collection system as designed. Of course consideration should be given to pertinent
research on the topic.

Topic: Section 3.0 General Water Closet Fixture Requirements

Comment: Testing of commercial HETs with multiple flushometer-valves is not
beneficial.

Rationale: As written, the draft specification includes a requirement to test water
closets with three different flushometer valves. In instances where additional testing can
significantly improve compliance confidence levels, additional testing is generally
helpful. However, if the additional testing will not significantly increase compliance
confidence levels and the additional testing will only serve to increase costs then it
should be deleted.

Topic: Section 4.0 General Flushometer Valve Requirements

Comment: The wording of subsection 4.4 needs to be clarified.

Rationale: I support the intent of Section 4.0. The non-adjustability of flushometer-
valves after installation is critical towards the realization of water saving efficiencies
throughout the life of the valve. The language in subsection 4.4 should be revised as
shown below.

Suggested Change (or Language):

4.4 The manufacturer shall provide documentation with the product that details a list of
replacement parts that will maintain the rated flush volume specified in Section 2.1.1.

Dave Bracciano

Demand Management Coordinator
Tampa Bay Water
2575 Enterprise Road
Clearwater, FL 33763

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Comments on Draft Specification for
Flushometer-Valve Water Closets

ph: 727-791-2313
cell: 813-3341723

www.tampabaywater.org

4

EPA

WaterSense

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