EPA
Water Sense
Comments on WaterSense® Notice of
Intent (NOI) to Develop a Draft Specification
for Landscape Irrigation Sprinklers
November 19, 2015
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WaterSense
Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Landscape Irrigation Sprinklers
Table of Contents
Karen Guz, San Antonio Water System 3
John Ossa, Rain Bird Corporation 14
John R. Farner, Jr., Irrigation Association 18
Seth Ostrowski, Sprinkler Flow Control 21
Adam Carpenter, American Waterworks Association 23
Jeffrey Hughes/Mary Ann Dickinson, Alliance for Water Efficiency 28
Sue McGuire, Unaffiliated 34
James Canyon, Digital Spring, LLC 35
Sandra Cannon, U.S. Department of Energy Sustainable Acquisition Program 36
Antonio Fernandez, Harvard School Dental Medicine 37
Jorge Manuel Mustonen Morel, Unaffiliated 38
Tom Reynolds, Water Balance 39
Edward Norum, CSU Fresca, Center for Irrigation Technology 40
Kinzea Thompson, Unaffiliated 41
Brian Shiffman, Unaffiliated 42
JohnTexeira, Unaffiliated 43
Keith Murr, Unaffiliated 44
Angelo N. Ververis, Unaffiliated 45
Greg Walsh, Unaffiliated 46
Mary Crocker, Unaffiliated 47
Ken Mauser, Aquatrols Corporation 48
James Johnson, Healthy Efficient Homes, LLC 49
Kerry Frost, Unaffiliated 50
Doris Wright, Unaffiliated 51
John Mitchell, Siphonaid/Siphon Priming Device 52
Greg Chick, Green Plumbers 53
Lucas Mouttet, Fort Collins Utilities 54
November 19, 2015
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EPA
Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Landscape Irrigation Sprinklers
WaterSense
Commenter: Karen Guz
Affiliation: San Antonio Water System
Comment Date: September 18, 2014
Email Attachment: WaterSense NOI CommentSAWS.pdf
Dear Sir or Madam:
San Antonio Water System (SAWS) would like to thank EPA for the opportunity to
comment on its WaterSense Notice of Intent (NOI) to Develop a Draft Specification for
Landscape Irrigation Sprinklers. SAWS is a water and wastewater provider serving over
1.6 million customers in South Central Texas. SAWS has been an avid supporter of the
EPA WaterSense program and has cited the program in San Antonio indoor efficiency
codes that require EPA WaterSense fixtures in new construction.
Technology Retrofits Will Not Save Water Without Water Management
Focus
While the EPA WaterSense approach to indoor technologies has been highly successful,
we have concerns about a similar labeling process for irrigation technologies. The
weather-based irrigation controllers that have already received a WaterSense label must
be used extremely carefully with exceptionally high water users to deliver their potential
savings. The 2013 Residential End Use Study (REUS), conducted in nine diverse
locations, notes that if all study homes were brought up to the theoretical landscape
budget by technology like a weather-based irrigation controller, the net effect would be a
significant increase in water consumption. This is because the majority of homes, in fact
82 percent of the study homes in the nine cities, water less generously than the
theoretical requirement built into the technology. The updated RUES illustrates how
variations in personal habits associated with outdoor water use make it complex to
achieve reductions. The number of toilet flushes, number of personal showers, and time
using faucets are fairly predictable in most indoor settings. How much individuals believe
is appropriate to add supplemental water to landscapes is not easy to predict.
The SAWS conservation department has a long history of working with residential and
commercial customers to help them decrease their discretionary landscape water usage.
The greatest savings we have achieved have not come from changing the irrigation
technology used, but rather from increasing the personal management of the water use
at the site. This usually has required enhanced personal understanding of the landscape
and its needs combined with careful human monitoring of the irrigation system settings.
We have also deployed a variety of technologies to achieve efficiency in how water is
applied to landscapes. The results from these efforts has been erratic with extreme
fluctuations in success or failure that appear to be dependent upon how carefully the site
manager or home owner adheres to irrigation setting advice. It has been startling that in
some retrofit circumstances, particularly in commercial settings, water use increases
after the seemingly more efficient technology has been deployed. (A brief program
review of a multi-stream nozzle retrofit rebate has been attached that provides a more
detailed example.) Every review of landscape irrigation program data reminds us again
that we cannot succeed in achieving long-term savings without a strong focus on
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EPA
Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Landscape Irrigation Sprinklers
WaterSense
motivating someone to function as a water manager. Even technologies designed to aid
in water management tracking fail if a person is not motivated to respond to the data
from them.
Discretionary water used on landscapes accounts for 20 to 40 percent of the municipal
water used in Texas and for similar percentages of water sold in other urban areas.
Patterns in discretionary use are particularly concerning because increases in irrigation
use in new homes often overwhelms the savings achieved through efficient indoor
practices. While this is a growing problem, there is not an easy to way to achieve water-
efficient landscaping practices and landscape designs. We applaud the EPA
WaterSense program for engaging with this challenge and hope that the approaches will
be more nuanced and that ample research will be conducted before any additional
irrigation products receive labeling.
Community planners, water utilities and elected officials are looking for answers to the
discretionary water use challenge. Systemic design and management is hard. A retrofit
to a specific technology is easier to deploy and manage but may be completely
ineffective. It is important that highly regarded programs like EPA WaterSense avoid
distractions from real solutions by giving the impression that a simple change in
technology will solve the problem. Integrated water management with site managers
actively watching consumption patterns must be emphasized to achieve success.
What Does Work to Save Landscape Irrigation Water?
What SAWS has learned from our experiences is that there is no substitute for having a
person concerned with the monthly water consumption and focused on how much water
is flowing through the irrigation system. A technology retrofit sometimes seems to create
a false sense of conservation success, which leads to increased water use. Even
conversions to drip irrigation can go terribly wrong if there is not vigilant water
management at a site. It is difficult to overstate the importance of water management
follow-through post-retrofit in order to achieve landscape irrigation savings. We hope that
the EPA WaterSense program can help emphasize water management as the most
important tool as part of their education programs.
Updating Assumptions About Landscape Water Use
There is an unfortunate assumption in landscape water planning that all landscape plant
material should be provided an ideal amount of water to optimize growth and health. The
models used to calculate these ideal amounts are derived from crop sciences used to
improve crop yields for food production. While the principles of the science are sound,
the assumption that all site managers desire an optimized plant growth for an aesthetic
landscape is flawed. Data does not support that most site managers apply these
relatively generous water quantities to their aesthetic plants.
The updated 2012 REUS research makes it clear that the majority of homeowners do
not water their landscapes to the theoretical landscape water budgets that are commonly
deployed to predict landscape water usage. Over 80 percent of homeowners have
consumption patterns significantly lower than the predicted amount and a very small
percentage use more than the predicted amount. It is concerning that the majority who
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Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Landscape Irrigation Sprinklers
WaterSense
are careful with their use are described as practicing "deficit irrigation." This negative
term implies that this practice is somehow flawed and perhaps should be corrected to
increase water usage.
Perhaps instead of describing the more moderate discretionary usage a "deficit" it should
be recognized as normal or sustainable.
The patterns of water use seem to indicate that many site managers and home owners
are satisfied using quite moderate amounts of supplemental water. This is logical
because many aesthetic landscape plants are capable of thriving and looking attractive
without receiving the theoretical ideal amount of supplemental water. Studies on how to
manage more landscapes with moderate amounts of water should be a focus. This is not
to suggest that there should never be supplemental water application to aesthetic
landscapes, but that perhaps it is time to reconsider some of the long-standing
assumptions about landscape water use patterns.
What About Better Irrigation Technology?
The issues that SAWS has raised are not meant to imply that improved irrigation
technology is unimportant. However, the technology alternatives need to be put into
perspective with water management and have very careful vetting to ensure that they do
achieve significant reductions when used by customers. Because education on water
management often is (and should be) included with retrofit programs it is important to
assess how much additional savings the technology achieves apart from the education.
This requires a study with a control group receiving only the education on water
management as well as a group receiving both the education and retrofit. We hope that
a study on pressure controlled nozzles will be conducted because there does not yet
seem to be compelling evidence that a retrofit to these nozzles will achieve savings. If a
study can confirm savings apart from education, the data would be helpful as utilities
consider incentive programs that are based on the quantity of water savings achieved.
Responses to Specific EPA Questions Within the NOI
1. Is the proposal of labeling nozzles and bodies separately appropriate for this product
If the EPA moves forward with this product labeling strategy, it is best to provide the label
separately.
2. Regarding the performance measure for high-efficiency nozzles, is the top-tier
approach or increase-from-baseline approach more appropriate for identifying the
performance threshold forDU?
There is an inherent assumption in this question that improvement in DU will
automatically yield lower water use at a site. In the early days of conservation programs
aimed at efficiency for landscape, this assumption was built into many programs. In light
of program evaluation and studies from the University of Florida, this assumption has
been questioned. Aesthetic plants, particularly xeric ones, have extensive root systems
capable of gathering water from a broad area. In addition water moves through soil
category?
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Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Landscape Irrigation Sprinklers
WaterSense
horizontally, as well as vertically after application. For this reason, being focused on
perfectly uniform application is perhaps just one consideration in quality irrigation design
but not the overall focus on achieving reductions at a site. This needs further study.
3. Regarding pressure regulation, is a sprinkler's ability to maintain a constant outlet
pressure over a range of inlet pressures an appropriate measure of performance for
pressure-regulating spray bodies? Is it appropriate to include a performance
measure that specifies the sprinkler body's ability to decrease flow when a nozzle is
damaged or missing?
One of the exciting aspects of many of the pressure control nozzles is their ability to
reduce waste from missing nozzles on irrigation heads. After years of monitoring
irrigation systems for waste, the staff at SAWS can confidently make this statement
"irrigation systems break and need constant maintenance." This is not a surprise. Water
flows through irrigation pipes with variable pressure, and lawn equipment is harsh if
heads do not drop all the way down after an irrigation cycle. The "geysers" from broken
or missing nozzles are a significant source of waste. It would be good to include some
way to measure this savings as one of the reasons to suggest this is a better product
than traditional ones.
4. Is the required orifice flow rate of 1.5 gpm in the ASABE/ICC test method for
pressure regulation adequate to characterize the performance of a family of sprinkler
nozzles that covers a range of wetted radii and patterns?
Irrigation heads have a different gallons per minute depending upon their radius of throw
and other factors. It seems limiting to focus only on 1.5 gpm.
Conclusion
We urge the EPA WaterSense program to pause and engage in further research
regarding what ways implementation of any irrigation technology is best accomplished to
achieve savings. Theoretical models of what savings "should" occur are not sufficient no
matter how firm the science seems. Retrofit studies that include education and
monitoring, as well as some that do not are needed to separate the issue of how much
taking "control of the controller" achieves savings versus the deployment of the
technology. We cannot justify expensive retrofits as essentially loss leader efforts that
help us get to the irrigation controller and the site manager. It is important to confirm how
much savings come from each aspect of the effort.
Please contact me with any questions about these comments. SAWS appreciates the
opportunity to engage with the EPA WaterSense program.
Karen Guz, Conservation Director, San Antonio Water System, (210) 233-3671
November 19, 2015
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Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Landscape Irrigation Sprinklers
WaterSense
EMAIL A TTACHMENT: SA WSmultistreamnozzleDroaramreview07052014.Ddf
Program Review—Multi-Stream Nozzle Rebate
Program Description
Irrigation Design Rebate
The initial template for the Irrigation Design Rebate was modeled after an existing
Landscape Rebate program that is no longer in practice. Participation in the program
was limited to San Antonio Water System (SAWS) residential and commercial
customers, and the total rebate disbursement was uniquely contingent upon whether the
system consumption was less than the calculated watering recommendation at each site
for the evaluation period of 12 months. Irrigation consultations conducted by SAWS
licensed irrigators were required before implementing the multi-stream rotor retrofit in
order to identify system consumption and to provide landscape irrigation management
education.
As a performance-based rebate program, a specified percentage of the rebate amount
was issued initially, while the remainder was issued upon completion of the requirements
of the rebate program. These conditions were presented and agreed to by the program
participants at the time of application. Initially, the rebate was set to disburse 25 percent
upon completion of the retrofit, and 75 percent upon completion of the evaluation period
and confirmation that the retrofit achieved an identifiable reduction in water consumption.
This schedule was adjusted in 2013 to disburse 50 percent upfront, and 50 percent upon
completion, in order to encourage greater participation in the program. The processes to
determine rebate amount and program success are laid out below.
In order to maintain communication, and as a courtesy, monthly emails were sent to
program participants for each site as a reminder of the calculated monthly water
recommendation, and how those calculations compared to their actual usage during the
month. The process for calculating the watering recommendation is outlined below.
Calculating a Monthly Water Recommendation
As a first step to measuring program success, a monthly landscape watering
recommendation was calculated for each site using a modified Water Use Classifications
of Landscape Species (WUCOLS) method. This method was chosen because it is more
concise than other methods and does not require a large amount of detail. Potential
evapotranspiration (ET0), factors for species (ks) and microclimate (kmc) to calculate the
landscape coefficient (Kl), and effective monthly rainfall amounts (ER) were required for
calculation. The formulas used for calculating the water recommendation are as follows:
There is a plant density factor (kd) included in the WUCOLS calculation of landscape
(1) Kl — ks X kmc
(2) Recommendation = (ET0 x KL) - ER
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Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Landscape Irrigation Sprinklers
WaterSense
coefficients, but it was concluded that the difference in plant densities is not a limiting
factor in this region and therefore does not affect results.
Average potential evapotranspiration in inches per month was collected from the
TexasET Network as a function of the Penman-Monteith equation using local weather
station data. The species coefficient was assumed to be a standard 0.6 for warm season
grasses as appropriate for the region. Seasonal coefficients were based on season and
type of cover. For turf during most months of the year, 0.6 was used. For beds, a
coefficient of 0.3 for woody perennials was used for all monthly calculations. The bed
coefficient was determined by Mark Peterson of SAWS based on reviews of existing
literature independent of the WUCOLS method. The effective rainfall range used is a
minimum of 0.2 inches to a maximum of one inch. This is based on SAWS determination
of local soil types and conditions, which is typically assumed to be six inches of clay
loam soil at which anything over one inch of rainfall is assumed to saturate the soil,
resulting in runoff and higher evaporative rates. According to the TexasET Network and
as a result of the lack of user supplied effective rainfall estimates, the first one-tenth of
an inch is assumed to be lost to evaporation, one-fifth to one inch is given full credit, and
any amounts from one to two inches are likely lost to runoff or deep percolation.
Identifying Actual Usage
The second step in assuring the rebate requirements are met is determining actual
irrigation consumption. Residential systems measure indoor and outdoor usage on the
same meter, so the following calculation is used to get irrigation consumption:
Average indoor residential usage is assumed to be 6,000 gallons or 802 cubic feet,
which is consistent with the SAWS winter average consumption. Commercial systems
include separate meters for indoor and irrigation uses, so the actual irrigation meter
reading is used for these sites.
Determination of Success
The monitoring period of 12 months was initiated following the irrigation consultation and
site-specific retrofit installation date. For both residential and commercial properties, the
same test was applied to determine if the property passed or failed the program
requirements. The aggregate total outdoor water use was required to be less than the
aggregate calculated water recommendation.
Savings Expectations
It is the expectation that rebate programs serve to incentivize customers to become
engaged in conservation efforts, and they allow SAWS licensed irrigators to gain access
to irrigation controllers, in the form of required consultations, to make sure schedules are
set correctly, and systems are watering efficiently.
Upon development of this program, rebate amounts were determined to be 25 to 30
percent of industry standard costs for materials and labor. The rebate amount offered
November 19, 2015 8
(3) Outdoor Usage = Meter Reading - Indoor Usage
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EPA
Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Landscape Irrigation Sprinklers
WaterSense
was initially $50 per zone up to $400 for residential and $3,200 for commercial
customers, but to attract additional participation, the rebate offer was increased in 2013
to $100 per zone, not to exceed $800 for residential and $6,000 for commercial
customers.
Results of Water Recommendation Calculations Versus Actual Water
Applied On Site
Residential customers were more successful at staying within the expected landscape
water recommendation than commercial customers. While 77 percent of residential
customers were awarded their full rebate at the end of the 12-month period, only 8.3
percent of commercial customers were awarded their full rebate. The water
recommendation methodology considered variables such as weather, while a secondary
analysis examined whether customers made net decreases in landscape irrigation use.
Post Retrofit Water Consumption Changes
The following figures illustrate the change in consumption from the 12-month periods
prior to and following the multi-stream nozzle retrofit. There were 12 commercial and 16
residential properties evaluated. The blue lines show the amount of water in gallons that
each commercial and residential property either reduced or increased their consumption.
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WaterSense
Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Landscape Irrigation Sprinklers
In Figure 1, the red line shows the percentage reduction or increase in consumption
amount as compared to the 12-month period prior to the retrofit with consultation at each
site. The green line represents the average yearly savings for all sites evaluated
following the multi-stream retrofit with consultation. On average, the commercial sites
increased their usage by 81,855 gallons.
Figure 1. Change in consumption as collected for 12 commercial customers who participated in the irrigation
design rebate program for a multi-stream nozzle retrofit.
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Comments on WaterSense®
epa Notice of Intent (NOI) to Develop a Draft
WaterSense Specification for Landscape Irrigation Sprinklers
Residential consumption was significantly reduced after the retrofit was completed.
However, water use is typically reduced significantly as a result of residential
conservation consultations that focus on irrigation system management. The red line in
Figure 2 represents the average yearly water savings at a site where an irrigation
consultation performed by a SAWS licensed irrigator was the sole conservation effort.
This data is a department metric for residential sites only, and shows an average yearly
savings of 24,000 gallons. The green line represents the average yearly water savings of
30,066 gallons for the 16 residential sites used for this evaluation. The difference in
average savings of consultations only and multi-stream retrofit with a consultation is
6,066 gallons a year.
<0
OO
c
o
40,000
30,000
20,000
10,000
0
a. -10,000
E
3
c -20,000
O
(J
-30,000
0)
W)
re -40,000
-Ł¦ -50,000
-60,000
-70,000
-80,000
-90,000
Residential Consumption Change
¦ Retrofit with Consults
Avg for Retrofit & Consult (-30,066) Avg for Consults Only (-24,000)
30,671
1,496
RA RB RC RD RE RF RG RH Rl RJ RK RM RN RO RP
¦5,235
AS,227
z
¦20,199
-27,680
-36,659 ."35,162
-77,830
-81,544
Property
Figure 2. Change in consumption as collected for 16 residential customers who participated in the
irrigation design rebate program for a multi-stream nozzle retrofit.
Comparison to Education Consultations
Using the average rebate amount per residential property ($288.28) and the difference in
average yearly residential water savings over a 10-year life (60,660 gallons or 0.186
acre-feet), the cost per acre-foot of water saved is determined to be $1,549.
November 19, 2015
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EPA
Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Landscape Irrigation Sprinklers
WaterSense
There was a net increase in commercial site water use following the retrofits and a fairly
high rate of failure to meet water recommendation expectations. Additionally,
independent variables at each commercial site prevented the determination of a relevant
average savings for consultations only. For this reason, there is not a cost per acre-foot
estimation for the commercial retrofits.
Preliminary Conclusion
Multi-stream nozzles reduce the rate at which water is applied to the irrigated area, so
this change will require an increase in run time. The increase in run time should not
increase the total consumption at a site because of improved distribution uniformity and
reduced loss from evaporation. There should be a net decrease in water use. It is
challenging to explain why this did not occur at commercial sites.
The significant increase in consumption at commercial properties may be attributed to
the control of the irrigation systems relying solely on contracted licensed irrigators. In an
attempt to increase the aesthetic value to a commercial property, it can be inferred that
the contracted irrigators may be increasing run times even more than required by the
retrofit alone. The irrigation settings for commercial sites were discussed with contracted
irrigators for each site, but SAWS staff did not directly manage or change commercial
irrigation controllers.
Residential participants were receptive to suggested irrigation controller settings
provided by SAWS consultants and are usually pleased to have these settings put in
place by SAWS staff. The residential customers may have succeeded in saving water
because they did not change these settings.
It is important to note that the evaluation periods for commercial and residential sites
were not the same. The large majority of commercial sites installed the retrofit in the fall
of 2010, and extreme drought conditions in 2011 could have influenced the increase in
consumption during the 12-month evaluation period. Of the residential sites evaluated,
there were a few install dates in each year from 2010 to 2013. However, there were no
distinct trends present for changes consumption at these sites when compared by year.
The cost of the additional water saved at residential properties due to the multi-stream
retrofit, excluding the savings from consultations only, is very high at $1,549 per acre-
foot. The approved rate of savings for peak water is $1,100 per acre-foot. The program
was discontinued during review because there were not apparent savings at commercial
sites and only modest savings at residential sites.
If the total savings per site (retrofit with consultation) is combined, then the cost per acre-
foot improves. The cost of a consultation service is approximately $155 making the total
cost $443.28 with the average rebate amount included. The cost per acre-foot for the
combined retrofit with consultation is $480.78, which is well within the approved metric
for programs. The question is whether or not the consultation service would have
occurred without the retrofit since the cost per acre-foot for consultations alone is only
$209. There is currently a strong waiting list for consultation services during summer
months and marketing efforts for consultations are hampered by limits in scheduling. For
these reasons, it does not appear to be necessary to offer a special rebate in order to
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Comments on WaterSense®
epa Notice of Intent (NOI) to Develop a Draft
WaterSense Specification for Landscape Irrigation Sprinklers
entice customers into a consultation service. The nozzle rebate will be reviewed to
determine if outcomes can be improved.
November 19, 2015
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Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Landscape Irrigation Sprinklers
WaterSense
Commenter: John Ossa
Affiliation: Rain Bird Corporation
Comment Date: July 25, 2014
Email Text:
From: Ossa, John MAIL TBA rmailto:JOssa@rainbird.coml
Sent: Friday, July 25, 2014 3:46 PM
To: Tanner, Stephanie
Cc: Ossa, John MAIL TBA
Subject: Rain Bird Position - Sprinkler Standard NOI
Stephanie,
Rain Bird was happy to participate in the process that AWE initiated to provide
WaterSense feedback on the Sprinkler Standard NOI.
We also felt it was appropriate to provide a direct response to WaterSense. Attached
please find our position statement.
If you have any questions, please don't hesitate to contact me.
Regards,
John
John Ossa, CID, CLIA
Public Agency Account Manager
Rain Bird Corporation
6991 E. Southpoint Rd.
Tucson, AZ 85756
(415) 378-8404 mobile
iossa@rainbird.com
Specification Hotline (800) 458-3005
SpecHotline@rainbird.com
www.Rainbird.com
Residence: Mill Valley
EMAIL ATTACHMENT:
Date: July 25, 2014
To: Stephanie Tanner
From: John Ossa
Re: Rain Bird Response to EPA WaterSense Sprinkler Standard NOI
November 19, 2015
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Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Landscape Irrigation Sprinklers
WaterSense
Rain Bird supports WaterSense initiatives that seek to "raise the bar" on landscape
water use efficiency. We believe the industry and markets will be well served if all
products delivered agreed upon thresholds of operating performance. Government
mandates and guidelines, as well as locally derived standards and codes, can drive the
change that is needed in products and behaviors associated with water waste.
Performance thresholds need science-based metrics that not only take into account
individual component metrics, but also system metrics that encompass product
capability and system management.
Irrigation system performance is the result of four elements. Proper irrigation design,
conscientious installation, diligent system maintenance that supports the design intent
and knowledgeable system management. Of the four elements, system management
can have the most profoundly negative impact in terms of water waste, plant failure and
site degradation. The mere presence of great hardware and technology does not
guarantee anything.
In addition to developing specifications for irrigation hardware, we recommend
WaterSense consider the following area of focus: Encourage interactive partnerships
between water purveyor, the green industry, and property owners for the purpose of
developing and implementing science based water budgets for landscapes that ensure
compliance with local water use mandates.
Since Rain Bird's beginnings in 1933, we have focused on developing products and
technologies the enable the use of water in the most efficient manner possible. We
communicate our history and commitment to a stewardship ethic, innovation and quality
in the phrase The Intelligent Use of Water. Rain Bird developed in-head pressure
regulation and check valves in the 1980's. While we know that in-head pressure
regulation as a single feature creates a significant opportunity to reduce water use, and
only costs a small fraction more than the same device without that feature, to date there
has not been a robust market for this technology.
Irrigation hardware and technology have evolved tremendously in recent years. An
explosion of new technology, as well as invigoration of markets for existing water
conserving hardware have been a direct consequence of market dynamics driven by
water availability and escalating water pricing.
Rain Bird is aligned with the goals of the WaterSense NOI and will continue to lead a
market transformation with products and technologies that preserve and protect water
resources.
The WaterSense NOI to Develop a Draft Specification for Landscape Irrigation
Sprinklers. Version 1.0 dated May 22, 2014, contains four specific questions. What
follows is our response to those questions.
1. Is the proposal of labeling nozzles and bodies separately appropriate for this product
category?
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Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Landscape Irrigation Sprinklers
WaterSense
2. Regarding the performance measure for high-efficiency nozzles, is the top-tier
approach or increase-from-baseline approach more appropriate for identifying the
performance threshold for DU?
3. Regarding pressure regulation, is a sprinkler's ability to maintain a constant outlet
pressure over a range of inlet pressures an appropriate measure of performance for
pressure-regulating spray bodies? Is it appropriate to include a performance
measure that specifies the sprinkler body's ability to decrease flow when a nozzle is
damaged or missing?
4. Is the required orifice flow rate of 1.5 gpm in the ASABE/ICC test method for
pressure regulation adequate to characterize the performance of a family of sprinkler
nozzles that covers a range of wetted radii and patterns?
Rain Bird Response
1. Yes. Nozzles and pressure-regulating sprinkler bodies are two different technologies
that should be considered separately.
Pressure and regulated pressure are key variables that drive nozzle performance.
Establishing performance metrics, testing protocols, and accepted ranges of
performance for pressure regulation is best done separate from developing nozzle
criteria. Conducting simultaneous testing and specification development will undermine
the ability to isolate variables and determine how they affect system performance.
2. A theoretical relationship does exist between DU and water savings. It is true that
one should expect that as DU increases there could be potential water savings via
less run time. However, other nozzle design factors can negate the potential water
savings of improved DU. The top-tier and increase-from-baseline can help indicate
some relative nozzle performance; however utilizing a single metric, DU alone—fails
to capture all the nozzle characteristics that lead to overall system efficiency.
Water savings are the sum of numerous variables being managed in a dynamic
system. At minimum, key variables include operating pressure, spacing, wind,
product age, water quality, soil-plant-water interaction, site maintenance, and
perhaps most important—system management. The effects of poor system
management (scheduling) easily undermine the potential for efficiency represented
by optimized hardware and system design. Maintaining a constant and optimum
outlet pressure is a desired objective in sprinkler and nozzle performance. Optimum
pressure ensures the nozzle will deliver the highest uniformity of application possible
for that device. Optimized uniformity combined with science based scheduling
creates desired system efficiency.
Crafting testing protocols to adequately address a great range of dynamic variables
is complex. During system operation water pressures may spike, drop and rise
again—all at frequencies and durations that may not repeat. Testing over a range of
inlet pressures is most important.
Including a performance measure that specifies a sprinkler's ability to decrease flow
when a nozzle is damaged is a desirable objective. Clarifying the distinction between
what constitutes "minor damage" and the conditions that would release the
expectation of performance (destroyed) is critical.
November 19, 2015
16
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EPA
Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Landscape Irrigation Sprinklers
WaterSense
The technology to decrease flow when a nozzle is missing is currently available as
an option. The manufacturers that have this technology have not addressed the
issue to an agreed upon specification, hence there are differences in the respective
features and performance.
3. No. The flow rate of 1.5 gpm does encompass what is found in many sprinkler
installations. It is unwise to conclude that data specific to a 1.5 gpm nozzle at a
variety of patterns constitute the basis for an "adequate characterization" of
performance of an entire product category. We recommend testing all flow rates and
operating pressures for the nozzle range available to be used on the sprinkler. In
addition, testing the regulator in both increasing and decreasing pressure
environments is important due to hysteresis.
November 19, 2015 17
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WaterSense
Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Landscape Irrigation Sprinklers
Commenter: John R. Farner, Jr.
Affiliation: Irrigation Association
Comment Date: July 28, 2014
Email Text:
Here are the IA comments. Please let me know if you have any questions!
John R. Farner, Jr.
Government and Public Affairs Director
Irrigation Association
6540 Arlington Blvd
Falls Church, VA 22042-6638
T: 703-536-7080
F: 703-536-7019
iohnfarner@irriqation.org
www.irriqation.org
Email Attachment:
July 28, 2014
Ms. Veronica Blette
Chief, WaterSense
United States Environmental Protection Agency
Dear Veronica:
Below are the comments from the Irrigation Association regarding the Notice of Intent to
Develop a Draft Specification or Landscape Irrigation Sprinklers. We look forward to
working with you throughout the development of this specification.
Thank you for all you do in promoting efficient irrigation in the marketplace. If you have
any questions regarding our comments, please feel free to contact me at
iohnfarner@irrigation.org or 703.536.7080.
John
Sincerely,
John Farner
Government Affairs Director
November 19, 2015
18
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EPA
Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Landscape Irrigation Sprinklers
WaterSense
• The Irrigation Association supports the intent of WaterSense to develop a
specification to label landscape irrigation sprinklers. We applaud WaterSense for
taking the initiative to promote water use efficiency through these vital technologies.
If labeled, these efficient products will open up new opportunities for WaterSense to
partner with the irrigation industry to conserve even more water in the landscape
through efficient irrigation.
• Throughout the NOI, WaterSense references both SWAT testing methods and those
developed through the ASABE/ICC 802-2014 Landscape Irrigation Sprinkler and
Emitter Standard. The Irrigation Association supports the decision by WaterSense to
adopting those set forth by the ASABE/ICC standard development process. These
processes have been developed by a full standard setting process, with various
interests participating (including the IA and WaterSense) and can withstand much
more scrutiny because of this.
• Questions defined by WaterSense:
Is the proposal of labeling nozzles and bodies separately appropriate for this
product category?
The IA supports the scope of the possible specification and feels that it is appropriate
to include both labels for nozzles and pressure-regulating bodies of landscape
irrigation sprinklers under one specification.
Regarding the performance measure for high-efficiency nozzles, is the top-tier
approach or increase-from-baseline approach more appropriate for identifying
the performance threshold for DU?
The Irrigation Association would like more data on how each of the performance
threshold testing approaches would be conducted, before supporting one over the
other. The IA feels that both methods have merit, if done properly.
• Under the top-tier approach, how will the "wide range of products" be selected
and how may will be tested to determine the top 20 percent of DUiq results? How
often will the top tier be updated as new nozzles are introduced?
• In the "increase-from-baseline-approach," how would WaterSense determine the
baseline DUiq?
Regarding pressure regulation, is a sprinkler's ability to maintain a constant
outlet pressure over a range of inlet pressures an appropriate measure of
performance for pressure-regulating spray bodies?
The method described in the ASABE/ICC standard may not be adequate if the
standard orifice of 1.5 gpm is not within the range of the sprinkler being tested.
Additionally, the flow rate of the nozzle could influence the performance of the
pressure regulating device. If so, that test should be conducted with a nozzle of the
highest flow rate designed for the sprinkler along with a nozzle with a lower flow rate
(but not less than for the quarter circle nozzle) to test performance over a range of
inlet pressures and flow rates.
November 19, 2015 19
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EPA
Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Landscape Irrigation Sprinklers
WaterSense
Is it appropriate to include a performance measure that specifies the sprinkler
body's ability to decrease flow when a nozzle is damaged or missing?
No, while it is desirable to reduce flow if a nozzle is missing, it should not be a
mandatory requirement. With the advent of flow sensing and many controllers being
able to adjust irrigation if there are problems with a modified flow rate, the flow
restrictions actually interfere with being able to capitalize on flow management
capabilities of controllers.
Is the required orifice flow rate of 1.5 gpm in the ASABE/ICC test method for
pressure regulation adequate to characterize the performance of a family of
sprinkler nozzles that covers a range of wetted radii and patterns?
The IA feels that it would be better to choose nozzles that represent the highest and
lowest flow rate designed for the sprinkler in question.
Finally, many sprinklers are sold with a "nozzle tree," meaning a variety of nozzles
available so that the proper nozzle for the circumstance can be selected. If some
nozzles on the nozzle tree "pass" a WaterSense label test and others not, how will
this be handled? Additionally, nozzles are sold with either fixed or variable arcs for
spray heads. There could be circumstances where one-half of circle nozzle passes,
but the quarter circle nozzle does not. How will the label be applied?
Also, because the proposed DU will be modeled, all nozzles can have a "sweet spot"
of performance but they may not have the same spacing requirement or operating
pressure when combined with a number of nozzles and arcs as used in the field.
Will these nozzle families or nozzle trees be labeled and if so, how will they be
treated?
November 19, 2015 20
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EPA
Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Landscape Irrigation Sprinklers
WaterSense
Commenter: Seth Ostrowski
Affiliation: Sprinkler Flow Control
Comment Date: July 28, 2014
Email Text:
Peter,
Here is my revision. I think it focuses first on the specification recommendation then our
solution.
RE: WaterSense® Notice of Intent (NOI) to Develop a Draft Specification for Landscape
Irrigation Sprinklers
We recommend you include in your specifications for landscape irrigation sprinklers the
following:
1. Each sprinkler must be able to reduce pressure to the nozzle optimal design
pressure range (generally 25-30PSI). This feature must either be part of the sprinkler
body assembly or be added into the sprinkler riser or pipe immediately prior to the
sprinkler body.
REASON: Higher than optimal pressure results in higher sprinkler equipment failure
rates, increased operation and maintenance costs and significant loss of water to from
"misting" and evaporation.
The excess supply pressure causes "high pressure misting" and the designed wetted
radii and patterns are negatively affected. Losses of up to 33 percent from over-
pressurized misting can result.
2. Each sprinkler should be able to reduce the amount of lost water by 70 percent due
to a sprinkler failure.
REASON: Currently, if a sprinkler is broken, a geyser will result in almost complete
loss of the water until the broken sprinkler is fixed. This broken condition may exist
for days or weeks until discovered with the rest of the zone receiving no water
causing possible vegetation failure, increased costs associated with plant
replacement, and water waste. This would require each irrigation zone to be self-
healing at each nozzle location and the reduction in water flow would still allow the
other sprinklers in the same zone to function properly.
Our company's solution to both issues:
Sprinkler Flow Control has a device that accomplishes at least two important results: 1. it
reduces the inlet pressure to the sprinkler nozzle and the gpm, thereby reducing water
loss due to "overpressurization"/high pressure misting and improving uniformity of water
distribution; and 2. it decreases the flow when a nozzle is damaged or missing by as
much as 90 percent. The disc is also removable and can be reinstalled.
November 19, 2015
21
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EPA
Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Landscape Irrigation Sprinklers
WaterSense
The Sprinkler Flow Control device is a concave stainless steel disc with radial cuts and a
center orifice. In the case of a RainBird Professional 1800 Series sprinkler body, the disc
is inserted into the bottom of the sprinkler body at the inlet. It is installed by removing the
top cover/seal assembly, then pushing the disc down into place using an install tool.
Other sprinkler applications require that the disc be inserted into the riser.
Depending on the disc orifice and supply pressure, the disc will allow between .75 gpm
to 5.0 gpm to pass. The standard range for most fan type sprinkler nozzles is between
.29 gpm and 4.0 gpm. The disc orifice is matched to the needs of the sprinkler nozzle.
Depending on the supply line size and pressure, 16 gpm or more will be supplied to the
sprinkler during normal conditions prior to the disc installation.
Our testing shows that the municipal supply pressures at the irrigations zones do not
vary much and the correct match of disc orifice and sprinkler nozzle will provide for a
consistent supply pressure to the nozzle.
We feel that modifications to existing sprinkler bodies should be considered when
developing specifications for landscape irrigation sprinklers. Our disc is a good example
of taking existing sprinklers and modifying them to perform better given certain
conditions. Because the modification may be less expensive to install and maintain,
there is a greater likelihood and probability that the end user will install water saving
devices.
My contact information is: Peter Maksymec, Sprinkler Flow Control, 9107 West Russell
Road, Las Vegas, Nevada 89148. Office 702-551-SAVE (7283), cell 702-493-8450, and
email Peter@SprinklerFlow.com. Our website is www.SprinklerFlow.com. We would like
to stay involved in the draft of the specifications.
Seth Ostrowski
Operations Manager
Sprinkler Flow Control
9107 W. Russell Rd.
Las Vegas, NV 89148
702-630-3136
Save Water, Save Time, Save Money
November 19, 2015 22
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EPA
Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Landscape Irrigation Sprinklers
WaterSense
Commenter: Adam Carpenter
Affiliation: American Waterworks Association
Comment Date: July 28, 2014
Email Text:
Dear Sir or Madam:
Please find comments from the American Water Works Association on EPA's
WaterSense Notice of Intent to Develop a Draft Specification for Landscape Irrigation
Sprinklers dated May 22, 2014 attached. Please do not hesitate to contact us with any
questions or feedback you may have.
Sincerely,
Adam T. Carpenter, ENV SP. DTM
Regulatory Analyst, American Water Works Association
202-326-6126-Office
acarpenter@awwa.org
Email Attachment:
U.S. Environmental Protection Agency
Office of Wastewater Management (OWM)
1200 Pennsylvania Ave, N.W.
Mail code 4201M
Washington, DC 20460
Re: Notice of Intent to Develop a Draft Specification for Landscape Irrigation
Sprinklers
Dear Sir or Madam:
The American Water Works Association (AWWA) would like to thank EPA for the
opportunity to comment on its WaterSense Notice of Intent (NOI) to Develop a Draft
Specification for Landscape Irrigation Sprinklers. AWWA is an international, nonprofit,
scientific and educational society dedicated to providing total water solutions assuring
the effective management of water. Founded in 1881, the Association is the largest
organization of water supply professionals in the world. Our membership includes over
3,900 utilities that supply roughly 80 percent of the nation's drinking water and treat
almost half of the nation's wastewater. Our nearly 50,000 total memberships represent
the full spectrum of the water community: public water and wastewater systems,
environmental advocates, scientists, academicians, and others who hold a genuine
interest in water, our most important resource. AWWA unites the diverse water
community to advance public health, safety, the economy, and the environment.
November 19, 2015
23
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EPA
Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Landscape Irrigation Sprinklers
WaterSense
Support for WaterSense and Water-Efficient Landscaping
AWWA supports the WaterSense program as a valuable tool for both consumers and
water utilities. WaterSense gives consumers choices for high-efficiency products. It also
assists water utilities in implementing conservation programs where locally relevant by
providing them with products appropriate to promote and incentivize because they can
be certain that installing those products will reduce water demand compared to
traditional products.
Given that a substantial portion of residential and commercial water use in many areas
goes to lawn and landscaping irrigation, highly efficient options are needed and AWWA
appreciates that WaterSense is working on identifying efficient irrigation options. AWWA
supports the development of WaterSense labeling for products that will use water more
efficiently when placed into actual use, and where that efficiency can be demonstrated in
actual conditions. However, we do not believe, based upon the NOI, that all of the
building blocks necessary to meet these intents of WaterSense labeling of irrigation
sprinklers have been put into place at this time. We recommend that additional research
be completed before pursuing labeling this product category, or at least delaying the
completion of a draft specification until this additional research has been completed. If a
poorly preforming labeling system were to be put into place, even with the best of
intentions, both consumers and water utilities could suffer poor performance and receive
a false sense of expected water savings.
Potential for Adverse Consequences and Need for More Research
It is important to remember that improved technology or increased product performance
alone does not automatically translate into water savings. We believe that additional
research and field data is needed to address a first question that EPA should be asking
itself and the stakeholder community. Specifically, whether irrigation sprinklers should or
should not be available for WaterSense labeling, prior to asking how they should be
labeled. In order for WaterSense to remain relevant to the water utility community and
other stakeholders, it must be clear that WaterSense labeled products actually reduce
water use compared to other reasonable alternatives. In the instance of irrigation
products (for residential and commercial applications) that are inherently discretionary
uses, determining savings much more difficult than for non-discretionary water uses
such as toilets.
For example, in designing a new home or performing landscape upgrades, the
homeowner, builder, and/or landscaper ("users") have several options to reduce outdoor
water use.
Developers and homeowners choosing to install a low water use landscape, such as
xeriscaping and other climate-appropriate landscaping, could reduce the needed area
for irrigation or possibly eliminate it entirely. Other landscaping techniques such as drip
irrigation for plants and shrubs are also much more efficient than sprinklers. If
WaterSense labeled products existed only for sprinklers and not for other, more
structurally efficient options, the user could end up in a situation where the choices are to
(1) install WaterSense approved equipment or (2) design the system to be more water
efficient using other landscaping designs that may not have the associated consumer
November 19, 2015
24
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EPA
Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Landscape Irrigation Sprinklers
WaterSense
education and recognition that a WaterSense label delivers. A user may then choose to
install WaterSense equipment to be able to market/promote the labeling or because the
labeling system misleads the user into thinking the sprinklers are more efficient than the
alternatives, because no labeling existed for those alternatives. EPA should carefully
consider ways to prevent this sort of unintended adverse consequence, such as
providing WaterSense labeling or alternative consumer education and recognition for
low-water-use landscapes that do not use irrigation devices or use devices other than
sprinklers. The ultimate goal of WaterSense is to provide choices that reduce water use
through more efficient options, and labeling one or a few more efficient landscaping
options without recognition of others could undermine this effort and reduce consumer
and utility confidence in the WaterSense program.
Additionally, it is unclear whether the proposed methods in the NOI would actually
reduce water use. Methods to reduce flow may be useful for proving water savings in a
controlled laboratory environment, but are built upon the assumption that consumers will
either no modify their behavior as a result of new technology or modify it in an
anticipated manner. For example, if it appears that less water is being applied per
minute of irrigation to their lawns, some consumers may simply increase the number of
minutes of irrigation, resulting in smaller savings or even greater overall use.
Additionally, there is little empirical data that high distribution uniformity (DU) actually
reduces water use, given that topography, behavior, vegetation type, and other factors
are all also important. Systems with different levels of DU should be studied in various
field conditions to develop an actual relationship before using DU as a measurement
towards labeling. DU also does not measure how much of the water leaving the sprinkler
actually is applied to the intended irrigated area. We recommend that EPA examine
additional factors, such as studying actual customer use and product category
performance in the field, prior to offering WaterSense labeling for irrigation sprinklers or
progressing far into specifications development.
These issues do not automatically suggest that EPA should not pursue WaterSense
standards for irrigation sprinklers. However, they do suggest that EPA should study them
more thoroughly and should explicitly address each of the potential unintended
consequences throughout specifications development for this product category. For
example, EPA may wish to consider labeling only in situations where the technology has
been demonstrated to save water, and provide alternative labeling and recognition for
alternative efficiency options that require little or no irrigation (thus, going further towards
reducing water use). Such a system could reduce the potential adverse consequences
of labeling in this product category. However, these alternatives must be studied with
care to identify how savings will occur and which conditions those savings would apply
to and to fit into other aspects of the WaterSense program. That way, users can make
more informed decisions and utilities can choose to incentivize this product category
(where locally appropriate) only if the correct conditions are met to result in water
savings. This information is necessary for utilities and consumers to make wise
investments in demand reduction where appropriate.
Finally, it is also essential that thorough educational materials be developed to help
inform developers and consumers of these product or system limitations to help them
use these products efficiently to further help avoid these unintended consequences. Any
November 19, 2015 25
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EPA
Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Landscape Irrigation Sprinklers
WaterSense
WaterSense program for this category would benefit greatly if the above identified issues
were both studied and clearly addressed.
Responses to Specific EPA Questions Within the NOI
3. Is the proposal of labeling nozzles and bodies separately appropriate for this product
We believe that it is appropriate to label nozzles and bodies separately. However, we
have some reservations about the product category as a whole because of potential
adverse outcomes and lack of demonstrated water savings in real-world situations. More
research is needed to make sure all the components come together correctly.
Additionally, any product labeling program would be well served by a robust marketing
and education effort that clearly presents irrigation system complexities and how
intended water savings can best be achieved.
4. Regarding the performance measure for high-efficiency nozzles, is the top-tier
approach or increase-from-baseline approach more appropriate for identifying the
performance threshold for DU?
We believe that additional research is needed before pursuing either one of these
approaches. At present, there is insufficient data to conclusively show that changing the
DU reduces water use outside of controlled laboratory settings. Not all irrigated areas
require the same amount of water because of different vegetation types, topography,
exposure to sunlight, and other factors. Additionally, an increase in DU does not mean
that consumers will use the system any more efficiently than if there had been a low DU.
Different products with a identical DUs could have differing efficiencies and evaporative
losses. This does not mean that DU is not a useful measure for other product
performance purposes, but for water use efficiency we do not agree with the assumption
that scoring high on DU automatically results in water savings worthy of WaterSense
labeling. It is possible that consumer satisfaction may be higher with higher DU products,
and that higher DU products help to reduce runoff, but these co-benefits would be
applicable to WaterSense only if higher DU can be proven to also reduce water use.
Therefore, we feel these issues need further study before using either approach.
5. Regarding pressure regulation, is a sprinkler's ability to maintain a constant outlet
pressure over a range of inlet pressures an appropriate measure of performance for
pressure-regulating spray bodies? Is it appropriate to include a performance
measure that specifies the sprinkler body's ability to decrease flow when a nozzle is
damaged or missing?
We recognize that varying inlet pressures based on utility services coupled with poor
irrigation system design can result in poor system performance and increased water use.
It is important to measure both inlet and outlet pressure and flow rate to determine how a
system is operating. Products that deliver a more constant outlet pressure and flow rate
improve sprinkler performance which can contribute toward water efficiency. In many
products, a constant outlet pressure may mean that the flow rate is also constant, but
this should not be assumed for all products.
category?
November 19, 2015
26
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EPA
Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Landscape Irrigation Sprinklers
WaterSense
For damaged or missing sprinklers, we believe that a device that would reduce flow or
shut the sprinkler off entirely would save water over the short term compared to the
"geyser" that could potentially occur for a damaged or missing sprinkler. However, there
are several issues to be addressed in such a design:
• First, what constitutes damaged or missing? Clear definitions are absolutely
essential to be able to objectively measure this phenomenon. If the sprinkler was
missing, would the device that regulates the flow also be missing?
• Second, does the reduced flow mask the fact that the sprinkler is damaged or
missing? In this case, users may not perform needed repairs that would reduce
water use because they are unaware of the problem, and may even increase
watering times when they notice that less water is being applied to certain irrigated
areas. Preferably, any such design would also include a component that would help
inform users of the problem and the need for repairs.
• Also, no device to shut off or reduce flow will work if that device is also damaged or
missing, and it is therefore unclear how such a device would be tested.
6. Is the required orifice flow rate of 1.5 gpm in the ASABE/ICC test method for
pressure regulation adequate to characterize the performance of a family of sprinkler
nozzles that covers a range of wetted radii and patterns?
We believe that 1.5 gpm may not be the correct rate in all situations. Given the wide
variety of nozzles with different spray patterns, coverage arcs, etc. a different flow rate
may be required for some products. It is important to use a realistic flow rate for a given
product because failing to do so may falsely show savings when in real-world
applications none exist.
Conclusion
Thank you for the opportunity to comment on this important notice of intent. It is our
sincere hope that additional research and development in the areas discussed
throughout these comments will help WaterSense identify potential barriers to
implementing a specification in this category and allow EPA to address each of the
roadblocks early in development. If you have any questions regarding this
correspondence or if AWWA can be of assistance in some other way, please contact me
or Adam Carpenter at (202) 326-6126 or acarpenter@awwa.org.
Respectfully,
Thomas W. Curtis
Deputy Executive Director American Water Works Association
CC: Peter Grevatt, EPA OGWDW
Andrew Sawyers, EPA OWM
Veronica Blette, EPA OWM
November 19, 2015 27
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EPA
Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Landscape Irrigation Sprinklers
WaterSense
Commenter: Jeffrey Hughes/Mary Ann Dickinson
Affiliation: Alliance for Water Efficiency
Comment Date: July 28, 2014
Email Text:
Please accept the attached as public comment on the EPA WaterSense Notice of Intent
to Develop a Draft Specification for Landscape Irrigation Sprinklers. Thank you for the
opportunity. Please acknowledge receipt.
Mary Ann Dickinson
President and CEO
Alliance for Water Efficiency
300 W. Adams Street, Suite 601
Chicago, Illinois 60606
www.a4we.org
Email Attachment:
Delivered via E-mail to: watersense-products@erg.com
July 28, 2014
WaterSense, U.S. Environmental Protection Agency Office of Wastewater Management
(4204M) 1200 Pennsylvania Avenue, N.W. Washington, D.C. 20460
RE: COMMENTS ON EPA WATERSENSE NOTICE OF INTENT TO DEVELOP A
DRAFT SPECIFICATION FOR LANDSCAPE IRRIGATION SPRINKLERS
The Alliance for Water Efficiency is pleased to submit the attached comments in
response to EPA WaterSense's request for comments or suggestions on the NOI to
develop a draft specification for landscape irrigation sprinklers.
The Alliance for Water Efficiency is a nonprofit organization dedicated to the efficient and
sustainable use of water. We represent a broad coalition of stakeholders which include
water suppliers, business and industry, government agencies, energy and environmental
advocates, and academia.
We appreciate your consideration of our comments and recommendations. Please let
us know if you have any questions.
Sincerely,
pnetLLjO/wv, SujJlls*
Mary Ann Dickinson
President and CEO
ALLIANCE FOR WATER EFFICIENCY
November 19, 2015
28
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EPA
Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Landscape Irrigation Sprinklers
WaterSense
Comments on EPA WaterSense Notice of Intent to Develop a Draft Specification
for Landscape Irrigation Sprinklers
JULY 28, 2014
Our discussion group has many more questions that we believe should be addressed in
addition to the questions posed by WaterSense. In order to respect the WaterSense NOI
process we have included our preliminary answers to the questions in Section V. of the
NOI. Our own list of questions concludes the notes from our conference call.
Section V. Outstanding Questions
WaterSense welcomes feedback on all aspects presented in this NOI but is seeking
specific input on the following outstanding questions:
1. Is the proposal of labeling nozzles and bodies separately appropriate for this product
category?
a. Yes. Some AWE stakeholders assert that if you were to do nothing
more than require pressure-regulating sprinkler body there would be
measurable savings. Please note that savings potential is greatest
when pressure is higher than optimum due to system supply pressure
or elevation changes in the irrigation system.
b. WaterSense might be better advised to focus on pressure-regulating
labeling before attempting to label nozzles at this time. Given that
pressure-regulating sprinkler bodies are more likely to deliver repeatable
results a quicker roll-out schedule is likely.
c. The efficient nozzles and pressure-regulating sprinkler bodies are two
different technologies that should be considered separately. Conducting
simultaneous testing and specification development is likely to result in
confusion regarding the difference in each of the technologies (i.e., test
only one variable at a time). Our stakeholders' recommended strategy for
study and roll out is to begin the labeling process for pressure-regulating
sprinkler bodies as soon as possible.
2. Regarding the performance measure for high-efficiency nozzles, is the top-tier
approach or increase-from-baseline approach more appropriate for identifying the
performance threshold for DU?
a. There is some indication in the literature that variability in catch can data
does not adequately represent soil moisture variability (Dukes, Haley, &
Hanks, 2006). These data indicate that this is not an appropriate question
because this question is based upon an assumption that there is a direct
relationship between DU and water savings. It is the experience of the AWE
stakeholders that there is not yet an established basis for assuming that this
is the case.
b. WaterSense research for high-efficiency nozzles should quantify whether
November 19, 2015
29
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EPA
Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Landscape Irrigation Sprinklers
WaterSense
there is a reliably direct connection between DU and water savings or
whether there is another lab test that can more reliably determine if high-
efficiency nozzles can deliver water savings on a level that merits
WaterSense labeling.
3a. Regarding pressure regulation, is a sprinkler's ability to maintain a constant outlet
pressure over a range of inlet pressures an appropriate measure of performance for
pressure-regulating spray bodies?
a. It is the opinion of the AWE stakeholders that the best way to test pressure
regulation for sprinkler bodies is to determine if the product can maintain a
relatively constant flow rate over a range of inlet pressures. For example, testing
for quarter circle, half circle, and full circle flow rates at step increased and
decreased pressures.
3b. Is it appropriate to include a performance measure that specifies the sprinkler
body's ability to decrease flow when a nozzle is damaged or missing?
a. Yes. The "geyser" of a broken sprinkler is a common occurrence and
minimizing water wasted in these instances could result in significant
savings. However, a "geyser" can only be managed by pressure regulation if
the feature is not damaged when the nozzle is damaged or missing.
b. Managing water loss from geysers is a desirable feature. It is the opinion of
the AWE stakeholders that it is appropriate to include a performance
measure that requires the sprinkler body to decrease flow by a specified
percentage or to a specified maximum flow rate when a nozzle is damaged
or missing.
c. In order to be clear about claims of water savings a clear definition of
damaged or missing nozzle should to be developed.
4. Is the required orifice flow rate of 1.5 gpm in the ASABE/ICC test method for
pressure regulation adequate to characterize the performance of a family of
sprinkler nozzles that covers a range of wetted radii and patterns?
a. While a flow rate 1.5 gpm matches the 1/4 circle nozzle, which represents
about 60 percent of sprinkler installations, it is the opinion of the AWE
stakeholders that there should be research conducted at higher flow rates
(typical of full circle) and at lower flow rates (typical of % circle) in the high-
efficiency nozzle testing protocol before accepting 1.5 gpm as a
representative of performance for all sprinklers.
Additional AWE Stakeholder Comments
Many AWE stakeholders question the savings consistency of WaterSense labeled
irrigation sprinkler bodies and nozzles because irrigation usage varies based on a
number of variables including, type of system, cost of water, socio-economic variables,
plant type, horticultural practices, etc. While it is true that other WaterSense products,
such as showerheads, faucets, and toilets, use water, none of these products have a
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Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Landscape Irrigation Sprinklers
WaterSense
spatial installation requirement in order to perform efficiently. In addition, irrigation
installations are subject to a different level of degradation in performance due to the
nature of outdoor installations. Sprinklers are prone to much more damage (e.g., from
mowing and vandalism) than indoor plumbing fixtures. Therefore, performance beyond
the day of installation should be taken into account when determining water savings
potential of sprinkler components.
The AWE stakeholders agreed that it is important that AWE participate fully in this NOI
process. Therefore, we focused our conversation on what we have discovered in our
own research and what data gaps WaterSense would need to fill in order to label high-
efficiency nozzles and pressure regulating sprinkler bodies with a high degree of
confidence that water saved would reliably meet the 20 percent threshold for
WaterSense labeling.
To our knowledge, none of the pilot studies to date have been peer reviewed, though
some have enough participants to be considered statistically valid. One or more peer
reviewed studies from representative regions of the country would be advisable before
implementing WaterSense labeling.
The three utility studies represented on the call tested for DU before and after
installation. All three studies provided modified watering schedules based on changes in
DU. Participants were trained on how to change schedules based on weather or time of
year. Water use evaluation was indexed to changes in ET. None of the three studies
identified any measurable water savings from retrofitting with high-efficiency sprinkler
nozzles.
One utility found that high-performing systems can degrade when retrofitted with high-
efficiency sprinkler nozzles. Surprisingly, there does not seem to be a strong relationship
between DU and total water used by an irrigation system. University studies have also
found no direct relationship between improvements in DU and improved appearance of
the landscape.
AWE stakeholders have several questions that we recommend be answered through
furtherresearch:
• The studies to date have all been conducted as retrofits of existing installations.
What is the water saving potential in a new construction situation?
• Most of the known studies are pilot studies where the majority of participants are
"early adopters" and, since early adopters are often very efficient irrigators, there is
only a limited opportunity to achieve water savings without compromising plant
health and landscape aesthetics. As such, the inclusion of early adopters in these
pilot studies might be partially responsible for the low or no water savings results.
The more important question is—what is the water-saving potential of using this
technology in the general population?
• Many of the known studies have concluded that any water savings realized were the
result of education about controller programming and not necessarily attributable to
changes in technology. How can further research discover the water saving potential
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Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Landscape Irrigation Sprinklers
WaterSense
associated with the technology alone, without the inclusion of an education
component to find out what really might happen when the physical equipment is
labeled and released?
• Is the management of the system more important to achieving water savings than
the sprinkler technology?
• Known studies have found that DU quickly degrades, sometime significantly
decreasing within one year. Changes in DU may not be technology related however
there is a concern about longevity of savings. Further research about how the
technologies perform over time is recommended. Are there changes (degradation) in
DU attributable to the technology or to installation challenges? Regardless of the
cause of the degradation in DU, are water savings significant enough after
degradation to meet the WaterSense threshold of 20 percent savings? Is pressure
regulation sustained over time? Are changes in pressure regulation product related
or installation related? Regardless of the cause of the degradation in pressure
regulation, are water savings significant enough after degradation to meet the
WaterSense threshold of 20 percent savings?
• Are there differences in how the technologies are likely to be adopted by sectors
(Commercial vs. Residential vs. Industrial)?
• How can data logging/AMR/AMI be used in the research so researchers can get
information without having to approach the customer, which might change results
because of behavior changes due to awareness that the customer is being studied
(Hawthorne effect)?
• Standards address specification and safety of the product, not water savings. How
will the WaterSense specification ensure water savings?
• Are these technologies useful in specific landscape configurations but not necessarily
appropriate for general use?
• Is there a regional difference in water savings potential? Running parallel studies in
several climate zones seems wise because savings could be regionally different.
• Is there a difference in water savings potential due to soil types? Running parallel
studies that specifically identify soil conditions and characteristics seems wise
because the purpose of irrigation is to fill the soil reservoir from which the plants
draw water overtime.
One of the stated reasons for early release of the NOI for sprinklers is because the EPA
is using the NOI process to seek existing studies. Several organizations have conducted
literature reviews regarding outdoor water efficient technology studies. Though some
studies have combined measures, those studies that have studies these technologies in
isolation are of particular interest.
A comprehensive list links to resources are listed below:
• CUWCC PBMP Report on Rotating Sprinkler Nozzles
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Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Landscape Irrigation Sprinklers
WaterSense
- http://www.cuwcc.orq/Portals/0/Document%20Librarv/Committees/Proqrammat
ic%20Com
mittees/Research%20and%20Evaluation/Meeting%20Documents/2013/Qc
tober%2030.%20
2013/RN%20PBMP%20Report%20Draft.pdf?timestamp=1401729034336
• Dr. Michael Dukes Studies
- http://abe.ufl.edu/mdukes/publications/
- http://abe.ufl.edu/people/directorv/facultv-profiles/dukes-mike.shtml
- http://abe.ufl.edu/mdukes/
• AWE Literature Review Due in Two Months Bibliography
Dukes, M. D., Haley, M. B., & Hanks, S. A. (2006). Sprinkler Irrigation and Soil Moisture
Uniformity. Falls Church, VA: Irrigation Association.
November 19, 2015
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EPA
Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Landscape Irrigation Sprinklers
WaterSense
Commenter: Sue McGuire
Affiliation: Unaffiliated
Comment Date: July 28, 2014
Email Text:
As a resident of Nevada County, California, and pursuant to Article X of the United
States Constitution, I dispute the federal government's claimed authority to regulate my
water usage.
Pursuant to the limitations on federal authority under Article X, I do not believe the
federal government or its regulatory agencies have such jurisdiction or authority to
regulate my personal water usage, that of my business, that of Nevada County, or that of
the State of California. I do not relinquish my personal rights, my rights as a citizen of
Nevada County, or as a citizen of the State of California to the federal government or its
regulatory agency, the EPA.
This is demand that the federal government's EPA withdraw any alleged claim of
jurisdiction to regulate water usage by me personally or my business and to withdraw
EPA's presence in Nevada County and in California.
SUE McGUIRE
P. O. Box 1715
Nevada City, CA 95959
(530) 913-3906
"In the beginning of change, the patriot is a scarce man,
and brave and hated and scorned. When his cause
succeeds, the timid join him, for then it costs nothing
to be a patriot." Mark Twain, 1904
November 19, 2015 34
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EPA
Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Landscape Irrigation Sprinklers
WaterSense
Commenter: James Canyon
Affiliation: Digital Spring, LLC
Comment Date: June 11, 2014
Email Text:
Re: ECCO Soil moisture system
To whom it may concern.
Our company is bringing a novel turf soil moisture product to the consumer market this
calendar year. I am writing to introduce Digital Spring, to inform you about our ECCO
wireless soil moisture stakes, and to request to be kept in the loop as soon as the
standard is adopted as it is our intention to ensure our product carries the WaterSense
label.
Digital Spring, LLC is a Startup company located in San Diego, CA, and we have spent
the past 2 years developing a new type of soil moisture sensor. Our sensor is fully
encapsulated inside plastic and, like TDR measurements measures dielectric constant of
soil however our sensor uses a new type of transducer to do so. Performance of our
sensors is currently being measured and verified by CSU Fresno CIT. Today we are
focusing on bringing our sensor technology to market in a variety of markets including
commercial farming, commercial turf, consumer turf, and consumer potted plants and
shrubs.
Last March, Digital Spring won Metropolitan Water District's 2013 Innovative
conservation program grant to study the performance of our new ECCO soil moisture
system installed as a retrofit to existing residential sprinkler systems in three cities in
CA/NV/AZ. ECCO soil moisture system is a bypass technology which consists of lawn
stakes inserted by the homeowner into the turf in each watering zone controlled by a
timer based sprinkler controller. ECCO Soil Moisture Stakes wirelessly communicate
with what we call a smart switch which is mounted onto the sprinkler valve. The ECCO
smart switch learns the homeowners watering patterns then interrupts the watering
based on the lawn demand as measured by the sensors. Each sensor contains a stand-
alone computer which allow our sensors to measure soil moisture 24 hours per day and
instructs the switch located at the valve how much to water each day based on the
sensor program. A schematic can be seen at www.eccosoil.com.
It is our intent to have our sensors and system pass the WaterSense testing and proudly
display the WaterSense logo on the packaging. As I said earlier, we are working with Cal
State Fresno to perform our testing and hope we will be able to get certified in their lab.
Please keep us in the loop regarding testing requirements and please feel free to contact
us if you have any questions.
Thanks
Sincerely,
James Canyon, CEO/Founder Digital Spring, LLC
www.digitalspringnet.com
www.eccosoil.com
+ 1858-204-9422
November 19, 2015
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EPA
Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Landscape Irrigation Sprinklers
WaterSense
Commenter: Sandra Cannon
Affiliation: U.S. Department of Energy Sustainable Acquisition Program
Comment Date: June 3, 2014
Email Text:
Dear WaterSense Tearn
I strongly recommend that the Landscape Irrigation Sprinkler Specification go well
beyond commercial code and be either focused on Federal facilities or have two sets of
specifications-one for Federal facilities and commercial entities AND one for home
owners.
The above is to preclude the situation we presently have with faucets where the
WaterSense specification does not meet commercial code and therefore is not
applicable for Federal facilities. —Sandra
Sandra Cannon, Technical Support
U.S. Department of Energy Sustainable Acquisition Program
Tel. 509-529-1535
Avoid Waste, Purchase Smart - EcoPurchasing
November 19, 2015
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EPA
Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Landscape Irrigation Sprinklers
WaterSense
Commenter: Antonio Fernandez
Affiliation: Harvard School Dental Medicine
Comment Date: May 30, 2014
Email Text:
To whom this may concern,
My name is Antonio Fernandez and I'm a first time home buyer that is trying to go as
green, at the same time I'm green to the complete green home system like water,
electricity etc. the reason I write is that I received a rebate add at my home for my toilet
and washer and as I was reading over the specs/all information I see the landscape
irrigation sprinkler tab. Can you explain a bit more how the (LIS) will benefit me and the
environment in the long run. Also the cost of it?
Thank you,
Antonio
School of Dental Medicine
Antonio Fernandez
Purchasing Assistant
Harvard School Dental Medicine
188 Longwood Ave. Rm B010
Boston, Mass 02119
Office: 617-432-6626|Mobile: 857-492-1748
Fax: 617-432-2161
antonio fernandez@hsdm.harvard.edu
B5 HARVARD
November 19, 2015
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EPA
Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Landscape Irrigation Sprinklers
WaterSense
Commenter: Jorge Manuel Mustonen Morel
Affiliation: Unaffiliated
Comment Date: May 27, 2014
Email Text:
APRECIADA GENTE DE WATERSENSE'
MUCHAS GRACIAS POR INFORMARME SOBRE LA ACTIVIDAD DE ASPERSORES
DE RIEGO DE PAISAJE.
ME GUSTARIA MUCHO RECIBIR LAS MEMORIAS DE ESA ACTIVIDAD, SI ES
POSIBLE TRADUCIDAS AL ESPANOL. MUCHAS GRACIAS,
November 19, 2015
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EPA
Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Landscape Irrigation Sprinklers
WaterSense
Commenter: Tom Reynolds
Affiliation: Water Balance
Comment Date: May 23, 2014
Email Text:
Since 2008, never got one handshake from EPA. I don't need it to know I have presence
in irrigation. You'll finally handshake, or I'll continue to move on, opening opportunities,
that have zero relationship with you.
Oh yeah. Get out of the business of supporting tax-payer-funded, typically municipal and
extension "conservation." It clearly has no basis, no more that full and complete
governmental health care. Those landscapes are alive, stupid! You clearly have no clue
about consumer-adviser intimacy and confidence.
Tom A. Reynolds
Tempe, AZ
602-463-5072
www.waterbalance.net
November 19, 2015
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EPA
Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Landscape Irrigation Sprinklers
WaterSense
Commenter: Edward Norum
Affiliation: CSU Fresca, Center for Irrigation Technology
Comment Date: May 27, 2014
Email Text:
We are working on the technical aspects of this specification. We offer to share our
progress with your project leader if you will provide the contact information.
Regards: Ed Norum
November 19, 2015
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EPA
Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Landscape Irrigation Sprinklers
WaterSense
Commenter: Kinzea Thompson
Affiliation: Unaffiliated
Comment Date: May 26, 2014
Email Text:
Once again the federal government is stepping far beyond its constitutionally granted
obligations. If you cannot or will not uphold your oath to protect and defend the
constitution, please by all means self-terminate. This country will never dig its way out of
this economic recession until you parasites stop thinking up new shit to make everything
more expensive, if your ideas were economically viable you would be in the private
sector providing for your families. Do you understand COMRADE?
November 19, 2015
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EPA
Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Landscape Irrigation Sprinklers
WaterSense
Commenter: Brian Shiffman
Affiliation: Unaffiliated
Comment Date: May 25, 2014
Email Text:
The landscape irrigation sprinklers that are available today are the most efficient
sprinklers ever developed with respect to water output. Their water output can be easily
determined by the information already supplied by the manufacturer and when
supplemented with the dealer's knowledge, make the determination of the water savings
readily available. In my area, we have seen a tremendous water savings by using these
new sprinklers. The industry has done a good job responding to the needs of the
landscape market both commercial and residential. I don't see the need for this
additional cost to incorporate "WaterSense" into the production of irrigation sprinklers. I
also don't see where the authorization is for the EPA to become involved in this activity.
Sincerely,
Brian Shiffman
November 19, 2015
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EPA
Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Landscape Irrigation Sprinklers
WaterSense
Commenter: John Texeira
Affiliation: Unaffiliated
Comment Date: May 25, 2014
Email Text:
This is America, the Constitution and my right to life, liberty and the pursuit of happiness
gives me the God given right to water my grass and garden.
Big Government needs to stay out of my life and my business.
John Texeira
November 19, 2015
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WaterSense
Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Landscape Irrigation Sprinklers
Commenter: Keith Murr
Affiliation: Unaffiliated
Comment Date: May 25, 2014
Email Text:
EPA Get out of our lives.
November 19, 2015
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EPA
Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Landscape Irrigation Sprinklers
WaterSense
Commenter: Angelo N. Ververis
Affiliation: Unaffiliated
Comment Date: May 25, 2014
Email Text:
This intent is ridiculous. It is a waste of our tax dollars. The EPA is out of line engaging in
this. States should address these issues on a local case by case basis.
Angelo N Ververis
Concerned Citizen
November 19, 2015
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EPA
Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Landscape Irrigation Sprinklers
WaterSense
Commenter: Greg Walsh
Affiliation: Unaffiliated
Comment Date: May 25, 2014
Email Text:
please stay out of our lives, we do not need or care for our Agenda
TAKE A HIKE
November 19, 2015 46
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EPA
Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Landscape Irrigation Sprinklers
WaterSense
Commenter: Mary Crocker
Affiliation: Unaffiliated
Comment Date: May 24, 2014
Email Text:
Greetings,
I'm a homeowner, not an irrigation specialist. However, I am very concerned about using
water resources wisely. I have 2 rain barrels in operation to water my small vegetable
gardens. I also collect the drip from my central air conditioner for when the rains don't
come, which is happening a lot lately in Texas. In fact, for several years. Texas is not the
only state with serious drought conditions. More use of rain barrels would help. And
learning about using native plants for your community which don't require more water.
I have heard about using grey water for landscape irrigation and I would love to use it.
However, my local government officials think that can only be used if you build the new
neighborhood with that system. Education is needed, perhaps at municipal government
statewide conferences.
I remember that my grandmother and her sister had cisterns under their houses which
were build on pier and beam. They preferred that water for gardens and washing hair.
Why did we neglect that technology and knowledge?
Peace and Joy,
Mary C
November 19, 2015
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EPA
Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Landscape Irrigation Sprinklers
WaterSense
Commenter: Ken Mauser
Affiliation: Aquatrols Corporation
Comment Date: May 24, 2014
Email Text:
I can understand your desire to get a more effective and more efficient sprinkler for the
application of the water. On the surface. But what happens to that water after it leaves
the sprinkler and lands on the soil? Water is lost every time a sprinkler or emitter is
turned on and water comes out because water doesn't go where we want it to. Water will
always follow a path of least resistance. And that is where the loss of water, in the soil,
begins. If you people are going to finally move outdoors and start to work on water
conservation and water use efficiency in the landscape then you better work on the
whole process and not just the application system. Irrigation systems deliver water from
point A to point B. And then they distribute that water as uniformly as possible. But once
that water is out of the irrigation system it is not controlled and can be lost in staggering
amounts. I have seen irrigation system distribution uniformity percentages of 80 and
85% drop to the 60% area when it comes to water use efficiency % because the water
wouldn't or couldn't get into the soil effectively. Let's do the whole job and not just part
so we can get maximum water use efficiency and max water conservation.
Aquatrols has been helping the turf and landscape industry save water for over 50 years.
We have more experience helping turf managers and landscapers manage water more
effectively and efficiently than anyone in the industry. We are here to help. Ask us.
Ken Mauser
Territory Manager/Territory Agronomist
Aquatrols Corporation
805-402-4863
November 19, 2015
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EPA
Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Landscape Irrigation Sprinklers
WaterSense
Commenter: James Johnson
Affiliation: Healthy Efficient Homes LLC
Comment Date: May 24, 2014
Email Text:
Why does WaterSense have a program for sprinklers when we should be banning
sprinklers. In the next few years with water being a valuable resource we will need to
stop using all sprinkler systems and let grass go brown in the summer as it should.
Jim Johnson
Healthy Efficient Homes LLC
100 Western St
PO Box 261
Worthing SD 57077
Cell 605-940-2738605-940-2738
November 19, 2015
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EPA
Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Landscape Irrigation Sprinklers
WaterSense
Commenter: Kerry Frost
Affiliation: Unaffiliated
Comment Date: May 24, 2014
Email Text:
Hi
I have a new product for the domestic home owner to save water and drip feed irrigate
the garden. The first of a range of product for this problem is on sale at
www.waterinqpipe.co.uk. Besides this the technology is design to change the way water
is stored and managed in numerous settings. Such as gray water irrigation systems and
integrated in structures for maximum efficiency of space.
Please consider this advance in the market whilst changing specifications etc.
Yours K. Frost
November 19, 2015 50
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EPA
Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Landscape Irrigation Sprinklers
WaterSense
Commenter: Doris Wright
Affiliation: Unaffiliated
Comment Date: May 23, 2014
Email Text:
I received an email asking for input regarding specifications for saving landscape water.
1. Don't water grass. It goes dormant but recovers when it rains. This should include
golf courses. Also sports fields.
2. In gardens lawn can be replaced with low water use plants that can be mulched to
conserve even more water, or by vegetables and fruits, also mulched.
3. Or if the lawn owner does not like to take care of plants he can cover the area with
mulch or gravel or some other permeable material.
4. Gray water is good for plants. But probably water from aquifers near fracking sites is
bad for plants as well as animals including us.
5. The irrigation system should be on a separate water line from the house line, and
one that can be shut off until the moisture level is below a certain level under all that
mulch. This could probably be automated with moisture sensors.
Any more questions?
DW
November 19, 2015
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EPA
Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Landscape Irrigation Sprinklers
WaterSense
Commenter: John Mitchell
Affiliation: Siphonaid/Siphon Priming Device
Comment Date: May 23, 2014
Email Text:
Have you considered grey water for landscape irrigation? www.siphonaid.com is an
inexpensive, easy to use tool for many (not all) households, this is water re-use - and not
just reduction of use - but re-use.
Do you have any feedback? Do you do anything w/ grey water?
thank you
John Mitchell
November 19, 2015
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EPA
Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Landscape Irrigation Sprinklers
WaterSense
Commenter: Greg Chick
Affiliation: Green Plumbers
Comment Date: May 23, 2014
Email Text:
It is my opinion thru decades of contracting that spray areas less than 8' in area are not
ideal for containing spray or even distribution.
Could this comment be put on the table?
Greg Chick, LEED AP. CWM, ARCSA AP, CLIA Current Plumbing contractor, former
irrigation contractor. ASABE TG member, water geek.
greg@ramonasplumber.com
ACCREDITED
yt GreenP/umbers'
^ * TRAINtNO
November 19, 2015
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EPA
Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Landscape Irrigation Sprinklers
WaterSense
Commenter: Lucas Mouttet
Affiliation: Fort Collins Utilities
Comment Date: May 23, 2014
Email Text:
Hi there -
Thanks for the email about the Notice of Intent on landscape sprinklers - very
interesting!
We have been rebating these items for a few years now, and were able for the first time
this year determine statistical savings from customers who received a rebate - analysis
from the consultant attached - please let me know if you need more explanation on it.
The nozzles we rebate are listed on our website here -
http://www.fcqov.com/utilities/residential/conserve/water-efficiencv/water-efficient-
sprinkler-systems/sprinkler-equipment-rebates/qualifying-sprinkler-equipment
Please let us know if we can be of any other assistance in this process with
collaborations or data - we're happy to help.
We are certainly excited for you guys to certify nozzles and heads, it will only help us
promote our current program!
Lucas
Lucas Mouttet
Water Conservation Coordinator
Fort Collins Utilities
970-224-6123-office
970-962-9138-mobile
Efficiency Works!
Email Attachment:
To: Lucas Mouttet
From: Tim Hillman
Date: May 8, 2014"
RE: 2013 Indoor/Outdoor Water Savings Summary by Rebate Measure
This document provides a summary of the indoor, outdoor and total water savings from
Fort Collins Utilities' (FCU) water rebate programs. This analysis is an update to the
"2013 Indoor/Outdoor Water Savings Summary by Rebate Measure" (delivered
September, 2013) that includes data through the end of 2013 and is meant to provide
FCU with another snapshot of the water use impacts observed among these customers.
November 19, 2015
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Comments on WaterSense®
epa Notice of Intent (NOI) to Develop a Draft
WaterSense Specification for Landscape Irrigation Sprinklers
As more customers participate and the analysis is further refined, FCU should be able to
rely on these metrics of program performance through the ongoing use of the Strategic
Intelligence Management System (SIMS). The remainder of this document contains a
description of the scope of this analysis and the methodology use to calculate indoor,
outdoor and total water use changes from each of the measures as well as a summary
of the results.
Methodology and Scope
At the time of this analysis, six of FCU's individual rebates and the sprinkler audit
program that are being tracked by FCU's Tracking Nexus on Sharepoint and are
similarly being tracked by the SIMS, are included in this analysis. The methodology and
analysis deriving the indoor/outdoor water use splits were outlined in detail in the
following reports: "Fort Collins Indoor and Outdoor Water Use Summary: 2005 - 2011"
(delivered 3/1/12).
In an attempt to better understand the impacts of particular measures, this analysis
evaluates program participants that only installed the rebated measure of interest (i.e.,
they are not known to have installed another rebated water measure at the property).
Caution should be used, however, when trying to infer actual savings attributable to the
measures from these results as there are a number of exogenous factors that affect
water use. Despite this, these results provide a valuable snapshot of water use changes
among these customers that can aid in the assessment of the impacts of these rebate
programs. Table 1 provides a summary of the measures and whether the indoor or
outdoor water use component was included in this assessment.
Table 1 Summary of measures include in thisanalysis
Measures with Indoor and Total Use Analyzed
Measures with Outdoor and Total Use Analyzed
Clothes Washer, Dishwasher, Toilet
Irrigation Controller, Irrigation Nozzles & Heads,
Rain Sensor, Sprinkler Audit
The water savings associated with each of the rebated measures is calculated from
billing consumption data that is totaled on an annual basis to yield the normalized annual
consumption (NAC). The NAC is simply the sum of the consumption for a consecutive
12 month period and does not represent weather normalized consumption, but in this
case consumption that is normalized to a full 12 month calendar period. The NAC
approach used in this analysis evaluated changes in total water use for all measures and
either indoor water use or outdoor water use changes depending on whether the
measure affected indoor or outdoor water use.
The difference of the NAC prior to measure install and the NAC after the measure install
is quantified to yield savings (gross program impacts):
Unadjusted Program Savings = ^ AN AC = } NACpre — NACpostt
i= 0 i=0
where: NACpre = Constant pre-enrollment NAC value for 1 month prior
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epa Notice of Intent (NOI) to Develop a Draft
WaterSense Specification for Landscape Irrigation Sprinklers
to enrollment NACpost = Rolling month post-enrollment NAC
starting 1 month after enrollment
Water use exhibits substantial variation across seasons and years and to attempt to
normalize for these impacts, our evaluation is based on the net program savings. Net
program savings are calculated by adjusting the gross savings observed among
program participants (the "unadjusted program savings" outlined above) against the
water savings observed among a control group composed of a random sample of non-
program participants.
The adjusted (or net) program savings are computed as:
Adjusted Savings = I (C_d. * NACpre) — NACpost}
J Program. Participants
where the control adjustment factor (Cadj) is computed as:
| NACpost^
Control,,., =
ad) I NACpre
Control
A control adjustment factor is calculated and applied for every NACpre and NACpost
period associated with a unique measure install date. A control adjustment factor greater
than 1.0 signifies that consumption increased among the control group customers over
the two years surrounding the measure install date.
Results
Three result sets are presented below: 1) a summary of the indoor water savings for the
measures that affect indoor water use (clothes washer, dishwasher and toilet); 2) a
summary of the outdoor water savings for the measures that affect outdoor water use
(irrigation controller, irrigation nozzle/head, rain sensor and sprinkler audit); and 3) a
summary of the total water use changes observed across program participants for all
measures. The number of meters, the median and average control adjusted annual
water savings (gal/year) and the 95% confidence interval on the average savings
observed on an indoor water use, outdoor water use or total water use basis are
summarized in Table 2, Table 3 or Table 4, respectively.
Table 2 Summary of control adjusted indoor water use savings by
measure
Program/Measur
Annual Indoor Water Savings per
Confidence Interval for Average
e
Program Participant
Savings
Number of
Median
Average
Absolut
Relative
Standard
Meters
(gal)
(gal)
e (+/-
(+/-%)2
Deviation
gal)
(gal)
Clothes Washer
1,825
4,280
5,200
530
10%
11,490
Dishwasher
1,186
970
1,350
530
40%
9,350
November 19, 2015
56
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WaterSense
Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Landscape Irrigation Sprinklers
Toilet
588
3,880
5,550
860
16%
10,600
1. Confidence interval defined for a 95% confidence level.
2. Relative confidence interval calculated as the absolute confidence level divided by the mean.
Table 3 Summary of control adjusted outdoor water use savings by
measure
Program/Measure
Annual Outdoor Water Savings per
Confidence Interval for Average
Program Participant
Change
Number
Median
Average
Absolute
Relative
Standard
of
(gal)
(gal)
(+/- gal)
(+/-
Deviation
Meters
%)2
(gal)
Irrigation Controller
32
13,450
23,470
21,100
90%
58,970
Irrigation Nozzle/Head
66
13,850
20,130
8,580
43%
35,810
Rain Sensor3
11
4,520
9,810
10,640
109%
18,010
Sprinkler Audit
748
8,670
13,840
2,190
16%
30,390
1. Confidence interval defined for a 95% confidence level.
2. Relative confidence interval calculated as the absolute confidence level divided by the mean.
3. Too small a sample to provide any statistical significance and should not be the
basis for any policy decision.
Table 4 Summary of control adjusted total water use changes by
measure (a positive number signifies a reduction in use)
Program/Measure
Annual Total Use Change per
Confidence Interval for Average
Program Participant
Change
Number
Media
Ave rag
Absolut
Relative
Standard
of
n
e
e (+/-
(+/- %)2
Deviation
Meters
(gal)
(gal)
gal)
(gal)
Clothes Washer
1,825
7,720
8,430
1,040
12%
22,590
Dishwasher
1,186
2,690
4,140
1,310
32%
22,920
Toilet
588
6,850
8,920
1,900
21%
23,560
Irrigation Controller
32
12,260
22,560
26,450
117%
76,320
Irrigation Nozzle/Head
66
4,260
6,440
5,590
87%
23,160
Rain Sensor3
11
-3,640
2,520
8,690
345%
14,700
Sprinkler Audit
748
2,750
4,190
1,710
41%
23,910
1. Confidence interval defined for a 95% confidence level.
2. Relative confidence interval calculated as the absolute confidence level divided by the mean.
3. Too small a sample to provide any statistical significance and should not be the
basisfor any policy decision.
November 19, 2015
57
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