EPA

Water Sense

Summary of Comments on Notice of Recent
Specifications Review and Request for Information

on WaterSense Program

Docket Number EPA-HQ-OW-2020-0026

August 2020


-------
Water Sense

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Table of Contents

I.	Introduction and Summary	1

II.	List of Comments Received	3

III.	Comments with Multiple Signatories	17

IV.	Compiled Comments on Notice of Recent Specifications Review and Request for
Information on WaterSense Program	19

List of Tables

Table 1. Summary of Commenter Affiliations	2

Table 2. Summary of Comment Tenor	2

Table 3. Summary of Support for Incorporating Customer Satisfaction into

WaterSense Specifications and Development Guidelines	3

Table 4. Summary of Other Topics Discussed in Comments	3

Table 5. List of Commenters	4

Table 6. AWE Comment Letter Signatories	17

Table 7. CAIOU Comment Letter Signatories	18

Table 8. PILC Comment Letter Signatories	19

i	August 2020


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Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

I. Introduction and Summary

On April 10, 2020, the U.S. Environmental Protection Agency (EPA) published a Notice
of Recent Specifications Review and Request for Information on WaterSense Program
in the Federal Register (85 FR 20268) and accepted public comments through July 24,
2020 through the associated Docket, EPA-HQ-QW-2020-0026. With the Federal
Register Notice (FRN), EPA announced the completion of the review of the WaterSense
product performance criteria as required under the America's Water Infrastructure Act
(AWIA) of 2018. EPA also sought information to help it assess consumer satisfaction
with WaterSense labeled products.

The FRN requested feedback on three specific issues. The text below in bold reflects the
text from the Summary section of the FRN. It is followed by the description of the request
in Section V of the FRN.

1.	EPA is seeking input and requesting information on any data, surveys, or
studies to help assess consumer satisfaction with WaterSense labeled
products, which could inform future product specification development.

Section V. text: Specifically, the EPA is requesting information on any data, surveys,
or studies that have assessed consumer satisfaction with WaterSense labeled or
standard products.

2.	EPA is also seeking input on how to design a study or studies to inform future
reviews that incorporate customer satisfaction considerations.

Section V. text: Specifically, the EPA is seeking input on how it could design a study
or studies for use in future reviews that incorporate customer considerations. For
example, we are interested in input on how we could use a survey or surveys to
determine what type of products consumers would like to see on the market, the
performance attributes that are important to consumer choice and satisfaction, the
range of performance customers are seeking in those attributes, and what additional
features or options related to efficiency consumers would like to see in WaterSense
products. The EPA is also interested in input on the collection method, frequency,
and source of the information as we seek to balance any burden the collection would
impose on the public with the usefulness the information would provide the Agency.

3.	EPA is also requesting input on whether it should include consumer
satisfaction criteria into the WaterSense program guidelines and, if included,
what criteria should be considered and how.

Section V text: Lastly, the EPA seeks input on whether there are specific consumer
satisfaction considerations, test methods, or additional criteria it should consider
adding to the WaterSense guidelines.

EPA received 110 public comments in response to the FRN, 43 of which were submitted
anonymously. Three of the comments had multiple signatories representing 81
organizations. Section II provides a list of the commenters and their associated
affiliations. Section III provides a list of the additional organizations that signed on to
individual comment letters. Section IV includes a verbatim compilation of the comments
and comment attachments, as received through Docket, EPA-HQ-QW-2020-0026.

4

EPA

WaterSense

1

August 2020


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Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

The remainder of this section provides a brief summary of the commenter affiliations and
comment content.

Table 1 summarizes the number of comment letters received, by affiliation type.

Table 1. Summary of Commenter Affiliations

Category

Number of Comments

General Public

58

Utilities (Water and Energy)

20

Associations and Non-Governmental
Organizations

19

Private Sector

7

Governmental

6

Table 2 summarizes the general tenor of the content of each comment.

Table 2. Summary of Comment Tenor

Category

Number of Comments

Positive/Supportive of WaterSense Program

98

Neutral Toward the WaterSense Program

6

Negative Toward the WaterSense Program

1

Duplicate or Off-topic Comments

5

Table 3 summarizes the general posture of the comments toward incorporating
customer satisfaction into WaterSense specifications and the WaterSense specification
development guidelines.

4

EPA

WaterSense

2

August 2020


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Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Table 3. Summary of Support for Incorporating Customer Satisfaction into
WaterSense Specifications and Development Guidelines (Issue #3)

Category

Number of
Comments

Explicitly Supported Including Customer Satisfaction in
Specifications/Guidelines

0

Explicitly Opposed to Including Customer Satisfaction in
Specification/Guidelines

43

Unclear Response

3

No Comment (i.e., comment did not explicitly address)

59

N/A (e.g., duplicate or off-topic)

5

Table 4 summarizes other common topics or themes discussed within the comments.

Table 4. Summary of Other Topics Discussed in Comments

Category

Number of
Comments

Provided Input on Data, Surveys, and/or Studies (Issue #1)

16

Provided Input on Design of Surveys or Studies (Issue #2)

11

Noted that Customer Satisfaction is Already a Consideration for
Performance Criteria in Specifications

8

Supported EPA in Evaluating Customer Satisfaction as a Means to
Improve WaterSense Brand

10

Mentioned Customer Satisfaction with Products Installed Through
Rebates

8

Supported Decision Not to Revise WaterSense Specifications

12

Called for Specifications to Strengthen Water Efficiency Criteria (i.e.,
reduce flow rates/flush volume limits)

6

Provided Other Suggestions for Program Improvement

6

II. List of Comments Received

Table 5 provides a list of the commenters that submitted comments on the FRN, in order
of receipt to the Docket. Rows shaded in green had comments with a positive tenor
supportive of the WaterSense program. Rows shaded in yellow had comments with a
neutral tenor, and rows shaded in red had a negative tenor. Rows without shading had
comments that were off topic (e.g. request for an extension). The table also identifies the
commenter's affiliation type and the Docket ID number for reference back to the original
comment. Section IV provides the verbatim comments for each commenter.

4

EPA

WaterSense

3

August 2020


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Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Table 5. Summary of Commenters and Feedback on Issues from FRN

Document ID

Page
Number

Commenter

Organization

Affiliation

Provided Input
on Data,
Surveys,
and/or Studies
(Issue #1)

Provided
Input on
Design of
Surveys or
Studies
(Issue #2)

Include
Customer
Satisfaction in
Specifications
and Development
Guidelines (Issue
#3)

EPA-HQ-OW-
2020-0026-0002

20

Anonymous

None

GP

No

No

No Comment

EPA-HQ-OW-
2020-0026-0003

21

Anonymous

None

GP

Yes

No

No Comment

EPA-HQ-OW-
2020-0026-0004

22

Anonymous

None

GP

No

No

No Comment

EPA-HQ-OW-
2020-0026-0005

23

Anonymous

None

GP

No

No

No Comment

EPA-HQ-OW-
2020-0026-0006

24

Anonymous

None

GP

No

No

No Comment

EPA-HQ-OW-
2020-0026-0007

25

K. Luther

None

GP

No

No

No Comment

EPA-HQ-OW-
2020-0026-0008

26

Anonymous

None

GP

No

No

No Comment

EPA-HQ-OW-
2020-0026-0009

27

Anonymous

None

GP

No

No

No Comment

EPA-HQ-OW-
2020-0026-0010

28

Anonymous

None

GP

Yes

No

No Comment

EPA-HQ-OW-
2020-0026-0011

29

Anonymous

None

GP

No

No

No Comment

EPA-HQ-OW-
2020-0026-0012

30

S. Cohen

None

GP

No

No

No Comment

EPA-HQ-OW-
2020-0026-0013

31

Anonymous

None

GP

No

No

No Comment

EPA-HQ-OW-
2020-0026-0014

32

Mary Ann Dickinson,
President and Chief
Executive Officer

Alliance for
Water Efficiency
(AWE)

A

No

No

Not Applicable

4

EPA

WaterSense

4

August 2020


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Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Table 5. Summary of Commenters and Feedback on Issues from FRN

Document ID

Page
Number

Commenter

Organization

Affiliation

Provided Input
on Data,
Surveys,
and/or Studies
(Issue #1)

Provided
Input on
Design of
Surveys or
Studies
(Issue #2)

Include
Customer
Satisfaction in
Specifications
and Development
Guidelines (Issue
#3)

EPA-HQ-OW-
2020-0026-0015

34

Darcey Peterson,
General Manager

King County
Water District
Number 90

U

No

No

No Comment

EPA-HQ-OW-
2020-0026-0016

35

Department of Water
and Power

City of Big Bear
Lake

U

No

No

No Comment

EPA-HQ-OW-
2020-0026-0017

36

Dain M. Hansen,
Executive Vice
President,

Government Relations

International
Association of
Plumbing and
Mechanical
Officials
(IAPMO)

A

No

No

Not Applicable

EPA-HQ-OW-
2020-0026-0018

38

Anonymous

None

GP

No

No

No

EPA-HQ-OW-
2020-0026-0019

39

Anonymous

None

GP

Yes

No

No Comment

EPA-HQ-OW-
2020-0026-0020

40

Anonymous

None

GP

No

No

No Comment

EPA-HQ-OW-
2020-0026-0021

41

Anonymous

None

GP

No

No

No Comment

EPA-HQ-OW-
2020-0026-0022

42

Anonymous

None

GP

No

No

No Comment

EPA-HQ-OW-
2020-0026-0023

43

W. Hammond

None

GP

No

No

No Comment

EPA-HQ-OW-
2020-0026-0024

44

Anonymous

None

GP

No

No

No Comment

EPA-HQ-OW-
2020-0026-0025

45

Anonymous

None

GP

No

No

No Comment

4

EPA

WaterSense

5

August 2020


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Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Table 5. Summary of Commenters and Feedback on Issues from FRN

Document ID

Page
Number

Commenter

Organization

Affiliation

Provided Input
on Data,
Surveys,
and/or Studies
(Issue #1)

Provided
Input on
Design of
Surveys or
Studies
(Issue #2)

Include
Customer
Satisfaction in
Specifications
and Development
Guidelines (Issue
#3)

EPA-HQ-OW-
2020-0026-0026

46

Ray Hoffman, Chief
Executive Officer
(CEO)

Cascade Water
Alliance

U

No

No

No

EPA-HQ-OW-
2020-0026-0027

48

Anonymous

None

GP

No

No

No Comment

EPA-HQ-OW-
2020-0026-0028

49

Anonymous

None

GP

No

No

No Comment

EPA-HQ-OW-
2020-0026-0029

50

Anonymous

None

GP

No

No

No Comment

EPA-HQ-OW-
2020-0026-0030

51

Anonymous

None

GP

No

No

No Comment

EPA-HQ-OW-
2020-0026-0031

52

Anonymous

None

GP

No

No

No Comment

EPA-HQ-OW-
2020-0026-0032

53

Anonymous

None

GP

No

No

No Comment

EPA-HQ-OW-
2020-0026-0033

54

Anonymous

None

GP

No

No

No Comment

EPA-HQ-OW-
2020-0026-0034

55

Anonymous

None

GP

No

No

No Comment

EPA-HQ-OW-
2020-0026-0035

56

Anonymous

None

GP

No

No

No

EPA-HQ-OW-
2020-0026-0036

57

V. Meyer Nixon

None

GP

No

No

No

EPA-HQ-OW-
2020-0026-0037

58

Anonymous

None

GP

No

No

No

EPA-HQ-OW-
2020-0026-0038

59

Anonymous

None

GP

No

No

No

4

EPA

WaterSense

6

August 2020


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Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Table 5. Summary of Commenters and Feedback on Issues from FRN

Document ID

Page
Number

Commenter

Organization

Affiliation

Provided Input
on Data,
Surveys,
and/or Studies
(Issue #1)

Provided
Input on
Design of
Surveys or
Studies
(Issue #2)

Include
Customer
Satisfaction in
Specifications
and Development
Guidelines (Issue
#3)

EPA-HQ-OW-
2020-0026-0039

60

A. Sholinbeck

None

GP

No

No

No

EPA-HQ-OW-
2020-0026-0040

61

Anonymous

None

GP

No

No

No

EPA-HQ-OW-
2020-0026-0041

62

Anonymous

None

GP

No

No

No

EPA-HQ-OW-
2020-0026-0042

63

Anonymous

None

GP

No

No

No

EPA-HQ-OW-
2020-0026-0043

64

Anonymous

None

GP

No

No

No

EPA-HQ-OW-
2020-0026-0044

65

Kerry Stackpole, Chief
Executive Officer
(CEO) and Executive
Director

Plumbing
Manufacturers
International
(PMI)

A

No

No

Not Applicable

EPA-HQ-OW-
2020-0026-0045

67

Anonymous

None

GP

No

No

No Comment

EPA-HQ-OW-
2020-0026-0046

68

Anonymous

None

GP

No

No

No Comment

EPA-HQ-OW-
2020-0026-0047

69

Shelley Flock,
Conservation and
Customer Service
Field Manager and
Ron Duncan, General
Manager

Soquel Creek
Water District

U

No

No

No Comment

EPA-HQ-OW-
2020-0026-0048

71

Jennifer Burke,
Director of Water

City of Santa
Rosa Water
Department

U

No

Yes

No

4

EPA

WaterSense

7

August 2020


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Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Table 5. Summary of Commenters and Feedback on Issues from FRN

Document ID

Page
Number

Commenter

Organization

Affiliation

Provided Input
on Data,
Surveys,
and/or Studies
(Issue #1)

Provided
Input on
Design of
Surveys or
Studies
(Issue #2)

Include
Customer
Satisfaction in
Specifications
and Development
Guidelines (Issue
#3)

EPA-HQ-OW-
2020-0026-0049

75

Thomas A. Love,
General Manager

Upper San
Gabriel Valley
Municipal Water
District

U

No

No

No

EPA-HQ-OW-
2020-0026-0050

77

C. Boyd

None

GP

No

No

No Comment

EPA-HQ-OW-
2020-0026-0052

78

Grant Davis, General
Manager

Sonoma County
Water Agency
(Sonoma Water)

U

No

No

No

EPA-HQ-OW-
2020-0026-0053

81

Anonymous

None

GP

No

No

No Comment

EPA-HQ-OW-
2020-0026-0054

82

Anonymous

None

GP

No

No

No Comment

EPA-HQ-OW-
2020-0026-0055

83

Anonymous

None

GP

No

No

No Comment

EPA-HQ-OW-
2020-0026-0056

84

Anonymous

None

GP

No

No

No Comment

EPA-HQ-OW-
2020-0026-0057

85

Anonymous

C+C, Inc.

P

No

No

No Comment

EPA-HQ-OW-
2020-0026-0058

86

Anonymous

None

GP

No

No

No Comment

EPA-HQ-OW-
2020-0026-0059

87

Anonymous

None

GP

No

No

No

EPA-HQ-OW-
2020-0026-0060

88

Mark Fagin, Chair

Regional Water
Providers
Consortium
Board

U

No

Yes

No

4

EPA

WaterSense

8

August 2020


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Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Table 5. Summary of Commenters and Feedback on Issues from FRN

Document ID

Page
Number

Commenter

Organization

Affiliation

Provided Input
on Data,
Surveys,
and/or Studies
(Issue #1)

Provided
Input on
Design of
Surveys or
Studies
(Issue #2)

Include
Customer
Satisfaction in
Specifications
and Development
Guidelines (Issue
#3)

EPA-HQ-OW-
2020-0026-0061

90

Kristen Johnson,
Government Affairs
Specialist

Coachella
Valley Water
District (CVWD)

U

No

No

No

EPA-HQ-OW-
2020-0026-0062

93

Brad Coffey, Manager,
Water Resource
Management

Metropolitan
Water District of
Southern
California

U

No

No

No

EPA-HQ-OW-
2020-0026-0063

97

Richard F. Harasick,
Senior Assistant
General Manager,
Water Systems

Los Angeles
Department of
Water and
Power (LADWP)

u

No

Yes

No

EPA-HQ-OW-
2020-0026-0064

103

Anonymous

None

GP

No

No

No

EPA-HQ-OW-
2020-0026-0065

104

G. Tracy Mehan, III,
Executive Director,
Government Affairs

American Water
Works
Association
(AWWA)

A

Yes

Yes

No

EPA-HQ-OW-
2020-0026-0066

110

E. Joaquin Esquivel,
Chair

California State
Water
Resources
Control Board

G

No

No

No

EPA-HQ-OW-
2020-0026-0067

114

D. Epley

None

GP

No

No

No

EPA-HQ-OW-
2020-0026-0068

115

Peter Mayer, Principal

WaterDM

P

Yes

No

No

4

EPA

WaterSense

9

August 2020


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Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Table 5. Summary of Commenters and Feedback on Issues from FRN

Document ID

Page
Number

Commenter

Organization

Affiliation

Provided Input
on Data,
Surveys,
and/or Studies
(Issue #1)

Provided
Input on
Design of
Surveys or
Studies
(Issue #2)

Include
Customer
Satisfaction in
Specifications
and Development
Guidelines (Issue
#3)

EPA-HQ-OW-
2020-0026-0069

122

Jennifer L. Perry,
Director, Water
Planning and
Management Division

Connecticut
Department of
Energy and
Environmental
Protection (CT
DEEP)

G

No

No

No

EPA-HQ-OW-
2020-0026-0070

125

K. Robinson

None

GP

No

No

No

EPA-HQ-OW-
2020-0026-0071

126

Anonymous

None

GP

No

No

No Comment

EPA-HQ-OW-
2020-0026-0072

127

M. Magana

None

GP

No

No

No Comment

EPA-HQ-OW-
2020-0026-0073

128

Rick L. Callender,
Chief of External
Affairs

Santa Clara
Valley Water
District (Valley
Water)

U

No

No

No

EPA-HQ-OW-
2020-0026-0074

131

Erik Hitchman,
General Manager

Walnut Valley
Water District
(WVWD)

U

No

No

No Comment

EPA-HQ-OW-
2020-0026-0075

133

Kelly Kopp, Director

Center for
Water Efficient
Landscaping,
Utah State
University

G

No

No

No

EPA-HQ-OW-
2020-0026-0076

136

Rick Maloy, President

Utah Water

Conservation

Forum

A

No

No

No

4

EPA

WaterSense

10

August 2020


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Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Table 5. Summary of Commenters and Feedback on Issues from FRN

Document ID

Page
Number

Commenter

Organization

Affiliation

Provided Input
on Data,
Surveys,
and/or Studies
(Issue #1)

Provided
Input on
Design of
Surveys or
Studies
(Issue #2)

Include
Customer
Satisfaction in
Specifications
and Development
Guidelines (Issue
#3)

EPA-HQ-OW-
2020-0026-0077

139

Donald F. Greeley,
Director

City of Durham
Department of
Water

Management
(DMW)

U

No

No

No

EPA-HQ-OW-
2020-0026-0078

142

Katherine Zitsch,
Director

Metropolitan
North Georgia
Water Planning
District

U

Yes

No

No Comment

EPA-HQ-OW-
2020-0026-0079

151

M. Martynowych

None

GP

No

No

No Comment

EPA-HQ-OW-
2020-0026-0080

152

S. Elsa-Beech

None

GP

No

No

No

EPA-HQ-OW-
2020-0026-0081

153

Elizabeth Beardsley,
Senior Policy Counsel

U.S. Green
Building Council
(USGBC)

A

No

No

No

EPA-HQ-OW-
2020-0026-0082

157

Clifford C. Chan,
General Manager

East Bay
Municipal Utility
District
(EBMUD)

U

No

No

No Comment

EPA-HQ-OW-
2020-0026-0083

159

Steven Westphal,
Senior Legal Director,
Commercial

Kohler Co.

P

Yes

No

Unclear

EPA-HQ-OW-
2020-0026-0084

162

J.Jonker

None

GP

No

No

No Comment

EPA-HQ-OW-
2020-0026-0085

163

S. Orum

None

GP

No

No

No Comment

4

EPA

WaterSense

11

August 2020


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Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Table 5. Summary of Commenters and Feedback on Issues from FRN

Document ID

Page
Number

Commenter

Organization

Affiliation

Provided Input
on Data,
Surveys,
and/or Studies
(Issue #1)

Provided
Input on
Design of
Surveys or
Studies
(Issue #2)

Include
Customer
Satisfaction in
Specifications
and Development
Guidelines (Issue
#3)

EPA-HQ-OW-
2020-0026-0086

164

Morgan Shimabuku,
Research Associate
and Peter H. Gleick,
President-emeritus

Pacific Institute

A

No

No

No Comment

EPA-HQ-OW-
2020-0026-0087

168

Anonymous

None

GP

No

No

No Comment

EPA-HQ-OW-
2020-0026-0088

169

Pluvial Solutions



P

No

No

No Comment

EPA-HQ-OW-
2020-0026-0089

172

Gabe Maser, Vice
President,

Government Relations

International
Code Council
(ICC)

A

No

No

No

EPA-HQ-OW-
2020-0026-0090

176

B. Grimm

None

GP

No

Yes

No Comment

EPA-HQ-OW-
2020-0026-0091

177

N/A

Alliance for
Water Efficiency
(AWE) et al.

A

Yes

Yes

No

EPA-HQ-OW-
2020-0026-0092

190

Brett Little

GreenHome
Institute

P

No

No

No Comment

EPA-HQ-OW-
2020-0026-0093

191

lyn S. Toole, Assistant
Vice President,
Sustainability & Green
Building

National
Association of
Home Builders
(NAHB)

A

Yes

Yes

No Comment

EPA-HQ-OW-
2020-0026-0094

213

Clayton Traylor, Vice
President (VP)

Leading
Builders of
America (LBA)

A

No

No

No

4

EPA

WaterSense

12

August 2020


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Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Table 5. Summary of Commenters and Feedback on Issues from FRN

Document ID

Page
Number

Commenter

Organization

Affiliation

Provided Input
on Data,
Surveys,
and/or Studies
(Issue #1)

Provided
Input on
Design of
Surveys or
Studies
(Issue #2)

Include
Customer
Satisfaction in
Specifications
and Development
Guidelines (Issue
#3)

EPA-HQ-OW-
2020-0026-0095

216

Dain M. Hansen,
Executive Vice
President

International
Association of
Plumbing and
Mechanical
Officials
(IAPMO)

A

Yes

Yes

No

EPA-HQ-OW-
2020-0026-0096

221

Eric Olson, Senior
Product Manager, and
Louis Starr, Energy
Codes and Standards
Engineer

Northwest
Energy
Efficiency
Alliance (NEEA)

A

No

No

Unclear



Megan Geuss, Policy
Associate

Appliance
Standard
Awareness
Project (ASAP)

A

EPA-HQ-OW-
2020-0026-0097

224

Stan Hazan, Sr.
Director, Regulatory
Affairs

NSF

International
(NSF)

P

No

No

No Comment

EPA-HQ-OW-
2020-0026-0098

227

Patrick Eilert,
Manager, Codes &
Standards

Pacific Gas and

Electric

Company

U

Yes

No

No



Karen Klepack, Senior
Manager, Building
Electrification and
Codes & Standards

Southern
California
Edison

U

4

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August 2020


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Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Table 5. Summary of Commenters and Feedback on Issues from FRN

Document ID

Page
Number

Commenter

Organization

Affiliation

Provided Input
on Data,
Surveys,
and/or Studies
(Issue #1)

Provided
Input on
Design of
Surveys or
Studies
(Issue #2)

Include
Customer
Satisfaction in
Specifications
and Development
Guidelines (Issue
#3)





Kate Zeng,
ETP/C&S/ZNE
Manager, Customer
Programs

San Diego Gas
and Electric
Company

U







EPA-HQ-OW-
2020-0026-0099

232

David Hochschild,
Chair

California
Energy
Commission
(CEC)

G

No

No

No

EPA-HQ-OW-
2020-0026-0100

239

Denise L. Schmidt,
Administrator of the
Division of Water
Utility Regulation and
Analysis, and Kristy
Nieto, Administrator of
the Division of Digital
Access, Consumer
and Environmental
Affairs

Public Service
Commission of
Wisconsin

G

No

No

No Comment

4

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Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Table 5. Summary of Commenters and Feedback on Issues from FRN

Document ID

Page
Number

Commenter

Organization

Affiliation

Provided Input
on Data,
Surveys,
and/or Studies
(Issue #1)

Provided
Input on
Design of
Surveys or
Studies
(Issue #2)

Include
Customer
Satisfaction in
Specifications
and Development
Guidelines (Issue
#3)

EPA-HQ-OW-
2020-0026-0101

242

Jennifer L. Jurado,
Director and Chief
Resilience Officer

Broward

County's

Environmental

Planning and

Community

Resilience

Division

G

No

No

No

EPA-HQ-OW-
2020-0026-0102

245

Kerry Stackpole, Chief
Executive Officer
(CEO)/Executive
Director

Plumbing
Manufacturers
International
(PMI)

A

Yes

Yes

No Comment

EPA-HQ-OW-
2020-0026-0103

251

M. Villere

None

GP

No

No

No

EPA-HQ-OW-
2020-0026-0104

252

N/A

Plumbing
Industry
Leadership
Coalition (PILC)
et al.

A

Yes

Yes

No

EPA-HQ-OW-
2020-0026-0105

256

David Searcy,

Conservation

Coordinator

Medford Water

Commission

(MWC)

U

No

No

No Comment

EPA-HQ-OW-
2020-0026-0106

258

Candice Rupprecht,
Water Conservation
Manager

Tucson Water,
City of Tucson,
AR

U

No

No

No

EPA-HQ-OW-
2020-0026-0107

261

John Farner,
Government and
Public Affairs Director

Irrigation
Association

A

No

No

No Comment

4

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Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Table 5. Summary of Commenters and Feedback on Issues from FRN

Document ID

Page
Number

Commenter

Organization

Affiliation

Provided Input
on Data,
Surveys,
and/or Studies
(Issue #1)

Provided
Input on
Design of
Surveys or
Studies
(Issue #2)

Include
Customer
Satisfaction in
Specifications
and Development
Guidelines (Issue
#3)

EPA-HQ-OW-
2020-0026-0108

264

Gregory J. Walch,
Chairman

Western Urban
Water Coalition
(WUWC)

U

Yes

Yes

Unclear

EPA-HQ-OW-
2020-0026-0109

269

Mary Ann Dickinson,
President and Chief
Executive Officer
(CEO) (original letter)

Alliance for
Water Efficiency
(AWE) et al.

A

No

No

Not Applicable

EPA-HQ-OW-
2020-0026-0110

282

Mary Ann Dickinson,
President and Chief
Executive Officer
(CEO) (re:
showerheads)

Alliance for
Water Efficiency
(AWE) et al.

A

No

No

Not Applicable

EPA-HQ-OW-
2020-0026-0111

287

Mary Ann Dickinson,
President and Chief
Executive Officer
(CEO)

Alliance for
Water Efficiency
(AWE) et al.

A

Yes

No

No Comment

EPA-HQ-OW-
2020-0026-0112

294

Mike Collignon,
Executive Director

Green Builder
Coalition

P

Yes

No

No

A: Association or Non-governmental Organization

G: Government

GP: General Public/Anonymous

P: Private Sector

U: Utility

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Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

III. Comments with Multiple Signatories

Three organizations submitted letters with multiple signatories representing 81
organizations as follows.

Alliance for Water Efficiency

In comment EPA-HQ-OW-2020-0026-0091, the Alliance for Water Efficiency (AWE)
submitted comments on behalf of 62 organizations. These organizations are listed in
Table 6 below.

Table 6. AWE Comment Letter Signatories

Organization

Organization

Alameda County Water District (California)

National Wildlife Federation

Alliance for Water Efficiency (AWE)

O'Cain Consulting

American Supply Association (ASA)

Peter Williams Solutions LLC

American Water

Plumbing-Heating-Cooling Contractors
(PHCC)-National Association

American Water Works Association
(AWWA)

Rancho Water

Arizona Municipal Water Users
Association

Regional Water Authority (California)

Amy Vickers and Associates

Santa Rosa Water (California)

Bottom Line Utility Solutions

Sacramento Suburban Water District
(California)

C+C, Inc

San Francisco Public Utilities
Commission (California)

California Water Efficiency Partnership

Scottsdale Water (Arizona)

City of Ashland (Oregon)

SCV Water (California)

City of Bellingham (Washington)

Sonoma-Marin Saving Water Partnership

City of Bend (Oregon)

Sonoma Water (California)

City of Big Bear Lake Department of Water
(California)

Soquel Creek Water District (California)

City of Charlottesville (Virginia)

Southern Nevada Water Authority
(Nevada)

City of Durham (North Carolina)

T&S Brass and Bronze Works

City of Flagstaff (Arizona)

Tacoma Water (Washington)

City of Mesa (Arizona)

Texas Water Foundation

City of Sacramento (California)

Turfgrass Water Conservation Alliance

City of Westminster (California)

Utah State University, Center for Water
Efficient Landscaping

Coachella Valley Water District (California)

United Association of Journeymen and
Apprentices of the Plumbing and Pipe
Fitting Industry of the United States,
Canada (UA)

4

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Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Table 6. AWE Comment Letter Signatories

Organization

Organization

Denver Water (Colorado)

Upper San Gabriel Valley Municipal
Water District (California)

EcoSystems, LLC

Utah Water Conservation Forum

Hawaii Commission on Water Resource
Management

Valley County Water District (California)

International Association of Plumbing and
Mechanical Officials (IAPMO)

Valley Water (California)

Las Vegas Valley Water District (Nevada)

Water Use it Wsely

Mesa Water (California)

Water Supply Citizens Advisory
Committee to Massachusetts Water
Resources Authority

Metropolitan North Georgia Water
Planning District (Georgia)

WaterDM

Metropolitan Water District of Southern
California (California)

Waterless Co

Monte Vista Water District (California)

WaterNow Alliance

Municipal Water District of Orange County
(California)

Western Urban Water Coalition

California Investor Owned Utilities

As part of comment EPA-HQ-QW-2020-0026-0098. California Investor Owned Utilities
(CA-IOU) submitted comments on behalf of 3 organizations. These organizations are
listed in Table 7 below.

Table 7. CA-IOU Comment Letter Signatories

Organizations

Pacific Gas and Electric Company
(PG&E)

Southern California Edison (SCE)

San Diego Gas and Electric (SDG&E)



Plumbing Industry Leadership Coalition

As part of comment EPA-HQ-OW-2020-0026-0104, the Plumbing Industry Leadership
Coalition (PILC) submitted comments on behalf of 16 member organizations. These
organizations are listed in Table 8 below.

4

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Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Table 8. PILC Comment Letter Signatories

Organizations

Alliance for Water Efficiency

Mechanical Hub

American Society of Plumbing Engineers
(ASPE)

Plumbing Contractors of America

American Supply Association (ASA)

Plumbing-Heating-Cooling Contractors—
National Association

American Society of Sanitary Engineering
(ASSE)

Plumbing & Mechanical Group (BNP
Media, Inc.)

Copper Development Association, Inc.

Plastic Pipe and Fittings Association
(PPFA)

International Association of Plumbing and
Mechanical Officials (IAPMO)

Plumbing Industry Leadership Coalition
(PILC)

International Code Council

The American Rainwater Catchment
Systems Association

Mechanical Contractors Association of
America

The United Association of Journeymen
and Apprentices of the Plumbing and
Pipe Fitting Industry of the United States,
Canada (UA)

IV. Compiled Comments on Notice of Recent Specifications Review and
Request for Information on WaterSense Program

The following is a compilation of the comments and comment attachments submitted to
Docket Number EPA-HQ-OW-2020-0026 in response to EPA's Notice of Recent
Specifications Review and Request for Information on WaterSense Program. The
comments appear in order of receipt to the Docket and with no editorial changes to the
comments (e.g., spelling, grammar).

4

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WaterSense

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Anonymous
Affiliation: Anonymous
Comment Date: April 11, 2020
Document ID: EPA-HQ-OW-2020-0026-0002

Comment Text:

I recommend the water sense be made mandatory with strict compliance and penalties
to include prison for failing to participate.

20

August 2020


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Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Anonymous
Affiliation: Anonymous
Comment Date: April 15, 2020
Document ID: EPA-HQ-OW-2020-0026-0003

Comment Text:

I fully support the EPA's WaterSense program. The 2016 Residential End Use Study
found that toilet double-flushing was not a statistically significant finding for high
efficiency toilets. I believe President Trump is attacking this program to rile up his base
of supporters. Water efficiency is critically important. It prolongs the life of our
infrastructure, it saves consumers money, and it protects a precious, limited resource.

4

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WaterSense

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Anonymous
Affiliation: Anonymous
Comment Date: April 30, 2020
Document ID: EPA-HQ-OW-2020-0026-0004

Comment Text:

I bought a Delta WaterSense certified toilet last summer of 2019 and installed it at my
home. Its been working great and we love it. It saves water and takes care of business.
Please keep this program going.

22

August 2020


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EPA

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

WaterSense

Commenter: Anonymous
Affiliation: Anonymous
Comment Date: April 30, 2020
Document ID: EPA-HQ-OW-2020-0026-0005

Comment Text:

biggest waste of money ever. Has done nothing to save water, in many situations people
use more water because of waternonsense.

23

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EPA

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

WaterSense

Commenter: Anonymous
Affiliation: Anonymous
Comment Date: April 30, 2020
Document ID: EPA-HQ-OW-2020-0026-0006

Comment Text:

One recommendation is that this is also discussed with the water reclamation facilities
that are now having problems in the plants with less and less water flow coming into
their facilities. We need to be careful in making flow rates less and less for showers,
lavs, etc. might be doing more harm then good. We have also seen a large jump in
Legionella since water flow rates are continuing to decline. These need to be discussed
with organizations like ASPE who can help in these efforts to make more sense for this
industry.

24

August 2020


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Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Kathy Luther
Affiliation: General Public
Comment Date: April 30, 2020
Document ID: EPA-HQ-OW-2020-0026-0007

Comment Text:

We love the WaterSense labeling system. It is a great tool to help me identify efficient
products, which is important to me. Labeling programs such as WaterSense allow the
free market to work by providing important information to consumers. Wthout this
information, people can't make informed choices. People interested in saving money,
building our economy sustainably, and preserving water resources for future need this
tool in order to make intelligient and rational decisions with their money.

Kathy Luther,

Indiana District 1

1703 Boca Lago, Valparaiso IN 46383

4

EPA

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25

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EPA

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

WaterSense

Commenter: Anonymous
Affiliation: Anonymous
Comment Date: April 30, 2020
Document ID: EPA-HQ-OW-2020-0026-0008

Comment Text:

The WaterSense label has been very helpful to me in both my personal and professional
life. Keep up the good work!

26

August 2020


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EPA

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

WaterSense

Commenter: Anonymous
Affiliation: Anonymous
Comment Date: April 30, 2020
Document ID: EPA-HQ-OW-2020-0026-0009

Comment Text:

I worked in hotel water conservation for many years and the Water Sense line of
products and the program overall is excellent and by no means should be jettisoned.
Businesses look for certified products as a way of guiding them through the morass of
options. I have no idea what would compel you to get rid of a program that helps both
businesses and residents.

27

August 2020


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Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Anonymous
Affiliation: Anonymous
Comment Date: April 30, 2020
Document ID: EPA-HQ-OW-2020-0026-0010

Comment Text:

I have personally been responsible for the installation of thousands of WaterSense
products (toilets, showerheads, faucet aerators, and Pre-Rinse Spray Valves) through a
position I held at an organization in Colorado that worked with water providers on water
conservation and efficiency. Myself and my employees installed WaterSense products in
both residential and commercial buildings. We requested feedback from every customer
after installation and use. We received an overwhelming amount of positive feedback on
all of these products. If issues arose, which was seldom, we would offer free
replacements if the issue could not be fixed by our technician, and we almost never
received additional complaints. Furthermore, I personally have installed and used
WaterSense toilets, showerheads, and faucet aerators in my own home and love how
they function. My family and I have not found them to have any performance difference
compared to non-WaterSense products, other than often times performing better.

Please keep and expand the WaterSense program. It is vital to ensuring a sustainable
water supply, in addition to helping save people and businesses energy and money.

4

EPA

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WaterSense

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Anonymous

Affiliation: Anonymous

Comment Date: May 1, 2020

Document ID: EPA-HQ-OW-2020-0026-0011

Comment Text:

We have found great value in the watersense program enabling us to make informed
choices in the purchase of our home appliances.

29

August 2020


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EPA

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

WaterSense

Commenter: Sara Cohen

Affiliation: General Public

Comment Date: May 1, 2020

Document ID: EPA-HQ-OW-2020-0026-0012

Comment Text:

I have a WaterSense shower head and enjoy my shower more now than I did with our
higher flow device. We also have WaterSense appliances. I really value the certification
and knowing that these products work well while saving water and energy. I know that
nationwide, the WaterSense program has helped to save trillions of gallons of water and
billions of dollars in water and energy costs. Please retain and strengthen this very
popular program. - Sara Cohen, Medford, MA

30

August 2020


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Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Anonymous

Affiliation: Anonymous

Comment Date: May 1, 2020

Document ID: EPA-HQ-OW-2020-0026-0013

Comment Text:

As a Water Conservation Coordinator located in the driest state of the United States, I
do not know how we could educate the customers without having researched- based
factual information and real numbers to provide to our customers without the ability and
information provided to us at no charge by WaterSense. Without WaterSense,
manufactures have no reason to compete and produce better water conservation
devices. WaterSense not only provides incentives to producers, but also educate the
very young and old with stimulating games, visuals, infographics, videos for youth and
adults.

4

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Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Mary Ann Dickinson, President and Chief Executive Officer

Affiliation: Alliance for Water Efficiency

Comment Date: May 4, 2020

Document ID: EPA-HQ-OW-2020-0026-0014

Comment Text:
See attached file(s)
Attachment

See page 33.

4

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May 4, 2020

Mr. David Ross

Assistant Administrator, Office of Water
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Washington, DC 20460

Re: Request for 60-Day Extension of the Comment Period Relating to the Request for
Information on WaterSense," 85 Fed. Reg. 20,268 (April 10, 2020) - Docket No. [EPA-HQ-
OW-2020-0026}

Dear Assistant Administrator Ross:

Alliance

Water

We are requesting a 60-day extension on the comment period for the above-referenced
Request for Information as published in the Federal Register on April 10, 2020.

As a stakeholder-based nonprofit organization dedicated to the efficient and sustainable
use of water, the Alliance for Water Efficiency serves as a North American advocate for
water-efficient products and programs. Our members include public and private water
utilities, water conservation professionals, planners, regulators, and consumers. We have
been an integral participant in the WaterSense program since its inception and have worked
closely with the EPA, industry and consumer groups to encourage and nurture this
extraordinarily successful public-private partnership.

We are vitally interested in contributing to the referenced Request for Information. But we
are finding that our members' attention is understandably focused on dealing with the
COVID-19 pandemic. As you well know, the pandemic is causing major disruption in the
activities of businesses, government agencies and organizations. And because many of our
members are organizations which must gain the approval of their directors before taking
any policy position, coordinating such approvals is proving extremely difficult given the
separation and isolation brought on by the pandemic. The added time we are requesting is
needed so that our members can provide us with the detailed and thorough data and
information that your request for comments deserves.

Your consideration of our request for an extension is greatly appreciated. Please contact
me at maryann@a4we.org with any questions or requests for additional information.

Sincerely yours,

33 N LaSalle Street
Suite 2275
Chicago, IL 60602

: E (773)360-5100
(866) 730-A4WE
(773) 345-3636

allianceforwaterefficiency.org
home-water-works.org

^OCUXjCWv,

Mary Ann Dickinson
President and CEO

CC: Andrew Wheeler, Administrator

R. Lee Forsgren, Deputy Assistant Administrator, Office of Water
Andrew Sawyers, Director, Office of Wastewater Management


-------
Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Darcey Peterson, General Manager
Affiliation: King County Water District Number 90
Comment Date: May 4, 2020
Document ID: EPA-HQ-OW-2020-0026-0015

Comment Text:

Hello, My name is Darcey Peterson. I am the General Manager of King County Water
District No. 90. I am asking that you please don't relax the requirements for the water
sense program. This technology has come a long way from when it was first introduced.
There is now no need to flush multiple times to get the bowl clean.

In fact this technology, along with education, plumbing code changes, and water District
efforts to eliminate wasted water, has meant that the entire Seattle Region has been
able to avoid building additional water shed reservoirs saving rate payers hundreds of
millions of dollars. In fact, Seattle uses less total water today than we did in 1960.

Water Sense technology matters. It allows our customers to easily identify which
products will help them save water (and money). Please don't decrease the
requirements in anyway.

Sincerely, Darcey Peterson.

4

EPA

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Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Anonymous

Affiliation: Department of Water and Power, City of Big Bear Lake

Comment Date: May 4, 2020

Document ID: EPA-HQ-OW-2020-0026-0016

Comment Text:

The City of Big Bear Lake, Department of Water and Power, relies on the WaterSense
program, including specifications and certifications. Our agency has provided
approximately 1,000 toilet rebates in the last five years. Customers ask us which
products to purchase, and while we cannot make brand or model specifications, we can
recommend the WaterSense certification. The WaterSense program lends credibility and
reliability that public agencies count on.

4

EPA

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Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Dain M. Hansen

Affiliation: International Association of Plumbing and Mechanical Officials (IAPMO)

Comment Date: May 8, 2020

Document ID: EPA-HQ-OW-2020-0026-0017

Comment Text:

Mr. David Ross

Assistant Administrator, Office of Water
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Washington, DC 20460

Re: Request for 60-Day Extension of the Comment Period Relating to the Request for
Information on WaterSense," 85 Fed. Reg. 20,268 (April 10, 2020) - Docket No. [EPA-
HQ- OW-2020-0026]

Dear Assistant Administrator Ross:

We are requesting a 60-day extension on the comment period for the above-referenced
Request for Information as published in the Federal Register on April 10.

The International Association of Plumbing and Mechanical Officials (IAPMO) is a nearly
100- year-old trade association that focuses its comprehensive services on the technical
aspects of the plumbing and mechanical industries. We focus where people come in
contact with water and sanitation. The IAPMO Group is comprised of 13 different
business units with offices and staff in 11 countries. Our membership includes trained
labor and contractors, engineers, product manufacturers, suppliers, plumbing and
mechanical inspectors, and building officials. As a global leader, IAPMO has assisted
with the development of standards, skills training, and conformity assessment services in
regions around the world. From the program's creation, IAPMO has been an integral
participant in WaterSense, as both a promotional partner and an accredited testing and
certification laboratory.

We are very interested in contributing to the referenced Request for Information. But we
also recognize the unique challenges faced by IAPMO and other stakeholders in putting
together the requisite data required, particularly as the industry is focused on the
continual evolution of business operations that the COVID-19 pandemic requires. As you
well know, the pandemic is causing major disruption in the activities of businesses,
government agencies and organizations. The added time we are requesting is
necessary so that IAPMO, its members, and its manufacturer clients can provide EPA
with the detailed data and information that your request for comments deserves.

We greatly appreciate your consideration of this request. IAPMO stands ready to
continue to work with EPA in the ongoing implementation of the WaterSense program
and looks forward to providing a helpful response to EPA's request. If you have
questions regarding this request to extend the comment period, please contact Dain
Hansen, IAPMO executive vice president for Government Relations, at
dain.hansen@iapmo.org or 202-445-7514.

4

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A

¦v.	Summary of Comments on Notice of Recent Specifications Review

WaterSense	an<^ ^ecluest f°r Information on WaterSense Program

Sincerely yours,

Dain M. Hansen
Executive Vice President
Government Relations

37

August 2020


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Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Anonymous
Affiliation: Anonymous
Comment Date: May 12, 2020
Document ID: EPA-HQ-OW-2020-0026-0018

Comment Text:

I am writing to comment on EPA-HQ-OW-2020- 0026. I am a parent of three children
and I'm deeply concerned about our future. In addition, I live in California, which is
haunted by persistent drought and fires, made worse by climate change. Water efficient
products help each of us help each our community as a whole, but we need clear
labeling to do that. The current WaterSense program specifications allow me to reduce
costs, understand my options quickly, and protect my kids' future. I strongly support the
current specifications and do not believe that customer satisfaction criteria should be
included in them.

4

EPA

WaterSense

38

August 2020


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Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Anonymous
Affiliation: Anonymous
Comment Date: May 14, 2020
Document ID: EPA-HQ-OW-2020-0026-0019

Comment Text:

I work for a Florida water utility. The utility issues rebates for Water Sense labeled toilets
and irrigation controllers, and provides free faucet aerators and showerheads to its
customers. The utility estimates these fixtures reduced customer water use by over 17
million gallons in 2019 alone. A 2015 survey found that 94% of customers that installed
WS Labeled toilets were 'Very Satisfied'. These same customers saved 20% more water
than if they had installed a standard non-labeled model. A 2020 survey of customers that
recently installed a WS labeled irrigation controller found that 92% rated the fixtures
"high' or 'very high' quality. The utility's customers with Water Sense labeled irrigation
controllers saved 13 million gallons of water in 2019.

The utility uses the label to reap the greatest water savings for funds it invests. Water
Sense labeled products are required to meet strict criteria that ensure a quality, well-
functioning fixture. The science -based criteria allows customers to choose a superior
fixture that will reduce water use. Prior to working with Water Sense, the utility struggled
to relay to customers brands & models that save water, work well and qualify for rebates.
Successful water reductions allow the utility to accommodate a larger population with
lesser or equal water supply. Reducing demand on existing water supplies is less
expensive than developing costly alternative water sources, such as desalination. EPA
Water Sense is crucial to successfully reducing water consumption.

4

EPA

WaterSense

39

August 2020


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WaterSense

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Anonymous
Affiliation: Anonymous
Comment Date: May 15, 2020
Document ID: EPA-HQ-OW-2020-0026-0020

Comment Text:

Saving water is so very important like making everyone stay in their home because of
the corona virus. Why don't you REQUIRE everyone to have water saving devises in
their homes and businesses? Once our water is gone, it's gone!

40

August 2020


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WaterSense

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Anonymous
Affiliation: Anonymous
Comment Date: May 15, 2020
Document ID: EPA-HQ-OW-2020-0026-0021

Comment Text:

Good program, it would be nice if it incorporates moisture content by zone and adjust
watering with that in mind. Weather forecasts are not accurate and if I followed their
advice for watering, my grass would be gone.

41

August 2020


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Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Anonymous
Affiliation: Anonymous
Comment Date: May 15, 2020
Document ID: EPA-HQ-OW-2020-0026-0022

Comment Text:

I like the thought process of this program, as the technology is fantastic. However, the
sprinkler control board used does not have any sort of surge protection like my previous
Rain Bird controller did. Due to this, I have blown through two controllers due to
lightning. This lack of protection also damaged my AC units, as the controller let the
surge go through the back door.

I contacted the manufacturer of the controller (Rachio), and they did replace the
controllers. However, with the lack of protection, I had to go back to Rain Bird as I have
to protect my home.

4

EPA

WaterSense

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August 2020


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WaterSense

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Wayne Hammond
Affiliation: General Public
Comment Date: May 15, 2020
Document ID: EPA-HQ-OW-2020-0026-0023

Comment Text:

Too early to tell. As of now unit is working fine. The education class was informatived.
Wayne Hammond

43

August 2020


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EPA

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

WaterSense

Commenter: Anonymous
Affiliation: Anonymous
Comment Date: May 15, 2020
Document ID: EPA-HQ-OW-2020-0026-0024

Comment Text:

The WaterSense program has a been a wonderful addition to our home. Considering the
current weather conditions, the controller makes the adjustments necessary and my
lawn has never looked better. My water bill has been great.

44

August 2020


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EPA

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

WaterSense

Commenter: Anonymous
Affiliation: Anonymous
Comment Date: May 15, 2020
Document ID: EPA-HQ-OW-2020-0026-0025

Comment Text:

I recently did major renovations to both of my bathrooms in a newly acquired home. I did
90% of the work myself, being retired on a fixed income. This program gave me the
ability to purchase and install better and more efficient toilets in my home and at the
same time, helping the environment by saving large amounts of water use.

45

August 2020


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Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Ray Hoffman, CEO
Affiliation: Cascade Water Alliance
Comment Date: May 15, 2020
Document ID: EPA-HQ-OW-2020-0026-0026

Comment Text-
Dear Andrew Wheeler,

Please find the attached letter of support of the US EPA WaterSense program from
Cascade Water Alliance in King County, Washington. If you have any questions, please
contact me at 425.453.1810 or mbrent@cascadewater.org.

Thank you.

Regards,

Michael Brent

Attachment

See page 47.

4

EPA

WaterSense

46

August 2020


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CASCADE

WATER ALLIANCE

May 15, 2020

Mr, Andrew Wheeler, Administrator
US Environmental Protection Agency
Washington, DC

RE: Comments on Docket ID No. EPA-HQ-OW-2020-0026

Request for Information on the WaterSense® Program

Dear Administrator Wheeler:

Cascade Water Alliance (Cascade) wishes to express its strong support for the WaterSense®
Program administered by the US Environmental Protection Agency (EPA) and the continuation of
its current methodology for developing product performance specifications.

The WaterSense® Program has been an extremely valuable tool in supporting Cascade's water
conservation program. Cascade has promoted and implemented rebate programs for WaterSense®
labeled showerheads, faucets, and toilets for years, which has helped save millions of gallons of
valuable drinking water and extend our limited water supplies. Cascade's experience has been that
customers and retailers are generally very satisfied with products that have received the
WaterSense® label. Nationally, the program has saved trillions of gallons of water and has provided
customers with confidence in their purchasing choices of plumbing fixtures, and it has had a long
and successful history of working with relevant industries and interested parties to craft fair,
science-based protocols to evaluate the efficacy of products.

Based on our experience, Cascade recommends that customer satisfaction criteria should not be
included in WaterSense® product specifications. The specifications should continue to focus on the
measurable, technical performance of plumbing products. The free market, social media, and other
sources of evaluation already available provide adequate consideration of product-specific
customer satisfaction.

Thank you for maintaining this extremely valuable program that provides tremendous benefit to
American consumers.

Warmest regards,

Ray Hoffman, CEO
Cascade Water Alliance

CASCADE

WATC8 •* I I I OF

Cascade is a municipal
corporation in King
County, Washington
serving more than 380,000
people and 20,000
businesses with safe,
reliable drinking water and
is comprised of five cities
and two water districts.

Cascade's mission is to
provide water supply to
meet current and future
needs of our members in a
cost-effective and
environmentally
responsible manner
through partnerships,
water efficiency programs,
acquiring, constructing and
managing water supply
infrastructure and
fostering regional water
planning.


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WaterSense

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Anonymous
Affiliation: Anonymous
Comment Date: May 15, 2020
Document ID: EPA-HQ-OW-2020-0026-0027

Comment Text:

it is a good program that saves a lot of water, there should be other programs similar to
save our enviroment.

48

August 2020


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EPA

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

WaterSense

Commenter: Anonymous
Affiliation: Anonymous
Comment Date: May 15, 2020
Document ID: EPA-HQ-OW-2020-0026-0028

Comment Text:

We installed a water saver controller on our irrigation system through our water
company, Citrus County Water Company in Lecanto .Florida. To date, the controller has
done a wonderful job of significantly reducing our water bill and thus our water
consumption. In the short time that the controller has been functioning, it has more than
paid for itself in water savings.

49

August 2020


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EPA

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

WaterSense

Commenter: Anonymous
Affiliation: Anonymous
Comment Date: May 15, 2020
Document ID: EPA-HQ-OW-2020-0026-0029

Comment Text:

The irrigation control system has helped us save on our water use. The weather in that
irrigation system app is way more reliable than either my phone weather app or the local
TV weather. The system adjusts based on weather and season. I can monitor this from
any place I go.

The installer explained how irrigation works and established the program. It was helpful
to get this background as we are not native Floridians.

Without this program, we wouldn't have been able to install a new controller and wouldn't
have known how to save water.

50

August 2020


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EPA

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

WaterSense

Commenter: Anonymous
Affiliation: Anonymous
Comment Date: May 16, 2020
Document ID: EPA-HQ-OW-2020-0026-0030

Comment Text:

I cannot comment at this time as I have not had my system long enough to see any
change and this is the dry season as well. I also have new sod so I have been watering
for 30 days to help it take root. It's only rained here maybe three times at best in the last
few of months so there is no real difference for me to speak of.

51

August 2020


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Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Anonymous
Affiliation: Anonymous
Comment Date: May 16, 2020
Document ID: EPA-HQ-OW-2020-0026-0031

Comment Text:

My household has acquired three WaterSense Program products (shower head, toilet,
water controller) from the Citrus County, Florida Water Conservation Office thanks to its
incentive program. Wthout the incentives, I, more than likely, would not have replaced
perfectly functioning products already in use. Nevertheless, my wife and I are extremely
pleased with their efficiency, water usage and cost reduction, and, most importantly, the
value of doing our small part in helping to conserve our most precious natural resource.

Of the three products, the app for the water controller has proven to be an amazing
means for regulating our lawn irrigation system. The app makes it easy and convenient
to adjust the irrigation schedule with the rainfall received. It also reminds you when the
irrigation started and finished, and shows what zone is running and how the time
remaining for the zone. Since we travel frequently to Europe, we have checked or
regulated the irrigation of our lawn from numerous European locales.

Suffice to say that from our experience the WaterSense Program is an invaluable means
for conserving our water, reducing water usage environmental and financial costs, and
facilitating return on investment for local utilities by reducing capital costs through
demand reduction.

4

EPA

WaterSense

52

August 2020


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WaterSense

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Anonymous
Affiliation: Anonymous
Comment Date: May 16, 2020
Document ID: EPA-HQ-OW-2020-0026-0032

Comment Text:

found rain sensor and commodes to be very efficient and has reduced my water bill
considerably

53

August 2020


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EPA

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

WaterSense

Commenter: Anonymous
Affiliation: Anonymous
Comment Date: May 16, 2020
Document ID: EPA-HQ-OW-2020-0026-0033

Comment Text:

My experience with the water sense irrigation controller has been very positive. The unit
performs very well is reliable and auto adjusts to the seasonal requirements. It requires
very little attention.

54

August 2020


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WaterSense

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Anonymous
Affiliation: Anonymous
Comment Date: May 17, 2020
Document ID: EPA-HQ-OW-2020-0026-0034

Comment Text:

bought two Kholer toilets and rain sensor, very happy with both

55

August 2020


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EPA

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

WaterSense

Commenter: Anonymous
Affiliation: Anonymous
Comment Date: May 17, 2020
Document ID: EPA-HQ-OW-2020-0026-0035

Comment Text:

I am writing to comment on EPA-HQ-OW-2020-0026. As a consumer, I am concerned
about a sustainable future, reducing household costs, and clear labeling. The current
WaterSense program specifications support all of these goals. I strongly support the
current specifications and do not believe that customer satisfaction criteria should be
included in them.

56

August 2020


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EPA

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

WaterSense

Commenter: Valerie Meyer Nixon
Affiliation: General Public
Comment Date: May 17, 2020
Document ID: EPA-HQ-OW-2020-0026-0036

Comment Text:

I am writing to comment on EPA-HQ-OW-2020-0026. As a parent and grandparent I am
grateful for labeling on appliances that make it easy to understand the water efficiency of
my purchase. I would prefer to not complicate that message with customer satisfaction
information that might confuse the buyer and can easily be found in other places. I
strongly support the current specifications and do not believe customer satisfaction
information needs to be added. Thank you, Valerie Meyer Nixon

57

August 2020


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WaterSense

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Anonymous
Affiliation: Anonymous
Comment Date: May 17, 2020
Document ID: EPA-HQ-OW-2020-0026-0037

Comment Text:

I am writing to comment on EPA-HQ-OW-2020-0026. As an educator, I am concerned
about a sustainable and health future for me students. I strongly support the current
specifications of the WaterSense program and do not believe that customer satisfaction
criteria should be included in them.

58

August 2020


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Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Anonymous
Affiliation: Anonymous
Comment Date: May 17, 2020
Document ID: EPA-HQ-OW-2020-0026-0038

Comment Text:

I am writing to comment on EPA-HQ-OW-2020-0026. I strongly support the EPA's
recommendation to keep the current specifications. Adding customer satisfaction criteria
will make them more confusing and less effective. The current WaterSense
specifications support the goals of a sustainable future, reducing household costs, and
clear labeling.

Please keep the current specifications.

4

EPA

WaterSense

59

August 2020


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EPA

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

WaterSense

Commenter: Amy Sholinbeck
Affiliation: General Public
Comment Date: May 17, 2020
Document ID: EPA-HQ-OW-2020-0026-0039

Comment Text:

I am writing to comment on EPA-HQ-OW-2020-0026. ] I am concerned about a
sustainable future, reducing household costs, and clear labeling. The current
WaterSense program specifications. I support all of these goals. I strongly support the
current specifications and do not believe that customer satisfaction criteria should be
included in them.

People could find reviews on their own.

Thanks,

Amy Sholinbeck
California Voter

60

August 2020


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EPA

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

WaterSense

Commenter: Anonymous
Affiliation: Anonymous
Comment Date: May 17, 2020
Document ID: EPA-HQ-OW-2020-0026-0040

Comment Text:

I am writing to comment on EPA-HQ-OW-2020-0026. The current WaterSense program
works. It does not need to be modified to include customer satisfaction criteria. I strongly
support the current specifications.

61

August 2020


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Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Anonymous
Affiliation: Anonymous
Comment Date: May 17, 2020
Document ID: EPA-HQ-OW-2020-0026-0041

Comment Text:

I'm writing to comment on EPA-HQ-OW-2020-0026. I feel that the current Water Sense
program specifications do a good job of supporting consumer concerns for sustainability,
cost reduction and clear labeling. I support the specifications as they are and do not
want to see the additional inclusion of consumer satisfaction criteria.

4

EPA

WaterSense

62

August 2020


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EPA

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

WaterSense

Commenter: Anonymous
Affiliation: Anonymous
Comment Date: May 17, 2020
Document ID: EPA-HQ-OW-2020-0026-0042

Comment Text:

I am writing to comment on EPA-HQ-OW-2020-0026. As a parent, partner and educator,
I support all of these goals. I strongly support the current specifications and do not
believe that customer satisfaction criteria should be included in them. I am concerned
about a sustainable future, reducing household costs, and clear labeling. This is not the
forum where individual comments in regards to the products with the regulation label on
them should be aired. Perhaps a separate site could be designated for that purpose.

Thank you for taking my comments here and I hope you will take them into
consideration.

63

August 2020


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WaterSense

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Anonymous
Affiliation: Anonymous
Comment Date: May 17, 2020
Document ID: EPA-HQ-OW-2020-0026-0043

Comment Text:

I am writing in support of the current specifications of this proposed regulation without
the need to include customer satisfaction criteria.

64

August 2020


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EPA

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

WaterSense

Commenter: Kerry Stackpole, Chief Executive Officer (CEO) and Executive Director

Affiliation: Plumbing Manufacturers International (PMI)

Comment Date: April 29, 2020

Document ID: EPA-HQ-QW-2020-0026-0044

Comment Text-

Request to EPA Assistant Administrator David Ross, Office of Water from Plumbing
Manufacturers International for 60-Day Extension of Comment Period Relating to the
Request for Information on the WaterSense Program - 85 Fed. Reg. 20,268 (April 10,
2020) - Docket No. [EPA-HQ-OW-2020-0026]

Attachment

See page 66.

65

August 2020


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PLUMBING
MANUFACTURERS
INTERNATIONAL ¦>

PMI

Board of Directors

Joel Smith
Kohler Co.

President

Todd Teter
Moen Incorporated

Vice President

Martin Knieps
Viega LLC

Secreta ry-T reasu rer

Nate Kogler
Bradley Corporation

Immediate Past
President

Sal Gattone
LIXIL

Daniel Gleiberman
Sloan Valve
Company

Fernando Fernandez
Toto USA

April 29, 2020
David Ross

Assistant Administrator
Office of Water

Environmental Protection Agency
1200 Pennsylvania Avenue, N.W.

Washington, D.C. 20460

Re: Request for 60-Day Extension of Comment Period Relating to the Request for Information on
WaterSense," 85 Fed. Reg. 20,268 (April 10, 2020) - Docket No. [EPA-HQ-OW-2020-0026

Dear Assistant Administrator Ross:

On April 10, 2020, the U.S. Environmental Protection Agency (EPA) published a notice in the Federal
Register stating that it was seeking information on the agency's WaterSense Program [See 85 Fed. Reg.
20,268], Comments are currently due June 9, 2020.

Since our plumbing manufacturers, suppliers and customers are completely focused on coping with
unprecedented magnitude brought on by the COVID-19 pandemic, Plumbing Manufacturers
International (PMI) requests a 60-day extension of the comment period to allow stakeholders the
opportunity to fully develop thoughtful feedback on this Request for Information (RFI). This global
pandemic is causing a major disruption to the economic activity in the plumbing and construction
sectors, including the operations of their workplaces.

PMI is the nation's leading trade association for the plumbing fixtures and fittings manufacturing
industry and has supported the WaterSense program since its inception in 2006. Producing 90 percent
of the United States' plumbing products and representing more than 150 brands, PMI's members are
industry leaders in manufacturing innovative, reliable and water-efficient plumbing products and
related supplies. The WaterSense program has created a water-efficiency benchmark for plumbing
products that has allowed our members to confidently invest millions of dollars in product
development and marketing initiatives while knowing that there will be a market for these products.
The program has grown to having more than 30,000 water-efficient plumbing and irrigation products
carrying the WaterSense label.

We appreciate your consideration of this comment extension request. Please do not hesitate to
contact me or Stephanie Salmon in the PMI Washington Office at ssalmondc@gmail.com or 571-242-
0186, if you have any questions or need additional information.

Kerry Stackpole, FASAE CAE
CEO/Executive Director
Plumbing Manufacturers International
kstackpole@safeplumbing.org

cc: EPA Administrator Andrew Wheeler

R. Lee Forsgren, Deputy Assistant Administrator, Office of Water
Andrew Sawyers, Director, Office of Wastewater Management

Plumbing Manufacturers International | 1750 Tysons Blvd. | Suite 1500 | Tysons Corner, VA 22102

Sincerely,

Tel: 847-481-5500 - Visit us at www.safeplumbing.org


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WaterSense

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Anonymous
Affiliation: Anonymous
Comment Date: May 18, 2020
Document ID: EPA-HQ-OW-2020-0026-0045

Comment Text:

Watering day restrictions should be removed to allow the WaterSense devices to
optimize water usage. Limiting to specific days will use more water than necessary and
damage to landscape.

67

August 2020


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Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Anonymous
Affiliation: Anonymous
Comment Date: May 19, 2020
Document ID: EPA-HQ-OW-2020-0026-0046

Comment Text:

As a consumer, I am extremely satisfied with the WaterSense program. I hold
WaterSense in such high regard because it uses product testing and data analysis to
decipher which water-using devices are both efficient and effective. This information is
essential for consumers who want to improve the water efficiency of their home or
business but don't want to lose performance. I have personally purchased many
WaterSense approved fixtures for my home and have found them to be of excellent
quality. In my professional life, we rely on WaterSense certification to provide guidance
on water fixture purchases to the residents of our community. Without this essential
program, there would be no way for laypeople to select water-using fixtures with
confidence.

4

EPA

WaterSense

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August 2020


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WaterSense

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Shelley Flock, Conservation and Customer Service Field Manager, and

Ron Duncan, General Manager

Affiliation: Soquel Creek Water District

Comment Date: May 19, 2020

Document ID: EPA-HQ-OW-2020-0026-0047

Comment Text:
See attached file(s)
Attachment

See page 70.

69

August 2020


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Board of Directors

Dr. Bruce Daniels, President
Rachel Lather, Vice-President
Dr. Thomas R. LaHue
Dr. Bruce Jaffe
Carla Christensen

Mail: P.O. Box 1550 • Capitola, CA 95010 • Office: 5180 Soquel Drive, Soquel, CA 95073

Tel.831.475.8500 • Fax.831.475.4291 • www.soquelcreekwater.org

Ron Duncan, General Manager

May 19, 2020

Mr. Andrew Wheeler
Administrator

US Environmental Protection Agency
Washington DC

Subject: Docket ID No. EPA-HQ-OW-2020- 0026

Dear Administrator Wheeler,

Soquel Creek Water District (SqCWD) is a public utility on the central California coast in Santa
Cruz County, a region which relies 100% on local water sources and has experienced water supply
shortage and seawater intrusion into local groundwater sources. As such, water conservation is
a crucial component of our strategy to reduce water demand to ensure a reliable and consistent water
source for all customers and reduce the strain on public infrastructure and shared natural resources.

Currently, SqCWD offers rebates for 18 different water conservation devices or measures to
residential and commercial customers. Rebates are very valuable in helping our customers reduce
water use and supporting our mission of providing a safe, high quality, reliable, and sustainable water
supply to meet our community's present and future needs in an environmentally and economically
responsible manner. SqCWD uses WaterSense to inform the specifications for the toilet, showerhead
and urinal rebates and encourages customers to use WaterSense to aid in their purchase decision.
By using WaterSense, the District assures customers that the products they are installing are not
only water efficient but have been assessed for performance by a third party. The District has largely
had very positive feedback on the performance of rebated WaterSense products, especially residential
toilets.

Soquel Creek Water District supports the continued use of the WaterSense label and the
reassessment and improvement of the standards over time to encourage further water conservation.

Sincerely,

SOQUEL CREEK WATER DISTRICT

Conservation and Customer Service Field Manager

Ron Duncan
General Manager


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WaterSense

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Jennifer Burke, Director of Water
Affiliation: City of Santa Rosa
Comment Date: May 20, 2020
Document ID: EPA-HQ-OW-2020-0026-0048

Comment Text:
See attached file(s)
Attachment

See pages 72 through 74.

71

August 2020


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0

City of

Santa Rosa

WATER

May 20, 2020

Mr. Andrew Wheeler
Administrator, U.S. EPA
Washington, DC

Re: Comments on Docket ID No. EPA-HQ-OW-2020-0026: Request for Information on the
WaterSense Program

Dear Administrator Wheeler,

On behalf of the City of Santa Rosa Water Department (Santa Rosa Water), I am writing to provide
comments in response to the Notice of Recent Specifications Review and Request for Information on
WaterSense Program published in the Federal Register on April 10, 2020. Santa Rosa Water
appreciates the U.S. EPA's ongoing review of the WaterSense Program and allowing partners to weigh
in on the most appropriate way to assess consumer satisfaction with WaterSense products. Santa
Rosa Water is a member of the Alliance for Water Efficiency and the Sonoma-Marin Saving Water
Partnership and is supportive of the comments provided in their respective letters.

Santa Rosa Water is an urban retail water supplier serving approximately 175,000 residents in
Sonoma County, California. Santa Rosa Water has a long-standing commitment to water use efficiency
and provides our customers with an array of individualized tools and resources to help them use
water wisely. By providing invaluable outreach materials, templates for marketing, and rebate
program support, the WaterSense Program has been an important part of our water use efficiency
"toolkit". Santa Rosa Water also participates in WaterSense's annual Fix-a-Leak campaign, which
enjoys considerable engagement from our community.

Our comments contained in this letter directly address the specific questions posed within the
Federal Register notice and our support of the U.S. EPA's decision not to revise any WaterSense
Product specifications at this time.

I. Customer satisfaction should be limited to helping the U.S. EPA make improvements to the
WaterSense program, and not used in product specifications and guidelines.

In this federal rulemaking, the U.S. EPA is seeking input on whether it should include consumer
satisfaction criteria in the WaterSense Program's product specifications and guidelines, and, if
included, what criteria should be considered. While there are reasonable uses for customer
satisfaction to inform the future direction of the WaterSense Program, Santa Rosa Water does not
recommend including this criteria in the WaterSense product specifications and guidelines. Rather,
customer satisfaction research should be used to help the U.S. EPA improve upon the WaterSense
Program and brand.

Including customer satisfaction requirements within individual product specifications provides little
benefit to the U.S. EPA in improving programmatic elements of the WaterSense Program. Customer

STONY CIRCLE I SANTA ROSA, CA 95401 | 707 543 4200 I SRCITY.ORG/WATER


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0

City of

Santa Rosa

WATER

satisfaction with a plumbing fixture depends greatly on the quality of manufacturing, the cost, the
customer's own expectations, the actual installation of the fixture, the water pressure in the building,
and the appearance of the fixture. These are all difficult to measure and subject to issues that are
beyond the control of the U.S. EPA. Individual product satisfaction research is more appropriate for
the marketplace and product manufacturers to strategically develop their products and brand for
competitive advantage.

Instead, Santa Rosa Water recommends specifically tailoring surveys around consumer satisfaction
with utility partnerships, brand recognition, and WaterSense products. This would provide the U.S.
EPA with valuable insight and general direction for product categories, opinions of the WaterSense
brand, their experience with WaterSense products, and inform the U.S. EPA on the successes or
failures of the program.

II.	The U.S. EPA should rely on professional, independent researchers to conduct consumer
satisfaction research.

The U.S. EPA should rely on the services of professional, independent researchers, who specialize in
customer satisfaction survey methods and plumbing fixtures, to design and conduct research on
consumers' satisfaction with WaterSense. Measuring consumer satisfaction is a complex task,
requiring statistical analysis and research, which is not the type of research that the U.S. EPA itself
should conduct.

Santa Rosa Water recommends that the scope of consumer satisfaction research should be limited to
the WaterSense brand itself and partnerships, instead of the products themselves. This is similar to
the type of research currently conducted by the EnergyStar Program. Gaining insight on consumer
satisfaction of the WaterSense brand and partnerships could be much more useful to the U.S. EPA in
evaluating awareness and satisfaction of the WaterSense Program. Whereas collecting product
specific customer satisfaction is more suited for product manufacturers and distributors who use
such information to develop new products and modify existing ones. Further, trying to understand
customer satisfaction of a particular product becomes challenging when there are varying factors
related to brand, style and manufacturing of the fixture, installation of the fixture, and local water
pressure.

Therefore, Santa Rosa Water recommends that that U.S. EPA consult with professional researchers
in order to gather meaningful data that will help build upon the existing WaterSense brand and
improve consumer experience with WaterSense products on a nationwide level.

III.	The EPA should continually review WaterSense product performance criteria and revise
as necessary.

Santa Rosa Water supports the U.S. EPA's decision not to revise any product specifications at this
time, however, we do recommend that the U.S. EPA continue to periodically review WaterSense
product performance criteria pursuant to the America's Water Infrastructure Act (AWIA) of 2018.
Periodic review of product performance and specifications will allow the U.S. EPA to ensure product
specifications continually advance with changing times and technology.

69 STONY CIRCLE I SANTA ROSA, CA 95401 | 707 543 4200 I SRCITY.ORG/WATER


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0

City of

Santa Rosa

WATER

Thank you for the opportunity to provide input on the WaterSense Program. We greatly appreciate
your support in ensuring that this tremendously successful program continues to provide water
providers and consumers the assurance that performance or quality is not sacrificed when choosing
a WaterSense certified product. If you have any questions, please feel free to contact Claire Nordlie,
Sustainability Coordinator, at 707-543-3962 or CNordlie@srcity.org.

Jennifer Burke

Director of Water, City of Santa Rosa

STONY CIRCLE I SANTA ROSA, CA 95401 | 707 543 4200 I SRCITY.ORG/WATER

Sincerely,


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WaterSense

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Thomas A. Love, General Manager
Affiliation: Upper San Gabriel Valley Municipal Water District
Comment Date: May 22, 2020
Document ID: EPA-HQ-OW-2020-0026-0049

Comment Text:
See attached file(s)
Attachment

See page 76.

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Mr. Andrew Wheeler
Administrator

US Environmental Protection Agency
Washington, DC

May 20, 2020

Board of Directors:

Anthony R. Fellow, Ph.D.,
Division 1

Charles M. Trevino,
Division 2

RE: Comments on Docket ID No. EPA-HQ-OW-2020-0026
Request for Information on the WaterSense® Program

Ed Chavez,
Division 3

Alfonso "Al" Contreras,
Division 4

Dear Mr. Wheeler:

Jennifer Santana,
Division 5

The Upper San Gabriel Valley Municipal Water District (Upper District) joins numerous other agencies, businesses, and
members of the public in offering full support for the WaterSense program at the Environmental Protection Agency
(EPA) and its current product specifications.

These comments are filed in response to the Notice of Recent Specifications Review and Request for Information on
the WaterSense Program published on April 10, 2020 in the Federal Register as Docket ID: EPA-HQ-OW-2020-0026.

WaterSense has consistently sought to base its product specifications on unbiased measured values of performance
which are tested in a laboratory setting and certified by a third-party certifying organization. Rigorous testing of
products bearing the WaterSense label assure consumers that products perform as specified. Devices bearing a
WaterSense label offers consumers much-needed, and appreciated, guidance in selecting water efficient products.

WaterSense products have become a vital tool in the efforts to save water throughout the United States. Maintaining
current WaterSense product specification levels are crucial for protecting the sustainability of our nation's water
resources.

Upper District believes that customer satisfaction criteria should not be included as part of WaterSense product
specifications. Incorporating customer satisfaction criteria into WaterSense specifications would introduce
uncertainty and bias into an otherwise fair and scientific process.

The WaterSense program has been an enormous success for the EPA and immensely helpful to consumers. Water
agencies across the nation have been able to implement highly successful water conservation programs involving
consumer selection, and use of, WaterSense-labeled products. These programs have resulted in tremendous water
and energy savings.

The Upper District values and appreciates the EPA's continued efforts to support and ensure the continuity of this
essential and effective program.

Sincerely,

Thomas A. Love, P.E.
General Manager

602 E. Huntington Drive, Suite B I Monrovia, CA 91016 1 (626) 443-2297 (phone) | (626) 443-061 7 (fax) lwww.upperdistrict.org


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EPA

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

WaterSense

Commenter: Carol Boyd
Affiliation: General Public
Comment Date: May 22, 2020
Document ID: EPA-HQ-OW-2020-0026-0050

Comment Text-

Very satisfied with my low flush toilet. Especially as the water rates keep creeping up. If
something could be done about people with broken sprinkler heads; people who have
wells and water when they feel like it and not on allowed days and times.

Thank You Carol Boyd

77

August 2020


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WaterSense

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Grant Davis, General Manager
Affiliation: Sonoma County Water Agency
Comment Date: June 1, 2020
Document ID: EPA-HQ-OW-2020-0026-0052

Comment Text:
See attached file(s)
Attachment

See pages 79 and 80.

78

August 2020


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Sonoma
Water

CF/O-O-l Letter of Support (ID 5524)

June 1, 2020

Mr. Andrew Wheeler
Administrator

US Environmental Protection Agency
Washington, DC

RE: Comments on Docket ID No. EPA-HQ-OW-2020-0026
Request for Information on the WaterSense® Program

Dear Administrator Wheeler:

The Sonoma County Water Agency (Sonoma Water) writes to express our strong support for the
WaterSense program at the Environmental Protection Agency (EPA) and to share with you our
submitted comments regarding WaterSense. We are filing these comments in response to the Notice
of Recent Specifications Review and Request for Information on the WaterSense Program published
on April 10, 2020 in the Federal Register. Our comments address the recent EPA review of the
WaterSense program, the EPA's decision not to revise any of the WaterSense product specifications,
and the specific questions asked within the Federal Register Notice related to consumer satisfaction.

The WaterSense program is a trusted partner that we rely on to help us meet regional water supply
needs through investments in demand-management programs that incentivize and promote the use
of WaterSense products by our customers. The science-based rigor of the WaterSense product
specifications provides the underpinning and confidence to make these investments, with the
knowledge that our and our customers' expectations for water savings will be realized. Although end
user satisfaction with WaterSense labeled products may vary for a wide variety of reasons, it is of
utmost importance that consumer satisfaction criteria remain separate from product specifications,
and that WaterSense uphold the current regime for specifications based on measured values of
performance that are tested in a laboratory and certified by a third-party certifying organization.
Including a vague, non-scientific concept such as customer satisfaction criteria could introduce
uncertainty and bias into what is currently a fair and scientific process for setting WaterSense
specifications.

Although reasonable uses for consumer satisfaction information can exist within WaterSense, the
scope of customer satisfaction research should be limited to consideration of the WaterSense brand
itself and WaterSense partnerships, like the type of customer satisfaction research ENERGY STAR has
conducted in the past. Proper uses of customer satisfaction survey results would inform the EPA
about Americans' opinion of the WaterSense brand and their experience with WaterSense labeled
products in homes and businesses. This information could help EPA guide the direction of the

404 Aviation Boulevard, Santa Rosa, CA 95403 ¦ 707.526.5370 ¦ www.sonomawater.org


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Sonoma Water Comments on
Docket ID No. EPA-HQ-OW-2020-0026
June 1, 2020
Page 2 of 2

WaterSense brand and program. However, any product-specific customer satisfaction research is
best left to the marketplace and manufacturers themselves. Product manufacturers conduct
customer satisfaction research frequently and keep the results to themselves so they can use it
strategically to develop their products and brand to competitive advantage.

This is not to say that WaterSense specifications should not move forward and advance in the future.
They should be reviewed regularly so that WaterSense products keep up with changing technology
and industry innovation, as has been the case with WaterSense products to date. By doing so,
WaterSense can continue to fuel innovation in American manufacturing while providing consistent
and fair metrics for product development in the plumbing and irrigation industries.

The WaterSense program has been a tremendous success for EPA, and has been a successful partner
with Sonoma Water for many years. We strongly encourage EPA to maintain the program's
effectiveness so we can continue to rely on regional water supply investments that tailor water
conservation programs around consumer use of WaterSense-labeled products.

General Manager

rw S:\Clerical\Pinks\06-01~20\SW-Letter-to-EPA-Admin-Wheeler-regarding-Federal-Register-NOI-final.docx


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WaterSense

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Anonymous
Affiliation: Anonymous
Comment Date: May 29, 2020
Document ID: EPA-HQ-OW-2020-0026-0053

Comment Text:

I am a Registered professional mechanical engineer and strongly recommend and
specify the water sense products constantly due to the huge savings provided by these.

81

August 2020


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WaterSense

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Anonymous
Affiliation: Anonymous
Comment Date: May 29, 2020
Document ID: EPA-HQ-OW-2020-0026-0054

Comment Text:

The WaterSense program has been helpful to identifying products with a minimum level
of performance while providing reduced water consumption. This is similar to the
benefits of the Energy Star program experienced by the market which helps drive
innovation by designers and manufacturers to continue to improve performance while
being good stewards of resources over the life of products.

82

August 2020


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Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Anonymous
Affiliation: Anonymous
Comment Date: May 29, 2020
Document ID: EPA-HQ-OW-2020-0026-0055

Comment Text:

WaterSense is a voluntary labeling program that has saved more than 3.4 trillion gallons
of water since its inception in 2006. That's more than the amount of water used by all
U.S. households for 4 months! The program has also saved more than $84.2 billion in
water and energy bills in that same timeframe. Without WaterSense, 462.5 billion kWh of
electricity would not have been saved. That's a year's worth of power to more than 44.4
million American homes. (Statistics are as of 2018, according to EPA). Wth an annual
budget of only $2 million, WaterSense has an incredible return on investment for
taxpayers.

Specifically regarding the WaterSense labeled products, an analysis of the 1999 and
2016 Residential End Uses of Water Studies showed that toilets, showerheads and
faucets have become more efficient, but contrary to President Trump's December 2019
comments, the use of these fixtures has not changed. If homeowners were unhappy with
the performance of their more efficient fixtures, that would lead them to use them more...
and that's just not happening.

As an architect I only specify WaterSense products. We have scientific data and long
standing evidence of the damage that will be caused by allowing such an action to
occur. One of the key roles of government is to preserve public safety. Willfully ignoring
clear evidence of an impending catastrophe is a dereliction of duty. Scientists have
worked for decades to assemble an incontrovertible body of evidence related to our
changing climate, and ignoring that information is insidious. Future generations'
resources, health and prosperity is dependent on us acting immediately, significantly and
broadly. I encourage the WaterSense program remain, or better yet, become law!

4

EPA

WaterSense

83

August 2020


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Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Anonymous
Affiliation: Anonymous
Comment Date: June 1, 2020
Document ID: EPA-HQ-OW-2020-0026-0056

Comment Text:

I think that the WaterSense Program is an incredible assett to consumers. As a
sustainability manager for a city, I am often asked about water and energy saving
product recommendations. I am able to point people to Energy Star and WaterSense as
fact-based programs that make product-specific energy and water consumption
information more transparent. Having WaterSense as a filter criteria for those searching
for products online also helps people easily focus their searches to products they know
will save them money and save one of our most important resources. Please ensure that
the program continues to be funded and promoted in a way that keeps up with changing
technologies.

My experience with WaterSense products is that they perform well for their intended
purpose. Although they may not provide the same experience as less efficient products,
they are effective and in some cases better. Toilets in particular have made major strides
in the past several years. The criticisms of multiple flushes is pretty much ancient
history. And new shower technology provides a great shower experience with much
lower levels of water use.

We live in a desert and water efficiency is critical. Without things like the WaterSense
label, it will be a lot harder for consumers to figure out what products to buy. It is
imperative that more sustainable choices be as easy as possible and clear labels are
one way to do this.

4

EPA

WaterSense

84

August 2020


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Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Anonymous
Affiliation: C+C, Inc.

Comment Date: June 1, 2020
Document ID: EPA-HQ-OW-2020-0026-0057

Comment Text:

My company, C+C, Inc. is filing this comment to address the recent EPA review of the
WaterSense program, the EPA's decision not to revise any of the WaterSense product
specifications, and the specific questions asked within the Federal Register Notice.

C+C is a communications firm, specializing in behavior change campaigns for social
good. We have supported the WaterSense program for the last 14 years. WaterSense is
a scrappy, but extremely effective public-private voluntary partnership program that has
helped change behaviors nationwide. The program has helped save trillions of gallons of
our world's most precious resource and billions of kilowatt hours of energy that are not
used to heat, pump and distribute water to homes, businesses and institutions around
the country. And in doing so the program has helped inspire manufacturers of water
using products to continue to innovate, making high performance bathroom and kitchen
fixtures, as well as products that save water outdoors. Products that are not only certified
to perform 20% better than their less efficient counterparts, but also happen to use a lot
less water.

These products have such high customer satisfaction that today, if you shop at The
Home Depot, 100% of the toilets, faucets and showerheads on their shelves are
WaterSense labeled. The largest fixture manufacturers, such as Kohler and American
Standard, have helped their customers save billions of gallons and have a large suite of
WaterSense labeled products, with new models introduced every year. Manufacturers
have toured the country time and time again with displays touting the high performance
of their WaterSense labeled products.

KB Home, one of the country's largest home builders, has built more homes certified
under the WaterSense label than any other national builder. To date, KB Home has built
more than 15,000 WaterSense labeled and Water Smart homes and installed over
600,000 WaterSense labeled fixtures. KB Home estimates that its homes conserve
approximately 1.5 billion gallons of water annually.

Public and private utilities in all 50 states tailor successful water conservation programs
around consumer use of WaterSense-labeled products.

Drought conditions continue to plague areas of the United States and North America.
Water-efficient fixtures and faucets and homes can help ease the burden. EPA
WaterSense efforts have also resulted in a significant financial benefit to consumers on
an average of $380 annually and $84.2 billion total in water, sewer, and energy bills
since 2006.

Thank you for doing your utmost to ensure this very inexpensive, valuable, and effective
program continues to deliver for the American people.

Water is life and it must be protected.

4

EPA

WaterSense

85

August 2020


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Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Anonymous
Affiliation: Anonymous
Comment Date: June 3, 2020
Document ID: EPA-HQ-OW-2020-0026-0058

Comment Text:

I support the WaterSense program. As a researcher in the water conservation field, I
have seen the huge amount of water savings a city can achieve that come from indoor
fixture rebate programs in which inefficient toilets, showerheads, etc are replaced with
watersense-labeled products. On a personal level, I find it convenient to be able to find
products that I know are tested and qualified to save water and work most efficiently by
searching specifically for watersense-labeled fixtures.

4

EPA

WaterSense

86

August 2020


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Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Anonymous
Affiliation: Anonymous
Comment Date: June 3, 2020
Document ID: EPA-HQ-OW-2020-0026-0059

Comment Text:

The specifications for the EPA's WaterSense program should not be changed. The
specifications serve as an excellent tool for achieving water conservation (while
architects, builders, developers, etc. can opt for more stringent conservation targets of
their own volition). EPA should continue to encourage the development and widespread
adoption of the water rating index created by RESNET and its partner organizations to
help make people aware of water conservation options plus the value of WaterSense-
labeled products. Thank you for this opportunity to comment.

4

EPA

WaterSense

87

August 2020


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Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Rebecca Geisen, Managing Director
Affiliation: Regional Water Providers Consortium
Comment Date: June 3, 2020
Document ID: EPA-HQ-OW-2020-0026-0060

Comment Text:

Please see attached comments in regards to WaterSense Program and specifications
review.

Rebecca Geisen

Managing Director, Regional Water Providers Consortium

Attachment

See page 89.

4

EPA

WaterSense

88

August 2020


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/<0£rs co*

Beaverton, City of
Clackamas River Water
Cornelius, City of
Forest Grove, City of
Gladstone, City of
Gresham, City of
Hillsboro, City of
Lake Oswego, City of
Milwaukie, City of
Newberg, City of
Oak Lodge Water Services
Portland, City of
Raleigh Water District
Rockwood Water PUD
Sandy, City of
Sherwood, City of
South Fork Water Board
Sunrise Water Authority
Tigard, City of
Troutdale, City of
Tualatin, City of
Tualatin Valley Water District
West Slope Water District

June 3, 2020

Mr. Andrew Wheeler, Administrator
US Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Washington, DC 20460

RE: Comments on Docket ID No. EPA-HQ-OW-2020-0026
Request for Information on WaterSense Program

Dear Administrator Wheeler:

The Regional Water Providers Consortium is writing to express its strong support for
the WaterSense program and to share our comments with you in response to the
Notice of Recent Specifications Review and Request for Information on the
WaterSense Program published on April 10, 2020 in the Federal Register. Our
comments are summarized below:

1.	The Consortium fully supports the WaterSense program and considers it a critical
tool for the effective management of our valuable water resources.

2.	Many of our 23 regional water providers utilize WaterSense products as a key
element of their successful water conservation programs because they are
rigorously tested by a third party, provide a national standard for efficiency, are
widely adopted and available, and result in cost savings in both water and energy
for customers.

3.	The proposal to use customer satisfaction information as a companion to
WaterSense performance metrics is potentially concerning and should only be
applied if collected in a manner that matches the technical rigor of the
WaterSense program. Customer satisfaction should be limited to consideration of
the WaterSense brand and WaterSense partnerships, and not specific products.

4.	Given the potential limitations and uncertainties associated with the collection,
interpretation and application of customer satisfaction information, we do not
support direct incorporation of customer satisfaction criteria into WaterSense
product specifications themselves.

The Regional Water Providers Consortium is a collaborative and coordinating
organization that works to improve the planning and management of municipal water
supplies in the greater Portland, Oregon metropolitan region. The Consortium was
established in 1997 and works with its 23 members in water conservation, emergency
preparedness and regional coordination.

Thank you for the opportunity to comment.

1120 SW 5th Avenue, Suite 600
Portland, OR 97204
503-823-7528
www.regionalh2o.org

H RegionalWaterProvidersConsortiurr
^ ConserveH20rg

Sincerely,

Mark Fagin, Chair

Regional Water Providers Consortium Board


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WaterSense

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Kristen Johnson, Government Affairs Specialist
Affiliation: Coachella Valley Water District
Comment Date: June 4, 2020
Document ID: EPA-HQ-OW-2020-0026-0061

Comment Text:
See attached file(s).
Attachment

See pages 91 and 92.

90

August 2020


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GENERAL MANAGER
Jim Barrett

ASSISTANT GENERAL MANAGER
Robert Cheng

CLERK OFTHEBOARD
Sylvia Bermudez

ASSISTANT GENERAL MANAGER
Dan Charlton

June 4, 2020

The Honorable Andrew Wheeler
Administrator

U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Washington, DC 20460
submitted via: www.regulations.gov

Re: WaterSense Program, Docket ID No. EPA-HQ-OW-2020-0026
Dear Administrator Wheeler:

Coachella Valley Water District (CVWD) respectfully submits the following comments and
support for the WasterSense program at U.S. Environmental Protection Agency (EPA). These
comments are in response to the April 10, 2020 Federal Register Notice of Recent Specifications
Review and Request for Information on the WaterSense Program.

1. Customer satisfaction criteria should not be incorporated into WaterSense product
specifications.

CVWD echoes the position of The Alliance of Water Efficiency (AWE) that customer satisfaction
criteria do not belong in WaterSense product specifications. However, there are reasonable
uses for customer satisfaction information within the WaterSense program. Results from
customer satisfaction surveys should inform the EPA about the public's opinions of the
WaterSense brand and experiences with WaterSense labeled products in their homes and
businesses.

Since the program's launch in 2006, WaterSense has sought to base its product specifications
on laboratory tested measured values of performance. By adhering to these measured
performance standards, the manufacturers who produce WaterSense products have had a level
playing field in which specifications are uniformly understood. A vague, non-scientific measure
such as customer satisfaction is likely to introduce uncertainty and bias into this stable and fair
process. CVWD believes product-specific satisfactions research is best left to the marketplace
and to the manufacturers themselves.

Coachella Valley Water District
P.O. Box 1058 Coachella, CA 92236
Phone (760) 398-2651 Fax (760) 398-3711

www.cvwd.org

an Equal Opportunity Employer


-------
Administrator Wheeler
June 4, 2020
Page 2 of 2

2.	Customer satisfaction research for WaterSense should be limited to the WaterSense
brand and to WaterSense partnerships.

The scope of customer satisfaction research should be limited to consideration of the
WaterSense brand itself and WaterSense partnerships, like the type of customer satisfaction
research ENERGY STAR has conducted in the past. Proper uses of customer satisfaction survey
results would inform the EPA about Americans' opinion of the WaterSense brand and their
experience with WaterSense labeled products in homes and businesses. This information could
help EPA guide the direction of the WaterSense brand and program.

3.	WaterSense specifications and products should be reviewed and revised, as
appropriate, at regular intervals to adapt to changing technology.

The April 10 Federal Register notice it states that EPA has made the decision not to revise any
WaterSense specifications at this time. CVWD supports the AWE position that it is important
for specifications to move forward and advance in the future. EPA's decision not to revise any
specifications is acceptable today, but must be reviewed regularly so that WaterSense products
keep up with changing times and technology.

CVWD relies heavily on the WaterSense to label products that promote water efficiency in a
uniform and controlled program. CVWD recommends WaterSense labeled products in its water
conservation rebate program. In the arid Coachella Valley, preserving the source groundwater
is critical. CVWD was excited to announce it had added high-efficiency washing machines and
hot water recirculation pumps to its indoor rebate program. In just the first five months of
offering these two new rebates, CVWD has processed 41 recirculating pump rebates and 49
washing machine rebates. These programs work. CVWD is thankful for the clear standards
embedded in the program, which means staff do not need to spend time researching, reviewing
and recommending products.

In closing, CVWD appreciates the opportunity to provide these brief comments. CVWD has also
signed a longer coalition letter authored by AWE. If you have any questions, please reach out
to me at kiohnson@cvwd.org or (760) 398-2661 ext. 3564.

Kristen Johnson, J.D.

Government Affairs Specialist

cc: The Honorable Raul Ruiz (CA-36)

Coachella Valley Water District	^

P.O. Box 1058 Coachella, CA 92236

Phone (760) 398-2651 Fax (760) 398-3711	www.cvwd.org

Sincerely,


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Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Brad Coffey, Manager Water Resource Management
Affiliation: Metropolitan Water District of Southern California
Comment Date: June 8, 2020
Document ID: EPA-HQ-OW-2020-0026-0062

Comment Text:
See attached file(s).
Attachment

See pages 94 through 96.

4

EPA

WaterSense

93

August 2020


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THE METROPOLITAN WATER DISTRICT
OF SOUTHERN CALIFORNIA

Office of the General Manager

June 8, 2020

Mr. Andrew Wheeler
Administrator

US Environmental Protection Agency
Washington, DC

Dear Administrator Wheeler:

Comments on Docket ID No. EPA-HQ-OW-2020-0026
Request for Information on the WaterSense® Program

The Metropolitan Water District of Southern California (Metropolitan) wishes to express its
strong support for the WaterSense program at the Environmental Protection Agency (EPA) and
to share with you our submitted comments regarding WaterSense. We are filing these comments
in response to the Notice of Recent Specifications Review and Request for Information on the
WaterSense Program published on April 10, 2020, in the Federal Register. Our comments
address the recent EPA review of the WaterSense program, the EPA's decision not to revise any
of the WaterSense product specifications, and the specific questions asked within the Federal
Register Notice.

Our comments are as follows:

1.	Regarding The American Water Infrastructure Act (AWIA) of 2018 and Review
Specifications:

a.	Metropolitan believes that EPA's WaterSense review process is fundamentally
sound, and that WaterSense reviewed the scope, efficiency, and performance
criteria within each specification under consideration for revision adequately.

b.	WaterSense adequately accessed and considered the most recent technical and
scientific studies, product trends, and specifications (regulatory and other), and
WaterSense correctly sought and considered feedback in the process of making its
determination.

c.	Metropolitan supports the determination that no updates to the existing
certifications are necessary at this time.

2.	Regarding the Request for Information on Consumer Satisfaction:

a. In Section IV(a), the Notice referenced a 1999 report on a consumer satisfaction
survey prepared for Metropolitan, suggesting that the main reason for "double
flushing" of higher efficiency toilets was the desire for bowl cleanliness, and that

700 N. Alameda Street, Los Angeles, California 90012 • Mailing Address: Box 54153, Los Angeles, California 90054-0153 • Telephone (213) 217-6000


-------
THE METROPOLITAN WATER DISTRICT OF SOUTHERN CALIFORNIA

Mr. Andrew Wheeler
Page 2
June 8, 2020

"Increasing the gram requirement may unduly impact product choice, consumer
satisfaction and offset any savings in water usage." Metropolitan believes that
this statement mischaracterizes the survey and draws incorrect inferences from the
actual survey questions.

i.	The survey questions sought to learn about performance of the sampled
toilet models in clearing and cleaning the bowl; no questions sought a
ranking of causes for double flushing. In summary, double flushing of the
newer toilets for clearing and cleaning were "Once a month" or "Never"
for approximately 2/3 of the responses. Other questions specifically
regarding double-flushing were in the context of frequency of double
flushing the new toilets relative to the older (replaced) toilets. Survey
findings suggested that consumers required double flushing the same or
less 68 percent of the time compared to their older toilets. The report did
not discuss gram requirements for sampled toilets, and therefore no
inferences should be made as to that metric's effect on customer
satisfaction.

ii.	The 1999 survey results notwithstanding, using data from more than

20 years ago is irrelevant for today. Manufacturers have vastly improved
on the designs and performance of newer high-efficiency toilets, to the
extent that many models have been thoroughly and rigorously 3rd-party
tested, and likely out-perform older high-volume flushing toilets still in
use.

b. Regarding seeking customer satisfaction criteria for WaterSense specifications,
Metropolitan feels that these criteria do NOT belong in any WaterSense product
specifications themselves.

i.	Including a vague, non-scientific concept such as customer satisfaction
criteria could introduce uncertainty and bias into what has until now been
a fair and scientific process for setting WaterSense specifications.

ii.	Product-specific customer satisfaction research is best left to the
marketplace and manufacturers themselves.

iii.	A Residential End Use Study (DeOreo, W.B., P. Mayer, J. Kiefer, andB.
Dziegielewski. 2016. Residential End Uses of Water, Version 2. Water
Research Foundation. Denver, CO.) showed that over the period between
1999 and 2016 (as toilets, showerheads, and faucets became more
efficient), customer's use of these fixtures has not changed nor has
flushing frequency increased, suggesting that consumers were likely
equally satisfied with their fixtures in 2016 as they were in 1999.


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THE METROPOLITAN WATER DISTRICT OF SOUTHERN CALIFORNIA

Mr. Andrew Wheeler
Page 3
June 8, 2020

c. There are reasonable uses for customer satisfaction information within

WaterSense: the scope of customer satisfaction research should be limited to
consideration of the WaterSense brand itself and WaterSense partnerships, like
the type of customer satisfaction research ENERGY STAR has conducted in the
past. Proper uses of customer satisfaction survey results would inform the EPA
about Americans' opinion of the WaterSense brand and their experience with
WaterSense labeled products in homes and businesses. This information could
help EPA guide the direction of the WaterSense brand and program.

The WaterSense program has been a tremendous success for EPA. Public and private utilities in
all 50 states tailor successful water conservation programs around consumer use of WaterSense-
labeled products. And because of the nexus between water and energy use, the 3.4 trillion of
gallons of water saved by WaterSense since 2006 have resulted in 462.5 billion kilowatt hours of
energy that are not used to heat, pump and distribute water. These savings have resulted in a
financial benefit to consumers on an average of $380 annually and $84.2 billion total in water,
sewer, and energy bills since 2006.

Thank you for doing your utmost to ensure this inexpensive, valuable, and effective program that
continues to deliver for the American people.

Sincerely,

Brad Coffey

Manager, Water Resource Management

GVT :vsm


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WaterSense

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Richard F. Harasick, Senior Assistant General Manager, Water Systems
Affiliation: Los Angeles Department of Water and Power (LADWP)

Comment Date: June 4, 2020
Document ID: EPA-HQ-OW-2020-0026-0063

Comment Text:
See attached file(s).
Attachment

See pages 98 through 102.

97

August 2020


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LA

Los Angeles
Department of
Water & Power

CUSTOMERS FIRST

June 4, 2020

Eric Garcetfl, Mayo>

5fiofr) o* CoiTfmiss»oret?

Mei Levins, Pfasioem
Cynthia McQiln-Hfll, Vice ^rfsiueflt
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Ms. Stephanie Tanner

United States Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Washington, District of Columbia, 20460

Dear Ms, Tanner;

Subject: Comments on the Environmental Protection Agency Review and
Request for Information on WaterSense Program

Los Angeles Department of Water and Power (LADWP) appreciates the opportunity to
comment on the Environmental Protection Agency (EPA) Review and Request for
Information on WaterSense Program. It is LADWP's understanding that this review
considers the revision of the WaterSense product performance specifications released
prior to 2012 and that there is also a request for information on any data or surveys for
customer satisfaction.

LADWP supports the WaterSense program and acknowledges that while the EPA
review has decided not to revise any specifications, there are stil! efforts that can be
done to encourage efficient and sustainable water supply. LADWP supports maintaining
the current standards as well as adopting more stringent standards as have been
adopted by the State of California, the City of Los Angeles or as rebated by the LADWP.
To that end, LADWP is submitting the following comments:

I. Lower WaterSense Maximum Efficiency Specifications

While the current WaterSense specifications have proven to be effective, with more
than 3.4 trillion gallons of water and $84.2 billion in bills saved since 2018, additional
improvement can still be achieved for the coming years. The following are suggested
considerations for increased efficiencies of current WaterSense devices:

Tank-Type Toilets: Currently, the federal standard for tank-type toilets is 1.6 GPF and
the WaterSense specification sets a maximum efficiency of 1.28 GPF, LADWP rebated
toilets are at a flush rate less than or equal to 1.1 GPF and a minimum MaP score of
600. This program is in line with MWD's SoCal Water Smart rebate program for high

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Ms. Stephanie Tanner
Page 2
June 4, 2020

efficiency toilets. Additionally, the California Plumbing Code has adopted a maximum
flush rate requirement for toilets of 1.28 GPF that applies to new construction or when
new toilets are installed to replace existing toilets. Based on the findings of residential
end-use studies conducted by respected consulting firms such as WaterDM, higher
efficiency toilets do not lead to an increased frequency in toilet flushing. Since 1999, the
use of these fixtures has not changed despite the decrease in flushing volume. LADWP
supports the following specifications based on California's efforts to reduce excessive
water use.

Based on this information, LADWP recommends EPA's WaterSense program consider
a higher efficiency standard for tank-type toilets.

Lavatory Faucets and Faucet Accessories: The WaterSense specification sets a
maximum efficiency of 1.5 GPM. LADWP offers free bathroom faucet aerators at
1.0 and 0.5 GPM. Additionally, the California Plumbing Code has adopted a maximum
residential lavatory faucet flow rate of 1.2 GPM that applies to new construction or when
new faucets are installed to replace existing faucets.

Based on this information, LADWP recommends EPA's WaterSense program consider
a higher efficiency standard for faucets.

Showerheads: The WaterSense specification sets a maximum efficiency of 2.0 GPM.
LADWP offers free showerheads at 1.5 GPM. There have been minimal complaints
from LADWP customers who are currently using these showerheads. There have also
been no reports from customers of thermal shock scalding with these showerheads.
Additionally, the California Plumbing Code has adopted a maximum showerhead flow
rate of 1.8 GPM that applies to new construction or when new showerheads are
installed to replace existing showerheads.

Based on this information, LADWP recommends EPA's WaterSense program consider
a higher efficiency standard for showerheads.

Flushing Urinals: The federal standard for flushing urinals is 1.0 GPF and the
WaterSense specification sets a maximum efficiency of 0.5 GPF. LADWP rebates
urinals with a flush rate of 0.125 GPF. Additionally, the California Plumbing Code has
adopted a maximum flush rate requirement for urinals of 0.125 GPF that applies to new
construction or when new urinals are installed to replace existing urinals.

Based on this information, LADWP recommends EPA's WaterSense program consider
a higher efficiency standard for urinals.


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Ms. Stephanie Tanner
Page 3
June 4, 2020

II.	Adjustments to Weather-Based Irrigation Controller Guidelines

With 90 percent of the population waiting to upgrade to Weather Based Irrigation
Controllers (WBIC) as mentioned in EPA's review, it would be advisable to have clearer
guidelines as to what WBICs should be considered to be WaterSense-approved.

For future guidelines, LADWP suggests that WBICs be mandated to have better
programming/sensors in calculating the amount of rain and soil moisture content and be
able to water accordingly. This should be applicable to all of the stations it serves such
that even if a consumer cannot set the controller correctly or manually sets the
controller without utilizing the weather capabilities, there will still be maximum water
savings.

LADWP also suggests that WBICs have connectivity to smart devices as well as having
a stand-alone screen controller. This will allow for easier customer use as most do not
have the patience to learn controlling methods.

III.	Criteria for Customer Satisfaction Surveys

Although customer satisfaction criteria are not necessary for the WaterSense
specifications and guidelines, it is useful for informing them. Thus, it would be more
prudent for the EPA to wait until studies on water fixtures and customer satisfaction are
completed before concluding at this time that there should be no changes to the
WaterSense program.

LADWP suggests that the customer satisfaction surveys should include questions for
customers that use more efficient products, such as 0.125 GPF urinals or 1.8 GPM
showerheads, and use those results as evidence for current opinions on these items.
Some other criteria that could be considered include how long the consumer has used
the product, their overall satisfaction with the product, and whether or not the consumer
plans to keep the device or change it.

Lastly, establishing a reference point for customer satisfaction should be done in order
to confirm its own influence on standards-setting as well as easily confirm effective
satisfaction.

IV.	Incorporation of New Devices for the WaterSense Program

LADWP recommends adding the following new devices to the WaterSense program
that hold potential for more water savings:


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Ms. Stephanie Tanner
Page 4
June 4, 2020

Landscape Irrigation Rotating Nozzles: One device for consideration in the future is
rotating sprinkler nozzles as these are also one of LADWP's most popular rebated
items. From LADWP's Water Conservation Potential study, 83 percent of single-family
residences have non-conserving irrigation fixtures, showing that there is a large
conservation potential from these devices. Rebates through MWD's SoCal Water $mart
program are currently being offered when 30 or more rotating nozzles are purchased.
WaterSense should consider these for future listing when standards for these devices
are adopted.

Leak-Detection Devices: Another device that WaterSense should consider listing is
smart leak-detection devices as household leaks cause a significant amount of water
loss. From the WaterSense website, the average household can lose up to 180 gallons
per week from household leaks alone. Adding these to the WaterSense program would
create a great potential for water savings. Properties of a qualifying leak-detection
device should include a user-friendly interface to view consumption data, the ability to
monitor 24 hours a day, an alert system for consumers of a sudden change in water use
or flow, and the option to automatically set the device to collect data in various minute
intervals.

V. Changes to WaterSense Labels

Lastly, LADWP recommends changing the medium of the label itself. In regards to
tank-type toilets, WaterSense should consider putting mandatory stamp/etched labeling
on both the tank and bowl for designating flow rates. Currently, WaterSense uses paper
stickers to label appliances, but in the case of tank-type toilets, these are not durable
since after repeated usage, the label comes off. A more permanent medium such as an
etching or stamp would be useful for verification, retrofitting, and building safety.

LADWP continues to support the WaterSense program. Its products have been a
success in assisting water conservation programs all over the country. Overall, while
EPA recommends no revisions to the current specifications, the WaterSense program
can still be improved for future water efficiency goals. More efficient specifications,

detailed WBIC guidelines, scrutinized customer satisfaction surveys, and additional
changes to the WaterSense label can help move toward such a direction. WaterSense
products should continue to be reviewed regularly to keep up with future changes.


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Ms. Stephanie Tanner
Page 5
June 4, 2020

Thank you for your consideration of our comments. Should you have any questions,
please contact Sofia Marcus, Manager of Water Resources Regulation, Legislation,
and Grants, at (213) 367-0925.

Richard F. Harasick

Senior Assistant General Manager - Water System
MO:cyr

c: David R. Pettijohn
Sofia Marcus
Nancy Sutley
David Jacot

Sincerely,


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EPA

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

WaterSense

Commenter: Anonymous
Affiliation: Anonymous
Comment Date: June 6, 2020
Document ID: EPA-HQ-OW-2020-0026-0064

Comment Text:

I am writing to comment on EPA-HQ-OW-2020-0026. I am a teacher. Every year I worry
more and more for the future of my students. I am concerned about a sustainable future,
reducing household costs, and clear labeling. The current WaterSense program
specifications support all of these goals. I strongly support the current specifications and
do not believe that customer satisfaction criteria should be included in them.

103

August 2020


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WaterSense

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: G. Tracy Mehan, III, Executive Director of Government Affairs
Affiliation: American Water Works Association (AWWA)

Comment Date: June 8, 2020
Document ID: EPA-HQ-OW-2020-0026-0065

Comment Text:

Please see comments from the American Water Works Association (AWWA) in the
attached file.

Attachment

See pages 105 through 109.

104

August 2020


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American Water Works

Government Affairs Office
1300 Eye Street NW
Suite 701W

Washington, DC 20005-3314
T 202.628.8303
F 202.628.2846

Association

Dedicated to the World's Most Important Resource™

June 8, 2020

Stephanie Tanner
Office of Water

Environmental Protection Agency
1200 Pennsylvania Ave NW
Washington, DC 20460

Re: Comments on EPA's "Notice of Recent Specifications Review and, Request
for Information on WaterSense Program (EPA-HQ-QW-2020-0026)"

Dear Ms. Tanner:

The American Water Works Association (AWW A) appreciates the opportunity to
comment on EPA's "Notice of Recent Specifications Review and, Request for
Information on WaterSense Program" We hope that these comments will assist EPA
in planning its next steps for the WaterSense program.

AWWA and water sector support WaterSense

AWWA has long supported the WaterSense program. As a voluntary program
rooted in providing consumers with efficient and high performing product choices
while giving utilities and local governments the tools and resources necessary to
support effective conservation programs, WaterSense is both valuable and cost
effective for every stakeholder involved. To this effect, we encourage EPA to assure
the continued availability of this valuable program as it continues to review the
underlying standards as necessary while dedicating all other resources necessary to
meet these objectives.

Periodic reviews of standards are appropriate

AWWA fully supports EPA conducting this review (and additional reviews when
appropriate) to help review whether the standards continue to meet their objectives.


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June 8, 2020

Review of EPA-HQ-OW-2020-0026
Page 2

In addition to verifying that the standards are working as intended, periodic
reviews provide the opportunity to identify other concerns that may arise from the
use of high efficiency products.

For example, on 85 FR 20270, the notice addresses potential water quality
challenges with the use of highly efficient products and the actions undertaken in
collaboration with stakeholders to explore this concern. A WW A appreciates that
EPA has acknowledged the impact of WaterSense product use on water quality in
building potable water and hot water systems, as well as, building piping and
systems for hot water, cold water, and wastewater. EPA's stated interest in
working with stakeholders will be essential to overcoming this challenge.
WaterSense products are not the only cause of increasing water residence time in
building systems but WaterSense is well-suited to inform integration of water
efficient products into existing and new buildings. With this role in mind, the
WaterSense program should:

1.	Include in all new WaterSense specifications and future reviews of existing
specifications an assessment of water quality impacts associated with the
specification. Where appropriate, the specifications should be expanded to
address proper installation and use to minimize water quality impacts
relevant to public health, aesthetics, and function of the building water and
wastewater systems1.

2.	Integrate effective communication into WaterSense program and promotional
materials about steps to minimize water quality and building infrastructure
considerations when increasing water efficiency in buildings2.

3.	Promote improved water-efficient product labeling, installation, and user
instructions highlighting relevant materials and plumbing construction
considerations to reduce water quality impacts and impacts on plumbing
(e.g., release of lead and copper into drinking water, and corrosion of
wastewater piping).

4.	Coordinate with the EPA Office of Groundwater and Drinking Water, EPA
Office of Pollution Prevention and Toxics, and the Centers for Disease
Control and Prevention on educational materials related to building water
quality (e.g., heavy metal and opportunistic pathogens).

1	Examples include the WaterSense specifications for labeled new homes for a building systems approach, shower
heads for potential water quality concerns, and flush urinals for wastewater system issues.

2	This could be added to the WaterSense "Our Water" page and into information about commercial buildings.


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June 8, 2020

Review of EPA-HQ-OW-2020-0026
Page 3

5. Engage in EPA's triennial research planning process to identify, prioritize,
and fund research on the effects of water efficiency on water quality (e.g.,

Safe and Sustainable Water Resources Strategic Research Action Plan.
Research Area 7).

No known performance problems or customer satisfaction issues of
WaterSense labeled products

AWWA is not aware of any recent significant performance problems with
WaterSense labeled products related to the standards. Many utilities and service
providers are highly engaged in working with customers and have not reported any
significant issues. Additionally, there are thousands of models of WaterSense
labeled products with millions of units produced, and these products have passed
third party testing procedures and there are no widespread reports of performance
challenges, it is unlikely that there would be any major or systematic problems with
the standards themselves. The combination of the marketplace and existing testing
procedures will address concerns with individual products, without the need for
revisions to the standards.

Although satisfaction with WaterSense products is often not tracked directly, many
conservation programs have much of their basis in promoting WaterSense labeled
products, and such programs tend to be well received. Because of this popularity,
especially when combined with information from manufacturers and retailers
showing that the products sell well, consumers generally appear satisfied with
WaterSense labeled products. EPA could further verify this by assuring there are
easy ways for consumers to provide feedback to the WaterSense program should
concerns arise.

Customer satisfaction could be assessed, but outside of the standards
process

EPA could work with its partners and stakeholders to assess customer satisfaction
with the WaterSense brand and labeled products generally. This could serve as a
basis for additional outreach on the brand and strategies to help encourage greater
adaptation of WaterSense labeled products.


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June 8, 2020

Review of EPA-HQ-OW-2020-0026
Page 4

However, EPA should not include customer satisfaction as part of the standards
themselves. The WaterSense standards are based upon specific, testable measures
of performance and efficiency. Products that meet these requirements and are
verified through third-party testing are eligible for labeling. This does not mean
that every WaterSense labeled product is a luxury product. In fact, labeled
products can span the whole range from basic products with full functionality but
no extras up through luxury products that have many additional features and are
made of upgraded materials. The basic functions of these products may be the
same, but customer satisfaction may vary considerably.

Additionally, consumer satisfaction is inherently subjective. It is important that
WaterSense retain vendor and product-neutral stance by continuing to develop and
update standard which are stakeholder informed, backed by data, and have
characteristics that can be directly tested. For these reasons, there's no appropriate
way to incorporate satisfaction into a standard itself, but rather satisfaction could
be part of a marketing and brand awareness and promotion campaign.

Utility experiences with WaterSense

AWWA gathered input from nine utility users of WaterSense materials and
specifications. Key findings of this outreach included:

About 90% of respondents appreciated that EPA is retaining the current
standards. 10% were neutral, noting there's an opportunity for future
strengthening of the standards but understanding the current levels are also
useful.

-	Most respondents (60-80%, depending on product type) felt they had overall
positive experiences with all five WaterSense product categories under
review. The remainder (20-40% noted that they did not have personal
experience with some product types or had a neutral opinion for some
reason). No respondents had negative opinions of any of the WaterSense
product categories.

-	All respondents (except for one that considered this question "not applicable"
stating that they had not assessed satisfaction) have overall found that their
end-use customers are satisfied with WaterSense labeled products.
Responding utilities generally have not directly assessed satisfaction, but
note that their rebate programs are popular and they have not received any
significant number of complaints about WaterSense labeled products. Some


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June 8, 2020

Review of EPA-HQ-OW-2020-0026
Page 5

respondents noted that in follow-up conversations with those assisted
through conservation programs were often interested in additional projects
(for example, if an apartment complex would work on a project, they would
often sign up other properties after a successful deployment).

We sincerely hope that this information will assist EPA in continuing to move the
successful WaterSense program forward. We appreciate the opportunity to provide
comment on this matter. Please feel free to contact me or Adam Carpenter at
AWWA (202-628-8303, acarpenter@awwa.org) if you have any questions regarding
these comments.

Respectfully,

i

Executive Director of Government Affairs
American Water Works Association

CC: Jennifer McLain, OW/OGWDW
Andrew Sawyers, OW/OWM
Eric Burneson, OW/OGWDW
Veronica Blette, OW/OWM
Brian Albert, OW/OGWDW
Suzanne Van Drunick, ORD

About AWWA:

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 nearly 4,400 utilities that supply roughly 80 percent of the
nation's drinking water and treat almost half of the nation's wastewater. Our over 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.


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WaterSense

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: E. Joaquin Esquivel, Chair
Affiliation: State Water Resources Control Board
Comment Date: June 11, 2020
Document ID: EPA-HQ-OW-2020-0026-0066

Comment Text:
See attached file(s).
Attachment

See pages 111 through 113.

110

August 2020


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Gavin Newsom

GOVERNOR

Jared Blumenfeld

SECRETARY FOR
ENVIRONMENTAL PROTECTION

Water Boards

State Water Resources Control Board

Friday June 5, 2020

United States Environmental Protection Agency
Office of Public Engagement
1200 Pennsylvania Avenue NW
Washington, DC 20460 United States

SUBJECT: Docket ID No. EPA-HQ-OW-2020-0026.

Notice of Recent Specifications Review and Request for Information on
WaterSense Program

Dear Administrator Wheeler,

The California State Water Resources Control Board (State Water Board) appreciates
the opportunity to comment on the United States Environmental Protection Agency's
(U.S. EPA) request for information on the WaterSense Program, as described in Docket
ID No. EPA-HQ-OW-2020-0026.

The mission of the California State Water Board is to preserve, enhance, and restore
the quality of California's water resources and drinking water for the protection of the
environment, public health, and all beneficial uses, and to ensure proper water resource
allocation and efficient use, for the benefit of present and future generations. Water
efficiency generally, and the WaterSense program specifically, play an important role in
fulfilling our mission.

The State Water Board is glad the U.S. EPA recently announced it will "maintain
WaterSense program specifications." If U.S. EPA were to revise existing WaterSense
specifications, the State Water Board encourages U.S. EPA to consider the stricter
standards developed in California and other states, which, alongside the WaterSense
specifications, are advancing the State Water Board's mission to protect water quality,
sustain water resources, and keep water affordable.

However, the State Water Board was somewhat surprised by the scope of the April 10
Request for Information (RFI). In the Request, U.S. EPA states it is "seeking input... to
help assess consumer satisfaction with WaterSense labeled products..." While U.S.

Office of Enforcement | 801 K Street, Suite 2300 | Sacramento, CA 95814 | 916.341.5272
E. Joaquin Esquivel, chair | Eileen Sobeck, executive director

1001 I Street, Sacramento, CA 95814 | Mailing Address: P.O. Box 100, Sacramento, CA 95812-0100 | www.waterboards.ca.gov


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Administrator Wheeler

-2-

June 5, 2020

EPA may desire to understand consumer satisfaction and confidence through the RFI, it
will be poor substitute for the significant resources that are spent in development,
testing and application for a WaterSense label. In fact, it seems worth highlighting that
customer satisfaction and confidence are core to the meaning of a WaterSense label.

When the first water-conserving products entered the marketplace in the 1990s,
customers were in fact dissatisfied. Showers were piddly and toilets had to be double
flushed. In 2006, over a decade after these poorly-performing products became
available, the U.S. EPA established the WaterSense program and label. The label
exists to signal to customers that, unlike those early model products, WaterSense-
labeled products not only save water, but perform as well as or better than regular
models. To bear the WaterSense label, products must meet rigorous specification
requirements, which are developed via a robust public process and supported by a
diverse group of stakeholders, including manufacturers, who, interested in maintaining
customer loyalty, are particularly motivated to ensure products meet customer
expectations. In other words, the specification development process inherently
"incorporates customer satisfaction considerations." If customers were dissatisfied, in
California or elsewhere, sales of WaterSense products—and the number of
WaterSense-labeled products—would not be increasing year and after year. Earning
the WaterSense label takes time and money, which manufacturers would not invest in if
it weren't worth it.

As an agency committed to protecting water quality, sustaining water resources, and
keeping water rates affordable, the State Water Board commends the WaterSense
program's excellent work, the rigor of the specification development process, and the
performance of products baring the WaterSense label.

Below, we discuss some of the ways water efficiency is important to California.

Water efficiency protects water quality. As much as 50 percent of water used for
irrigation outdoors is lost or wasted due to evaporation, wind, or runoff caused by
inefficient irrigation methods and systems. In many areas of California, such dry-
weather runoff from wasteful outdoor water use impairs water bodies and is regulated
as an "illicit discharge" per National Pollutant Discharge Elimination System Municipal
Separate Storm Sewer System permits. Over-irrigating landscapes conveys bacteria,
sediment, pesticides, and nutrients into water bodies, compromising human health and
ecosystems. Weather-based irrigation controllers help to reduce dry-weather runoff by
applying water only when plants need it. The WaterSense specification for weather-
based irrigation controllers has helped to transform the market for these devices, giving
California customers the confidence to buy controllers that perform, save water, and
reduce pollution.


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Administrator Wheeler

-3-

June 5, 2020

Water efficiency ensures water resources for present and future generations. With
the increased frequency and severity of droughts, California's water supplies have
become more vulnerable. The impacts of the 2012-2016 drought were serious and
widespread, prompting major legislative and regulatory changes. To adapt, California is
making water efficiency a way of life, which means doing more with less water. For
several decades, we have been on the right track. Since 1967, water use has increased
only 20 percent while California's population has doubled and the economic output has
increased fivefold. The increased efficiency and performance of water-saving fixtures,
such as WaterSense toilets, faucets and showerheads, have helped California
communities grow and prosper while saving water. Indoor water use rates continue to
decline in California, reflecting consumer confidence in and satisfaction with water
efficient products. On the precipice of what may be another major drought, we're
counting on WaterSense to help Californians stay on track.

Water efficiency keeps water affordable for customers and utilities. Water supply
vulnerability, aging infrastructure, and a growing population are impacting the costs
customers pay for water. Efficient plumbing standards and long-term conservation
programs lower costs for customers by helping to delay or even avoid the need to
develop new supplies and treatment capacity. The cheapest "new" water source is often
the more efficient use of what's already been developed. In Los Angeles, efficiency
measures have translated to a 26.7 percent reduction in water supply costs and
customer water bills. Water efficiency has benefited communities across California and
across the Country. According to the 2018 annual accomplishments report, WaterSense
has helped Americans save $84.2 billion in water and energy bills. Central to the
success of conservation programs are the availability and reliability of water efficient
products. When Californians look for the WaterSense label, they know they will find a
product that performs, saves water and saves money.

Thank you for considering the State Water Resources Control Board's comments.
Please do not hesitate to reach out with any questions, and we look forward to further
discussion on the multiple values of the WaterSense program for the State of California.

Sincerely,

E. Joaquin Esquivel

Chair, State Water Resources Control Board


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EPA

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

WaterSense

Commenter: David Epley
Affiliation: General Public
Comment Date: June 15, 2020
Document ID: EPA-HQ-OW-2020-0026-0067

Comment Text:

I have found Water Sense to be very helpful as a consumer when purchasing fixtures for
my home. It has helped me distinguish between a variety of products. With Water Sense
I can trust it has been tested and will deliver the water savings but also a good
performance. If looking to make changes, it would be nice to have a tiered Water Sense
structure that allowed for me to choose between a range of water efficient fixtures.

Thank you, David Epley

114

August 2020


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WaterSense

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Peter Mayer, Principal
Affiliation: WaterDM
Comment Date: June 16, 2020
Document ID: EPA-HQ-OW-2020-0026-0068

Comment Text:

Attached please find comments from Peter Mayer, P.E., Principal of WaterDM regarding
EPA-HQ-OW-2020-0026-0001

Attachment

See pages 116 through 121.

115

August 2020


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WaterDM

June 16, 2020

Comments on Docket ID No. EPA-HQ-OW-2020-0026

Request for Information on the WaterSense® Program

Stephanie Tanner and Veronica Blette
Office of Water

Environmental Protection Agency
1200 Pennsylvania Ave NW
Washington, DC 20460

Dear Ms. Tanner and M. Blette:

WaterSense is one of the most cost-effective government programs ever and I am writing to
express my strong support for the WaterSense program at the Environmental Protection
Agency (EPA). I have supported the WaterSense program since it was founded and I urge you to
continue and expand this remarkable program.

As a voluntary program rooted in providing consumers with efficient and high performing
product choices while giving utilities and local governments the tools and resources necessary
to support effective conservation programs, WaterSense is both valuable and cost-effective for
every stakeholder involved. EPA should assure the continued availability of this valuable
program as it continues to review the underlying specifications as necessary while dedicating all
other resources necessary to meet these objectives.

My comments focus on four specific areas of the Request for Information (ROI:

1. EPA should not include customer satisfaction criteria in the WaterSense product
specifications and guidelines.

Customer satisfaction criteria do not belong in WaterSense product specifications
themselves, but there are reasonable uses for customer satisfaction information within
WaterSense. Since its inception in 2006, WaterSense has sought to base its product
specifications on measured values of performance that are tested and certified in a lab. A
fundamental adherence to measured performance has provided a level playing field for
manufacturers who produce WaterSense products since 2006. The playing field is level
because the measured requirement of each specification is understood by product
manufacturers.


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Including a vague, non-scientific concept such as customer satisfaction criteria could
introduce uncertainty and bias into what has until now been a fair and scientific process for
set WaterSense specifications. Product-specific customer satisfaction research is best left to
the marketplace and manufacturers themselves. Product manufacturers conduct customer
satisfaction research frequently and keep the results to themselves so they can use it
strategically to develop their products and brand to competitive advantage.

2. Fixture performance has improved since the advent of WaterSense.

In 2003, three years before WaterSense was created, all toilets sold in the US were required
to comply with ASME Standard A112.19.2-203 which required testing with media comprised
of plastic "granules", nylon balls, sponges and kraft paper. Also in 2003 engineers John
Koeller and Bill Gauley created Maximum Performance Testing (MaP Testing) and began
bench-testing toilets using far more realistic test media comprised of dense bean paste.
MaP also began publishing testi results on a regular basis so that water utilities could
provide rebates to their customers for toilets that were proven to perform well using
realistic tests. Manufacturers voluntarily submitted their toilets for MaP Testing so that they
could be part of large rebate programs in California, Texas, Georgia, and elsewhere. Due to
this success, MaP Testing also expanded to include showerheads.

By June 2006 when the WaterSense program was created there were about 500 tank-type
toilet models submitted for MaP Testing and these toilets could remove an average of 420
grams each (Error! Reference source not found.)- As the WaterSense toilet specification for
tank-type toilets was developed many parties recommended that MaP Testing (or similar
testing using realistic test media) and ultimately the WaterSense tank-toilet minimum
performance specification was set at 350 grams of waste removal using the MaP approach.

The WaterSense tank-toilet specification was released in 2007 and since that time the
number of tested fixture models has gone from 500 to 3,390 and the average flushing
performance has improved from 500 grams of waste removed in a single flush to 897
grams. The impact of MaP Testing in improving toilet performance has been so significant
that it was incorporated the American ASME A112.19.2 and Canadian CSA B45.1-13
standards in 2013. Figure 1 shows the progression of fixtures tested and the improvement
in average flushing performance since the advent of MaP Testing and WaterSense.


-------
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Fixure Models Tested

Minimum Grams Removed to Achieve WaterSense

Figure 1: Fixture models tested and average grams of waste removed by tank-type toilets,
2003 - 2020 (Source: MaP Testing)

American consumers have expressed a high level of satisfaction with WaterSense labeled
products that have been tested through this process through their actions in the
marketplace since the program was introduced. Customers of the Home Depot were so
satisfied with WaterSense products that the company chose to sell WaterSense labeled
products exclusively in all of their stores. At competitor Loew's, the overwhelming majority
of eligible product offered for sale carry the WaterSense label. If there were a problem with
customer satisfaction, these retail giants would know it and would offer something
different. Home Depot and Loew's both understand that the performance standards
included in WaterSense product specifications create customer satisfaction because the
products that carry the WaterSense label perform better than the competition which is not
subject to rigorous performance testing.

WaterSense has operated on a shoestring budget for less than 15 years and has become
remarkably popular. WaterSense-certified tank-type toilets have a 16.8% market
penetration. WaterSense-certified bathroom sink faucets have a 40.1% market penetration,


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and WaterSense-certified showerheads have a 45.4% market penetration.1 WaterSense
manufacturer partners have produced nearly 3,900 WaterSense labeled tank-type toilets,
9,300 models of WaterSense labeled showerhead, and 18,000 WaterSense labeled lavatory
faucet and accessory models2. American consumers have voiced their satisfaction with their
purchases. Industry agrees and more than 1,700 manufacturers, retailers and distributors,
water and energy utilities, state and local government, non-profit and trade organizations,
irrigation training organizations, and home builders strengthen their businesses through
partnerships with WaterSense.

Based on this success, the popularity of WaterSense is expected to grow. Research from
Plumbing Manufacturer's International fond that within the next 15 years, most bathroom
sink faucets and showerheads installed in the United States will be WaterSense-certified or
meet the WaterSense program. Within the next 30 years, most residential tank-type toilets
will be WaterSense-certified or meet the WaterSense program. Within the next 40 years,
most flushometer-valve toilets and flushing urinals will be WaterSense-certified or meet the
WaterSense program.3

If customers were satisfied with their fixtures in 1999 they appeared to be equally satisfied
with their fixtures in 2016 and use them in pretty much the same way, even after the
advent of WaterSense and as the fixtures themselves have become more efficient. While
not addressing customer satisfaction or WaterSense products directly, the 1999 and 2016
Residential End Uses of Water Studies4 measured how people use water at home in their
daily lives. The studies reveal how frequently people use toilets and faucets and clothes
washers and to what extent those behaviors have changed over time. This information can
be a strong indicator of customer satisfaction. These paired residential end use studies offer
the best available measurements of key metrics such as the frequency of toilet flushing, the
duration of shower and faucet usage, and the flow rate of these fixtures. This information
provides valuable insight about water use patterns and indicate if people are using fixtures
the same or more frequently as the flow rates and flush volumes of the fixtures have
changed.

The results for toilet flushing, showering, and faucet use show that over 15 years, fixtures
themselves have become more efficient, but the use of these fixtures has not changed. The
average volume of water used to flush a toilet has decreased, but the average number of

1	U.S. WaterSense Market Penetration. A GMP Research Industry Report commissioned by Plumbing
Manufacturers International, https://www.safeplumbing.org/files/safeplumbing.org/documents/misc/7-l-19-
WaterSense-2019-Report.pdf

2	Federal Register. April 10, 2020. EPA-HQ-OW-2020-0026 - Request for Information on the WaterSense Program.
Vol. 85, No. 70.

3	IBID

4	DeOreo, W.B., P. Mayer, J. Kiefer, and B. Dziegielewski. 2016. Residential End Uses of Water, Version 2. Water
Research Foundation. Denver, CO.

Mayer, P., W. DeOreo, J. Kiefer, E. Opitz, B. Dziegielewski, and J.O. Nelson. 1999. Residential End Uses of Water.
Water Research Foundation, Denver, CO.


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flushes per person per day has stayed the same. The average number of minutes spent in
the shower has stayed the same. The average faucet use per person per day has stayed the
same. Subsequent analysis on shower patterns using the same Residential End Uses of
Water data sets found "on average, people do not compensate for lower flow rates by
increasing the duration of their shower and that lower flow rate showerheads do, on
average, result in a lower overall shower volume".5

3.	The Federal Register ROI contains problematic statements regarding product
standards.

Under section "V. Request for Information on Consumer Satisfaction" of the April 10 Federal
Register Notice it states the following (emphasis added):

"Understanding consumer satisfaction is important to the EPA as the Agency seeks to
ensure that our performance criteria review is in fact ensuring that labeled products
are meeting the same standards as products on the market before the WaterSense
label was adopted."

This statement is problematic for several reasons. First, the statement incorrectly implies
that products which achieve the WaterSense label are meeting different standards than
products which do not receive the label. In fact, all plumbing products and fixtures must
meet the same set of basic reference manufacturing standards established by the American
Society of Mechanical Engineers (ASME). While there is overlap, products that receive the
WaterSense label must be separately certified to meet the distinct WaterSense
specifications. Appendix A shows the current standards that all tank-type toilets must meet
in 2020 along with a history of these specifications since 2003.

Second, the statement wrongly implies that customer satisfaction for plumbing fixtures was
higher "back in the old days" before 2006 when the WaterSense label was adopted and that
products met a different standard back then. The tremendous success and popularity of
WaterSense labeled products is due in large part because WaterSense specifications include
measurable performance requirements that result in products that work better for
consumers. WaterSense labeled products meet a higher standard than non-labeled
products but this statement implies they should somehow meet the same standard.

Achieving the WaterSense label requires that products be tested to a higher standard and
the Federal Register statement wrongly implies that these don't meet the same minimum
basic standards as other fixtures. The confusion evident in this statement in the Federal
Register should be corrected.

4.	It is important the WaterSense specifications move forward and not remain static.

5 Gauley, B. and J. Koeller. 2017. How Showerhead Flow Rates Impact Shower Duration and Volume. Prepared for
the Alliance for Water Efficiency, www.map-testing.com


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The April 10 Federal Register Notice also included a summary of the review of WateSense
product performance criteria conducted as required under the authorizing legislation under the
America's Water Infrastructure Act (AWIA) of 2018. Based on this review, the EPA made the
decision not to revise any specifications.

I strongly believe it is important that specifications move forward and advance overtime. This
decision is acceptable today in 2020 but must be reviewed regularly so that WaterSense
products keep up with changing times and technology.

The WaterSense program has been a tremendous success for EPA. Public and private utilities in
all 50 states tailor successful water conservation programs around consumer use of
WaterSense-labeled products. And because of the nexus between water and energy use, the
3.4 trillion of gallons of water saved by WaterSense since 2006 have resulted in 462.5 billion
kilowatt hours of energy that are not used to heat, pump and distribute water. These savings
have resulted in a financial benefit to consumers on an average of $380 annually and $84.2
billion total in water, sewer, and energy bills since 2006.

Thank you for doing your utmost to ensure this inexpensive, valuable, and effective program
that continues to deliver for the American people.

Peter Mayer, P.E.

Principal

WaterDM

1339 Hawthorn Ave.
Boulder, CO 80304
www.waterdm.com

Sincerely,


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Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Jennifer L. Perry, Director, Water Planning and Management Division
Affiliation: Connecticut Department of Energy and Environmental Protection
Comment Date: June 19, 2020
Document ID: EPA-HQ-OW-2020-0026-0069

Comment Text:
See attached file(s).
Attachment

See pages 123 and 124.

4

EPA

WaterSense

122

August 2020


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Connecticut Department of

ENERGY &

ENVIRONMENTAL

PROTECTION

79 Elm Street • Hartford, CT 06106-5127

www.ct.gov/deep

Affirmative Action/Equal Opportunity Employer

Via Electronic Submission

To the Federal eRulemaking Portal

www.regulations.gov

U.S. Environmental Protection Agency
Docket ID Number: EPA-HW-OW-2020-0026

Re: Comments on Review ofWaterSense Program specifications
Dear Docket Administrator:

The Connecticut Department of Energy and Environmental Protection (CT DEEP) welcomes the
opportunity to comment on the United States Environmental Protection Agency's (EPA) decision
to maintain the WaterSense program specifications after a review in December 2019, as directed
by the America's Water Infrastructure Act (A WIA) of 2018. After completing the review, the EPA
has decided not to revise the WaterSense specifications.

The CT DEEP supports and promotes the foundational goals of utilizing water-efficient
infrastructure and practices in buildings and households across the state and providing education
in water conservation. To further these goals, the CT DEEP became a promotional partner of
WaterSense in March of 2020. We support the current standards set by the WaterSense program,
as well as any opportunity to update the WaterSense standards as more efficient technology
becomes available. The CT DEEP urges EPA to continue to collect information and revise
efficiency and test methods as appropriate.

Connecticut adopted the state's first State Water Plan on June 5, 2019 to provide a framework for
water management and conservation, now and into the future, to ensure that in-stream and out-of-
stream water needs are met across the state. The fundamental goals and principles of the
WaterSense program align with Connecticut's goals to use water more efficiently to ensure there
is a balance among users across the state. The WaterSense program will be a resource to the state
of Connecticut with completing goals outlined in our State Water Plan.

The CT DEEP understands the critical need to bring credibility to the marketplace for water-
efficient products. Consumer satisfaction ratings and reviews can serve as a supplemental rating
on a product labeled with the WaterSense logo, but should not be paramount to the water
efficiency of products. We do not support using consumer satisfaction ratings as a criteria for a
product to be WaterSense certified, nor including this information in product guidelines.
Consumer satisfaction ratings is pertinent data to a product's seller and producer, but should not
hold grounds in a federal water efficiency program's guidelines. The foundational components
of water efficiency and water conservation should be the primary matters handled by the
WaterSense Program.


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CT DEEP re: WaterSense Program Specifications

Page 2 of 2

Connecticut remains committed to forming a strong partnership with the WaterSense program,
and we will continue to support the program's goals of water conservation. We would be happy
to provide additional information concerning our comments.

Sincerely,

June 19, 2020
Date

Jennifer K Perry
Director

Water Planning and Management Division
Bureau of Water Planning and Land Reuse


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Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Kim Robinson
Affiliation: General Public
Comment Date: June 21, 2020
Document ID: EPA-HQ-OW-2020-0026-0070

Comment Text:

I am writing to comment on EPA-HQ-OW-2020-0026. As a parent, I am deeply
concerned about a sustainable future for my children, reducing household costs, and
clear labeling. The current WaterSense program specifications support all of these
important goals. I strongly support the current specifications and definitely do not believe
that customer satisfaction criteria should be included in them.

Thank you,

Kim Robinson

4

EPA

WaterSense

125

August 2020


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Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Anonymous
Affiliation: Anonymous
Comment Date: June 24, 2020
Document ID: EPA-HQ-OW-2020-0026-0071

Comment Text:

As an informed citizen, I would not like customer opinions to determine whether or not
an appliance should be taken into consideration for the WaterSense Program.
Researchers, scientists, and agencies complete arduous work to determine what
products and services are water-efficient, and will thereby save our precious natural
resources. As consumers, we trust in that work and the research that informs the
process. The climate crisis is significantly impacting our communities and local
environments, and products that save water are extremely beneficial. As a consumer, I
am grateful the WaterSense label is found in products, the WaterSense program tracks
how much water and energy has been saved. The benefits of the program are
tremendous. WaterSense helps me know that my purchase is not only saving me water,
but will preserve water for my children and grandchildren.

4

EPA

WaterSense

126

August 2020


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EPA

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

WaterSense

Commenter: M. Magana

Affiliation: General Public

Comment Date: July 1, 2020

Document ID: EPA-HQ-OW-2020-0026-0072

Comment Text:

I am writing in support of continuing the WaterSense Program. As a water utility, your
WaterSense program guidance and grant programs have been essential in delivering
educational information to our customers. We are a small utility that is extremely under-
staffed, and the WaterSense program has helped me meet compliance and water use
efficiency goals. WaterSense saves valuable time and money, and helps me meet the
many demands of a water system on a daily basis. Thank youf for ensuring this
inexpensive, valuable, and effective program continues to deliver for the American
people.

127

August 2020


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WaterSense

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Rick L. Callender, Chief of External Affairs
Affiliation: Santa Clara Valley Water District
Comment Date: June 29, 2020
Document ID: EPA-HQ-OW-2020-0026-0073

Comment Text:

Please see attached comments

Attachment

See pages 129 and 130.

128

August 2020


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Valley Water	Clean Water • Healthy Environment • Flood Protection

June 29, 2020

The Honorable Andrew Wheeler
Administrator

U.S. Environmental Protection Agency
1300 Pennsylvania Avenue
Washington, D.C. 20004

Subject: Comments on Docket ID No. EPA-HQ-OW-2020-0026
Request for Information on the WaterSense Program

Dear Administrator Wheeler:

On behalf of the Santa Clara Valley Water District (Valley Water), I write to express our strong support
for the Environmental Protection Agency's (EPA) WaterSense Program, in response to the Notice of
Recent Specifications Review and Request for Information published on April 10, 2020, in the Federal
Register. Thank you for the opportunity to comment on this important program.

The WaterSense Program has resulted in savings of $84.2 billion in water and energy bills since 2006.
The Program's products have resulted in exceptional performance, savings on our water bills, and
water efficiency. The program results in tangible savings for residents and businesses and has a
demonstrated track record of success, and therefore the specifications should not include customer
satisfaction criteria without first conducting adequate research and studies.

Valley Water's water conservation program relies on the EPA WaterSense program. Here are just a few
ways that Valley Water and Santa Clara County benefit from this program:

•	Valley Water-Landscape Rebate Program's Qualifying Weather Based Irrigation Controller List
is based on the EPA WaterSense certification. It's the only list that consistently evaluates the
efficiency of controllers and allows us to create a list of qualifying products.

•	We do not have the staff power or budget to create testing and certification programs on our
own, so we rely on WaterSense certification to ensure that we are rebating for products that are
performing to a higher standard.

•	Since 1992, this program has helped Valley Water save approximately 2.67 billion
kilowatt-hours (kWh) of energy (worth $347 million assuming average residential electricity
rates).

•	And during just the last fiscal year, the program helped our county save more than 70,000 acre
feet of water—enough to supply more than 700,000 people for a year!

In light of the success of the labeling program, Valley Water believes that customer satisfaction criteria
do not belong in WaterSense product specifications themselves. Instead, we recommend that further
revisions on any specifications center on adequate study, research, and a focus on future needs.

Santa Clara Valley Water District | 5750 Almaden Expressway, San Jose, CA 95118-3686 | (408)265-2600 | www.valleywater.org


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The Honorable Andrew Wheeler
Page 2

June 30, 2020

Thank you for doing your utmost to ensure that this inexpensive, valuable, and effective program
continues to deliver for the American people.

Rick L. Callender, Esq.

Chief of External Affairs
Acting for Norma J. Camacho
Chief Executive Officer

lf:fd

0630a-1

Sincerely,


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WaterSense

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Erik Hitchman, General Manager
Affiliation: Walnut Valley Water District
Comment Date: July 6, 2020
Document ID: EPA-HQ-OW-2020-0026-0074

Comment Text:

Walnut Valley Water District - Letter of Support

Attachment

See page 132.

131

August 2020


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WALNUT VALLEY WATER DISTRICT

BOARD OF DIRECTORS

271 South Brea Canyon Road
Walnut, California 91789-3002 • (909) 595-1268 • (626) 964-6551
www.wvwd.com • Fax: (909) 444-5521

Theresa Lee

President

Election Division III

Scarlett P. Kwong

First Vice President
Election Division V

Jerry Tang

Assistant T reasurer
Election Division I

Edwin M. Hilden

Director

Election Division II

STAFF

Erik Hitchman, P.E.

General Manager
Chief Engineer
Secretary

Brian Teuber

Assistant General Manager
T reasurer

Lily Lopez

Director of External Affairs

Sheryl L. Shaw, P.E.

Director of Engineering

Thomas M. Monk

Director of Operations

Gabriela Sanchez

Executive Secretary

LEGAL COUNSEL
James D. Ciampa

July 6, 2020

Mr. Andrew Wheeler
Administrator

US Environmental Protection Agency
Washington, DC

RE: Comments on Docket ID No. EPA-HQ-OW-2020-0026
Request for Information on the WaterSense® Program

Dear Administrator Wheeler:

The Walnut Valley Water District (WVWD) Board of Directors and staff strongly
support the continuation of the valuable and effective WaterSense program. Our
customers greatly benefit from WaterSense-labeled products, rebates, and
educational materials.

WVWD serves potable water to over 100,000 multi-use customers within a 20
square mile service area in eastern Los Angeles County. The WaterSense
program is a key component in our water conservation outreach to both our
residential and commercial customers. As we continue to expand the District's
conservation program, we plan to incorporate partnerships with energy utilities to
increase energy savings with WaterSense-labeled products.

Most importantly, the WaterSense brand and programs have proven very effective
nationwide. Annual water and energy savings continue to rise, resulting in a
significant financial benefit to both consumers and water, sewer and energy
utilities.

Thank you for providing us with this opportunity to comment on the WaterSense
program.

Sincerely,

0J



Erik Hitchman

General Manager

Walnut Valley Water District


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Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Kelly Kopp, Director

Affiliation: Center for Water Efficient Landscaping, Utah State University

Comment Date: July 21, 2020

Document ID: EPA-HQ-OW-2020-0026-0075

Comment Text:

Re: Docket ID No. EPA-HQ-OW-2020-0026

The Center for Water Efficient Landscaping writes today to submit comments regarding
WaterSense in response to the Notice of Recent Specifications Review and Request for
Information on the WaterSense Program published on April 10, 2020 in the Federal
Register. Please see the attached letter.

Attachment

See pages 134 and 135.

4

EPA

WaterSense

133

August 2020


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CENTER FOR

WATER-EFFICIENT

LANDSCAPING

July 21, 2020

To whom it may concern,

The Center for Water Efficient Landscaping, based at Utah State University, strongly supports
the USEPA's WaterSense Program. As a partner to the WaterSense Program, we write today to
submit comments to the Notice of Recent Specifications Review and Request for Information
on the WaterSense Program published April 10, 2020.

Since 2006, WaterSense has based its product specifications on measured values of
performance by a third-party certifying organization, the gold standard for performance
measures. This approach has not only provided clear guidance for manufacturers who produce
WaterSense products, but has also provided objective, research-based information to
consumers.

We oppose the proposed change to this process of inclusion of customer satisfaction data
within WaterSense product specifications. Including a non-scientific concept such as customer
satisfaction criteria in the specifications could introduce bias into what, up to now, has been an
objective and unbiased scientific process.

There are reasonable uses for product customer satisfaction information, but this research
should be left to manufacturers and the marketplace itself. Product manufacturers are well-
suited to this work, as they conduct such surveys routinely and use them in product
development and brand strategy.

Within WaterSense, we support limiting the scope of customer satisfaction research to the
WaterSense brand itself and WaterSense partnerships, such as those the ENERGY STAR
program has conducted in the past. This would inform the USEPA about American's opinion of
the program and their experience with the labeled products, helping guide the direction of the
program and brand, similarly to how manufacturers use such information to guide product
development.

We also write in support of allowing WaterSense to revise and develop specifications in the
future. This is imperative for advancing the specifications and allowing labelled products to
keep up with changing technologies and societal needs.

We note that more than 2,000 manufacturers, retailers and distributors, water and energy
utilities, state and local government, non-profit and trade organizations, irrigation training
organizations, and home builders strengthen their businesses through partnerships with
WaterSense. The program has also saved more than 4.4 trillion gallons of water and more than


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$87 billion in water, sewer and energy bills since 2006, not to mention the 522.9 billion
kilowatt-hours of electricity saved as a result of WaterSense-labeled product use.

The WaterSense program is a tremendous success for USEPA! And public and private utilities
and organizations in all 50 states, including our own, tailor successful water conservation
programs around consumer use of WaterSense labeled products.

Respectfully submitted,

Kelly Kopp, Director

Center for Water Efficient Landscaping

Utah State University


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WaterSense

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Rick Maloy, President
Affiliation: Utah Water Conservation Forum
Comment Date: July 21, 2020
Document ID: EPA-HQ-OW-2020-0026-0076

Comment Text:

Refer to: Docket ID No. EPA-HQ-OW-2020-0026

Attachment

See pages 137 and 138.

136

August 2020


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~

UTAH WATER

CONSERVATION FORUM

July 21, 2020

To whom it may concern,

The Utah Water Conservation Forum, a group of industry leaders and water professionals in
Utah, strongly supports the USEPA's WaterSense Program. As a partner to the WaterSense
Program, we write today to submit comments to the Notice of Recent Specifications Review
and Request for Information on the WaterSense Program published April 10, 2020.

Since 2006, WaterSense has based its product specifications on measured values of
performance by a third-party certifying organization, the gold standard for performance
measures. This approach has not only provided clear guidance for manufacturers who produce
WaterSense products, but has also provided objective, research-based information to
consumers.

We oppose the proposed change to this process of inclusion of customer satisfaction data
within WaterSense product specifications. Including a non-scientific concept such as customer
satisfaction criteria in the specifications could introduce bias into what, up to now, has been an
objective and unbiased scientific process.

There are reasonable uses for product customer satisfaction information, but this research
should be left to manufacturers and the marketplace itself. Product manufacturers are well-
suited to this work, as they conduct such surveys routinely and use them in product
development and brand strategy.

Within WaterSense, we support limiting the scope of customer satisfaction research to the
WaterSense brand itself and WaterSense partnerships, such as those the ENERGY STAR
program has conducted in the past. This would inform the USEPA about American's opinion of
the program and their experience with the labeled products, helping guide the direction of the
program and brand, similarly to how manufacturers use such information to guide product
development.

We also write in support of allowing WaterSense to revise and develop specifications in the
future. This is imperative for advancing the specifications and allowing labelled products to
keep up with changing technologies and societal needs.

We note that more than 2,000 manufacturers, retailers and distributors, water and energy
utilities, state and local government, non-profit and trade organizations, irrigation training


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organizations, and home builders strengthen their businesses through partnerships with
WaterSense. The program has also saved more than 4.4 trillion gallons of water and more than
$87 billion in water, sewer and energy bills since 2006, not to mention the 522.9 billion
kilowatt-hours of electricity saved as a result of WaterSense-labeled product use.

The WaterSense program is a tremendous success for USEPA! And public and private utilities
and organizations in all 50 states, including our own, tailor successful water conservation
programs around consumer use of WaterSense labeled products.

Respectfully submitted,

Rick Maloy, President

Utah Water Conservation Forum


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WaterSense

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Donald F. Greeley, Director

Affiliation: City of Durham (North Carolina) Department of Water Management

Comment Date: July 21, 2020

Document ID: EPA-HQ-OW-2020-0026-0077

Comment Text:
See attached file(s)
Attachment

See pages 140 and 141.

139

August 2020


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I

******

WATER MANAGEMENT
CITY OF DURHAM

July 21, 2020

Mr. Andrew Wheeler
Administrator

US Environmental Protection Agency
Washington, DC

RE: Comments on Docket ID No. EPA-HQ-OW-2020-0026
Request for information on the WaterSense® Program

Dear Administrator Wheeler:

The City of Durham Department of Water Management (DWM) respectfully submits the following comments in
response to the Notice of Recent Specifications Review and Request for Information on the WaterSense Program
published on April 10, 2020 in the Federal Register as Docket ID: EPA-HQ-OW-2020-0026.

In Durham, we regularly utilize the tools, technical assistance, research, and data provided by the WaterSense
program. The City of Durham has been a promotional partner in the EPA's WaterSense Program since 2007, and
it has become absolutely essential to our ongoing efforts to provide quality services and programming to our
residents and customers. Our Toilet Rebate program and our Water Efficiency Kit program rely the WaterSense
product labeling system.

In 2019 alone, we estimate that Durham's WaterSense-related programming, such as our toilet rebate program
and showerhead program, saved over 4.5 million gallons. Durham's experience has been that customers and
retailers are very satisfied with products that have received the WaterSense label. In the 12 years that we have
been WaterSense promotional partners, we have not received any complaints regarding the performance of
their fixtures from participants in our programs.

Nationally, the program has saved trillions of gallons of water and has provided customers with confidence in
their purchasing choices of water-efficientfixtures. By focusing on both water-savings and performance, the
WaterSense program has a successful history of working with relevant manufacturers and interested parties to
craft fair, science-based methods to evaluate the efficacy of products.

As such, DWM believes that customer satisfaction criteria should not be included as part of WaterSense product
specifications. Incorporating customer satisfaction criteria into WaterSense specifications would introduce
uncertainty and bias into an otherwise fair and scientific process.

DWM supports the EPA's decision not to revise any product specifications at this time; however, we do suggest
that the EPA continue to regularly review WaterSense product performance criteria. As technology changes,
periodic review of product performance and specifications will allow WaterSense to ensure product
specifications continually advance.

1600 Mist Lake Dr. Durham, NC 27704	919.560.4381	DurhamNC.gov	Follow Us @CityofDurhamNC

GO ©


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Thank you for the opportunity to provide input on the WaterSense Program. Durham remains committed to
partnering with EPA WaterSense program and will continue to support the program's goals for water efficiency.
We value and appreciate the EPA's continued efforts to support and ensure the continuity of this essential and
effective program.

Sincerely,

Donald F. Greeley, P.E., P.L.S.
Director

1600 Mist Lake Dr. Durham, NC 27704

919.560.4381

DurhamNC.gov

Follow Us @CityofDurhamNC

oo ©


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EPA

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

WaterSense

Commenter: Katherine Zitsch, Director

Affiliation: Metropolitan North Georgia Water Planning District

Comment Date: July 23, 2020

Document ID: EPA-HQ-OW-2020-0026-0078

Comment Text:

Please find attached the Metropolitan North Georgia Water Planning District's comments
on the Notice of Recent Specifications Review and Request for Information on
WaterSense Program.

Attachment

See pages 143 through 150.

142

August 2020


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Metropolitan North Georgia Water Planning District

International Tower I 229 Peachtree St., NE I Suite 100 I Atlanta, GA 30303

July 23, 2020

VIA REGULATIONS.GOV

Docket ID No. EPA-HQ-OW-2020- 0026

Mr. Andrew Wheeler
Administrator

US Environmental Protection Agency
Washington, DC

RE: Metropolitan North Georgia Water Planning District's Comments

Notice of Recent Specifications Review and Request for Information on WaterSense Program

Dear Administrator Wheeler,

The Metropolitan North Georgia Water Planning District (the "District"') appreciates the
opportunity to provide comments regarding the EPA's Notice of Recent Specificati ons Review
and Request for Information on WaterSense Program ("Request for Information"). The District
is a regional water planning organization covering 15 counties and 95 cities across the greater
metropolitan Atlanta area, serving as a regional source of expertise regarding water use and
efficiency. For five consecutive years, the EPA has recognized the Metro Water District for its
innovative water conservation programming and close collaboration with its network of partners,
including the 55 water providers in the metro Atlanta region. Most recently, the District received
the WaterSense Sustained Excellence Award in October 2019. The District's work includes our
regional Water Resource Management Plan, a technical assistance program, and extensive
educational and outreach efforts. These efforts have distinguished the District as a national leader
in water conservation and have contributed to a 10% decrease in total withdrawals within the
Metro Atlanta region, while the area's population has increased by 1.3 million individuals since
2000.

Many of the District's water efficiency programs depend on WaterSense-labeled products,
including:

•	The current Georgia plumbing code requires the use of WaterSense labeled toilets,
urinals, and lavatory faucets.

•	The District and our utility partners have saved more than 2.4 million gallons of water per
day through the replacement of over 145,000 old and inefficient toilets with WaterSense
toilets.


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July 23, 2020
Mr. Andrew Wheeler
Page 2

•	The District specifies the use of WaterSense labeled irrigation controllers within its
ordinance on large landscapes.

•	The District requires the replacement of inefficient toilets and urinals with WaterSense
labeled versions within local government buildings.

WaterSense programs are well-integrated into the District's work. The District looks to the
program for the promotion, education and implementation of water conservation and efficiency
and utilizes these tools within our own scope of work. Given the District's experience with the
WaterSense program, we would like to express our support for the Alliance for Water Efficiency's
(AWE) comments related to EPA's Request for Information.

Through a variety of programs, the District advocates for the adoption and utilization of leading
water efficient products that are readily available on the market. The District strongly agrees with
AWE that it is critical that specifications continue to progress in efficiency capabilities into the
future. Though the EPA is electing not to revise any WaterSense specifications at this time, the
District believes these specifications should be regularly re-assessed into the future to ensure that
WaterSense products are keeping pace with those available on the market.

With rapid advancements in technology, and the decision not to revise the WaterSense standards
today, it can no longer be guaranteed that WaterSense labeled products are providing the highest
level of efficiency among readily available products. The District recently conducted market
research (See Attachment A) on the availability of efficient plumbing fixtures. These results were
published in 2020 in The Georgia Operator. 1 Results indicated that there are a wide variety of
ultra-high efficient fixtures readily available today, with some in greater quantities than fixture
products meeting the minimum level of efficiency required in current WaterSense specifications.

With continuous rapid advancements in technology, the WaterSense program should reflect the
leading products in water efficiency to continue to drive the market. If the goal is for WaterSense
labeled products to be at least 20% more efficient than standard models, as stated in various
program materials and the Request for Information, it appears that WaterSense is not meeting this
goal in Georgia. Given that other states also have ultra-high efficiency plumbing codes and
programs, this goal is likely not being met in other states as well.

As a result of WaterSense's decision not to update its standards at this time, the District can no
longer rely solely on the WaterSense label to ensure consumers receive the benefit of the most
efficient, readily available technologies. For example, of the showerheads reviewed as part of the
District's retail market research, 72% (465 models) used 1.8 gpm or less. The WaterSense label
requires showerheads using 2.0 gpm or less. As a result, the District's programs will now ask
customers looking to maximize their efficiency to look for the WaterSense label and fixtures that
use 1.8 gpm.

1 Georgia Operator Summer 2020 issue (p.40-42) (https://www.gawp.org/page/GAOPOnlineMagazine)


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July 23, 2020

Mr. Andrew Wheeler

Page 3

As another example, 1.2 gpm lavatory faucets were common based on the retail market data.
Currently, WaterSense labels lavatory faucets using 1.5 gpm or less. This availability of 1.2 gpm
lavatory facuets presents the program with the opportunity to further increase WaterSense
efficiency standards.

The WaterSense program is, and will remain, vital to the planning process and work of the District,
and we will continue to promote this program. However, when the WaterSense program lags
behind the efficiency levels of readily available products, the District's message to consumers will
need to be more nuanced and complex. Ideally, the WaterSense specifications would be revised
soon to account for the higher efficiency levels of readily available products.

The District is grateful for this opportunity to share our comments. The WaterSense program
demonstrates on a national scale the significance of water as a resource now and into the future.
Moving forward, the District intends to maintain our strong relationship with WaterSense and
continue to utilize the program as a standard within our work.

If you have any questions regarding this letter, the District, or our research, please do not hesitate
to reach out at kzitsch@atlantaregional.org.

Sincerely,

Katherine Zitsch
Director

Metropolitan North Georgia Water Planning District

cc: Glenn Page, District Board Chair


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July 23, 2020
Mr. Andrew Wheeler
Page 4

Attachment A

Market Research Shows Current Georgia Plumbing Fixture Efficiency Requirements Are
Often Exceeded

by Andrew D. Morris, Celine Mollet Saint Benoit, and Jacob Whitacre

Published in The Georgia Operator, Summer 2020 issue (p.40-42)
(https://www.gawp.org/page/GAOPOnlineMagazine)

The Metropolitan North Georgia Water Planning District (the "Metro Water District") is
frequently presented with the following question from utilities and other stakeholders: "With
Georgia already a national leader on water efficiency, how much more efficient can residential
customers become?"

Georgia's national leadership over the past two decades is unquestionable. For example, Georgia
is ranked as the 4th best state for water efficiency and conservation in the Alliance for Water
Efficiency's 2017 report titled: "The Water Efficiency and Conservation State Scorecard: An
Assessment of Laws." Only Arizona, California, and Texas scored better than Georgia on this
scorecard. Exemplifying this success, the Metro Water District withdraws 10% less water today
than in 2000 despite a 1.3 million increase in population.

Efforts by the State of Georgia, the Metro Water District, and utilities have all helped drive down
total water withdrawals and per person water demands. The use of high-efficiency plumbing
fixtures has played a key role in this progress. In the 2000s, the Metro Water District and its local
government partners promoted high-efficiency fixtures through rebates, education, and a variety
of other programs. The State of Georgia built on these efforts in 2010 when the Georgia General
Assembly passed the Georgia Water Stewardship Act. This act requires, among other things, the
use of high-efficiency plumbing fixtures through plumbing code standards for toilets, urinals,
and faucets in new and renovated buildings.

Since it's been 10 years since the Georgia Water Stewardship Act was passed, a review of
current trends in water efficient plumbing fixtures is needed to answer the question of what
additional efficiency is feasible today. Therefore, the Metro Water District has taken a data-
driven approach to survey today's technology trends and to see how plumbing fixtures in retail
stores meet or exceed the State of Georgia's minimum plumbing fixture efficiency requirements.

For the Metro Water District's market research, plumbing fixtures available in stores at Home
Depot, Lowe's, and Walmart retail stores in the Metro Water District were reviewed. Five of
each store, for a total of 15 retail stores, were selected at random, and research was conducted at
the following locations:


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July 23, 2020
Mr. Andrew Wheeler
Page 5

9 Plumbing Fixture Store Locations
	Metro Water District Boundary

—i Metro water District counbes Store Locations within Metro Atlanta

The market research was performed electronically by selecting a specific store location on each
retailer's website and then choosing the option to only show products available on the day of the
review at the selected store. Fixture data were gathered from retail stores because they provided
the most robust and readily accessible data set on plumbing fixture availability, pricing, and
customer satisfaction. While many fixtures are sold through other channels to builders and
contractors, these sources do not readily provide the same amount and quality of data.

Table 1 shows the current fixture efficiency requirements in the State of Georgia. In the figures
below, fixtures listed as meeting current efficiency requirements are those that match exactly the
current Georgia efficiency requirements. The retail market data shown in these figures strongly
support the conclusion that exceeding current efficiency requirements remains feasible for three
reasons.

Table 1. Current Georgia Efficiency Requirements.

Fixture

GA State Code

Toilet

1.28 gpf

Showerhead

2.5 gpm

.

Kitchen Faucet

2.0 gpm

Lavatory Faucet

1.5 gpm

First, fixtures that exceed the current efficiency requirements are readily available. In fact, the
results provided in Figure 1 show that, except for toilets, there are many more fixtures available
in retail stores that exceed the standards than those that meet it.


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July 23, 2020
Mr. Andrew Wheeler
Page 6

180
160
140
120
100
80
60
40
20
0

Market Availability (number of models)
per Fixture















1



128





















131





































62













2



-1



Toilets	Showerheads	Kitchen Faucets Lavatory Faucets

Meets Current Efficiency Requirements ¦ Exceeds Current Efficiency Requirements

Figure 1. Market availability of fixture models.

Showerheads and faucets that exceed current requirements are widely available. It's worth noting
that while only four toilet models that exceed current efficiency requirements were available in
stores, nearly every store carried at least one of these four very popular models that exceed
current efficiency requirements. The Metro Water District is exploring additional research
avenues to understand what models are available beyond retail store shelves that exceed current
efficiency requirements. For example, the MaP voluntary toilet performance testing program has
tested more than 100 models that exceed current efficiency requirements. See https://www.map-
testing.com/map-premium.html. More research is needed to understand why more models are not
available at retail.

Second, customers appear to be very satisfied, and sometimes more satisfied, with fixtures that
exceed current efficiency requirements as seen in Figure 2. We've excluded faucets from the
chart below given how few faucets are available that merely meet the current efficient
requirements (2 kitchen faucets and 1 lavatory faucet).


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July 23, 2020
Mr. Andrew Wheeler
Page 7

5.0

4.0

3.0

2.0

1.0

0.0

Average Customer Satisfaction Rating

4.9

Toilets

I Meets Current Efficiency Requirements

Showerheads
I Exceeds Current Efficiency Requirements

Figure 2. Customer satisfaction ratings of toilet and showerhead fixtures.

Third, fixtures that exceed current efficiency requirements fall within a similar price range as
demonstrated in Figure 3. Again, faucets have been excluded given the limited number available
that merely meet current requirements.

Average Fixture Price

$250

Toilets	Showerheads

¦ Meets Current Efficiency Requirements ¦ Exceeds Current Efficiency Requirements

Figure 3. Average price of toilet and showerhead fixtures.


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July 23, 2020
Mr. Andrew Wheeler
Page 8

While the average price for showerheads that exceed current efficiency requirements is
somewhat higher, the difference in price would be recouped in utility bill savings in less than a
year. Compared to showerheads that merely meet Georgia's current efficiency requirements,
EPA's WaterSense program estimated the utility bill savings in its March 4, 2010 Supporting
Statement for the WaterSense Specification for Showerheads, with the WaterSense showerheads
exceeding Georgia's current efficiency requirements. The relevant part reads:

"The average homeowner retrofitting his or her showerheads with WaterSense labeled
showerheads will realize an accompanying $14 savings on water and wastewater costs
annually due to lower water consumption. Factoring in the accompanying energy savings,
the average household with electric water heating may save an additional $36, for a
combined annual savings of $50. The average household with natural gas water heating
may save an additional $18 for a combined annual savings of $32."

Accounting for inflation and average water, sewer, and energy rate increases since 2010 when
WaterSense did this analysis, the savings would be even larger today.

Also, if one is looking for the least expensive showerhead options, our data show that five of the
10 least expensive models were models that exceed current efficiency requirements. Clearly,
many low-cost showerhead models are available.

In conclusion, the data from the Metro Water District show that plumbing fixture technology and
markets continue to advance, and so the question "How much more efficient can our residential
customers become?" is one that must be reevaluated from time to time. Based on this evaluation
of current technologies available at retail stores in the Metro Water District, exceeding current
efficiency requirements remains feasible.

The data also show that, even without code changes, some new and renovated homes will use
fixtures that exceed current efficiency requirements based simply on what is already widely
available on retail store shelves.

The Metro Water District expects to continue our work to take advantage of new efficiency
opportunities through a data driven approach. We would love to hear from you if you have
experience or insights on plumbing fixture efficiency that will help us in our research, analysis,
and action through the Metro Water District's technical assistance programming and next
regional plan update.

Note: copies of the retail data are available by emailing amorris@northgeorgiawater. com.


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EPA

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

WaterSense

Commenter: Denis Martynowych
Affiliation: General Public
Comment Date: July 23, 2020
Document ID: EPA-HQ-OW-2020-0026-0079

Comment Text:

EPA's Water Sense program has proved VERY useful. It must b e continued and fully
supported as a proven source of high quality research and education in how Americans
as individuals, communities and businesses can save water and money. Frivolous,
politically motivated attacks like the President Trumps complaints about double flushing
toilets are not grounded in science. Water efficiency is critically important. It prolongs the
life of our infrastructure, it saves consumers money, and it protects a precious, limited
resource.

151

August 2020


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Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Sara Elsa-Beech
Affiliation: General Public
Comment Date: July 23, 2020
Document ID: EPA-HQ-OW-2020-0026-0080

Comment Text:

As an architect long involved in water-conservation and sustainability, I would like to
comment on EPA-HQ-OW-2020-0026. The current WaterSense program has done a
tremendous amount to promote and support water-efficiency. This national program has
enabled water agencies across the nation to be able to implement successful water
conservation programs involving consumer selection, and use of, WaterSense-labeled
products. The development of reliable water-efficient technology has been a real
success of our nation, and a national program to promote and support this is critical. The
WaterSense program does not need to include customer satisfaction criteria; I strongly
support the program as it has been running, without weakening or the distraction of
added customer satisfaction criteria. Thank you for the consideration.

4

EPA

WaterSense

152

August 2020


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WaterSense

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Elizabeth Beardsley, Senior Policy Counsel
Affiliation: U.S. Green Building Council (USGBC)
Comment Date: July 23, 2020
Document ID: EPA-HQ-OW-2020-0026-0081

Comment Text:

Please see comments from the U.S. Green Building Council (USGBC) in the attached
file.

Attachment

See pages 154 through 156.

153

August 2020


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July 23, 2020
David Ross

Assistant Administrator
Office of Water

Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Washington, DC, 20460

RE: Recent Specifications Review and Request for Information on WaterSense Program
Dear Assistant Administrator Ross,

On behalf of the U.S. Green Building Council (USGBC) and our over 9,000 member
companies nationwide, we are pleased to provide our comments regarding EPA's
recent specifications review of the WaterSense Program.

USGBC is a nonprofit organization dedicated to transforming the way buildings and
communities are designed, built and operated, enabling an environmentally and socially
responsible, healthy, and prosperous world. Our flagship green building system,
Leadership in Energy & Environmental Design (LEED), has been embraced across the
world. USGBC represents a full range in the building sector, including builders, product
manufacturers, professional firms, and real estate professionals.

First and foremost, we urge EPA to continue to fully implement and invest resources in
the WaterSense program. Since its creation in 2006, WaterSense has saved more than 4.4
trillion gallons of water as a voluntary labeling program.1 The program has saved users
more than $87 billion in water and energy bills over the same timeframe.2 In 2018,
Congress statutorily authorized and expanded the program via America's Water
Infrastructure Act (AWIA) of 2018. The law required EPA to "consider for review and
revise, if necessary, any WaterSense performance criteria adopted before January 1,
2012."3

On behalf of our member organizations and credentialed professionals, USGBC wishes to
express our support for EPA's proposed decision not to revise WaterSense program
specifications. EPA's proposal means standards will remain unchanged—standards that
saved Americans 871 billion gallons of water in 2019 alone.4

1	Environmental Protection Agency, "WaterSense Accomplishments 2019."
https://www.epa.gov/sites/production/files/2020-Q7/documents/ws-aboutus-
2019 watersense accomplishments.pdf.

2	Ibid.

3	America's Water Infrastructure Act of 2018 (AWIA), p. 121.
https://www.congress.gov/115/bills/s3021/BILLS-115s3021enr.pdf.

4	Ibid.

USGBC

2101 L STREET, NW
SUITE 500

WASHINGTON DC 20037
202 828-7422
USGBC.ORG

FOUNDERS

David Gottfried
Michael Italiano
S. Richard Fedrizzi


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USGBC

2101 L STREET, NW
SUITE 500

WASHINGTON DC 20037
202 828-7422
USGBC.ORG

David Gottfried
Michael Italiano
S. Richard Fedrizzi

USGBC relies on WaterSense because of its rigorous 3rd party performance testing and
life-cycle quality assurance to ensure fixtures installed in residential, commercial, and
government buildings are truly water efficient. Every prospective LEED project must
achieve the Indoor Water Use Reduction prerequisite, which sets minimum water
efficiency metrics.5 The prerequisite requires all newly installed toilets, urinals, private
lavatory faucets, and showerheads to feature the WaterSense label.

We concur with comments made by the Alliance for Water Efficiency (AWE), stated in
their letter dated June 8. There are reasonable uses for customer satisfaction information
within WaterSense, but customer satisfaction criteria do not belong in product
specifications themselves.6 We also reiterate comments made by the Connecticut
Department of Energy and Environmental Protection in their letter dated June 19, that
consumer satisfaction ratings should not become a criterion for a product to achieve
WaterSense certification.7 Rigorous product performance standards alone should dictate
whether or not a product achieves WaterSense certification. To the extent that EPA
proceeds with consideration of consumer satisfaction in the program—by providing
additional information for the public but not part of certification, for example—the data
should be representative of all consumers, unbiased, and independently obtained by a
third party.

The success of the WaterSense program clearly contributes to the program's well-
documented popularity. According to a survey of utility companies conducted by the
American Water Works Association, all respondents reported their end-use customers
were satisfied with WaterSense labeled products.8 The popularity of the certification with
consumers led The Home Depot to exclusively feature WaterSense products at their retail
stores.9 We agree with AWE, that the program enjoys "tremendous success and
popularity...because WaterSense specifications include measurable performance
requirements that result in products that work better for consumers than the products
they had before."1"

USGBC commends EPA for the clear successes of the WaterSense program. Preserving
performance-based program specifications would ensure users continue to save water,
energy, and money.

5	Indoor Water Use Reduction Credit, https://www.usgbc.org/credits/new-construction-core-and-shell-data-
centers-new-construction-warehouse-and-distribution-
0?return=/credits/New%20Construction/v4.1/W atei%20efficiencv.

6	Alliance for Water Efficiency, June 8, 2020. "Comments on Docket ID No. EPA-HQ-OW-2020-0026
Request for Infonnation on the WaterSense® Program."

https://www.allianceforwaterefficiencv.org/sites/www.allianceforwaterefficiencv.org/files/assets/AWE-
Letter-to-EPA-Admin-Wheeler-regarding-Federal-Register-NOI-final.pdf. pp. 1-9.

7	Connecticut Department of Energy and Environmental Protection, June 19, 2020. "Re: Comments on
Review of WaterSense Program specifications." https://beta.regulations.gov/document/EPA-HQ-OW-
2020-0026-0069. 1.

8	American Water Works Association, June 8, 2020. "Comments onEPA's "Notice of Recent
Specifications Review and Request for Infonnation on WaterSense Program (EPA-HQ-OW-2020-0026)".
https://beta.regulations.gov/document/EPA-HO-OW-2020-0026-0Q65. 4.

9	Alliance for Water Efficiency, June 8, 2020. 7.

10	Ibid, 8.


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Please do not hesitate to contact us if you have any questions, or if we can be of any
assistance.

USGBC

2101 L STREET, NW
SUITE 500

WASHINGTON DC 20037
202 828-7422
USGBC.ORG

David Gottfried
Michael Italiano
S. Richard Fedrizzi

Sincerely,

Elizabeth Beardsley
Senior Policy Counsel
ebeardslev@usgbc.org

U.S. Green Building Council
2101 L Street NW Suite 500
Washington, DC 20037


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WaterSense

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Clifford C. Chan, General Manager
Affiliation: East Bay Municipal Utility District (EBMUD)
Comment Date: July 23, 2020
Document ID: EPA-HQ-OW-2020-0026-0082

Comment Text:
See attached file(s)
Attachment

See page 158.

157

August 2020


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 EAST BAY
 MUNICIPAL UTILITY DISTRICT

CLIFFORD C CHAN
GENERAL MANAGER

July 23, 2020

VIA FEDERAL E-RULEMAKJNG PORTAL

Mr. Andrew Wheeler
Administrator

United States Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Washington, DC 20460

Re: Comments on Docket ID No. EPA-HQ-OW-2020-0Q26
Request for Information on the WaterSense® Program

Dear Administrator Wheeler:

The East Bay Municipal Utility District (EBMUD) writes to express its strong support for the
WaterSense labeling program administered by the United States Environmental Protection
Agency. The WaterSense program has a successful track record of helping consumers save
water and money. It is also a vital tool that helps water agencies manage limited water
resources.

According to the Alliance for Water Efficiency (AWE), since its inception in 2006 the
WaterSense program has saved more than 4.4 trillion gallons of water. The program has also
helped consumers save money. The average American family spends more than $1,000 per
year on water but can save more than a third of that amount by retrofitting with WaterSense-
labeled fixtures and ENERGY STAR-certified appliances. In total, il is estimated that the
program has yielded more than $87 billion in savings on water, sewer, and energy bills. The
program has accomplished this despite a modest annual budget of S2 million.

The WaterSense program is particularly vital to water agencies looking to manage scarce
resources. EBMUD serves more than 1.4 million customers in the eastern San Francisco Bay
Area. Significant fluctuations in annual hydrology, including droughts, lead to uncertainty in
EBMUD's supply of potable water. In order to ensure the long-term reliability of its water
supply, EBMUD requires that new developments use water-efficient fixtures and appliances.
The WaterSense program makes it easy for customers to comply with these requirements.

Lastly, EBMUD is an active member of AWE and supports the points that AWE raised in its
own July 22, 2020, comment letter.

Sincerely,

Clifford C. Chan

375 ELEVENTH STREET . OAKLAND . CA 9-160742JO - (510)287-0101
BOARD OF DIRECTORS JOHN A. COLEMAN . ANDY KATZ . DOUG LtNNEY

lbsa r, Mcintosh . frank mellon . wiluamb. Patterson . marguerite young


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WaterSense

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Steven Westphal, Senior Legal Director - Commercial

Affiliation: KohlerCo.

Comment Date: July 23, 2020

Document ID: EPA-HQ-OW-2020-0026-0083

Comment Text:

Please find comments from Kohler Co. attached.

Attachment

See pages 160 and 161.

159

August 2020


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KohlerCo. 444 Highland Drive Kohler, Wisconsin 53044 920-457-4441 kohier.com

KOHLER.

U.S. Environmental Protection Agency

RE: Docket ID No. EPA-HQ-OW-2020-0026 Request for Information on the WaterSense® Program

Dear Docket Administrator:

As a leading manufacturer of bathroom and kitchen plumbing fixtures, Kohler Co. deeply values
sustainable water use in our operations, the home and the community. Based in Wisconsin, Kohler Co.
has worked consistently for more than a decade to make it easier for Americans to use less water without
sacrificing the performance they expect in their kitchens and bathrooms. Being a manufacturer of
WaterSense products, such as showerheads, toilets, urinals and lavatory faucets, Kohler Co. appreciates
the opportunity to provide comments on the Request for Information on the WaterSense® Program,
Docket ID No" EPA-HQ-OW-2020-0026.

Kohler Co. is highly supportive of the EPA WaterSense program and has been since its inception in 2006.
As a partner in the program, we strive to not only be engaged but to excel, earning ten EPA WaterSense
awards including multiple Manufacturer Partner of the Year and Sustained Excellence awards. We have
found the program to be effective for manufacturers, retailers and consumers, so much so that we have
worked to promote it in other countries as well.

As a manufacturer, we value this robust program, developed in conjunction with all stakeholders using a
balanced, consensus process. The input of manufacturers is, and should continue to be, utilized during the
development and review of WaterSense specifications. We appreciate that the WaterSense program
brought consistency to water efficiency programs nationally. Prior to its inception, cities and states were
developing unharmonized requirements for water consumption, or for eligibility for rebates from their
local efficiency programs. By creating a national program, manufacturers were able to focus their
product development strategies on specific targets with the knowledge that markets would accept the new
products. As states looked to mandate higher levels of water efficiency, Kohler Co. and other plumbing
manufacturers encouraged them to adopt WaterSense. Almost all of them did and were able to implement
new rules with little to no disruption of the market.

The EPA WaterSense program provides value to consumers, allowing an easy way to identify efficient
products that have been tested to performance standards. We currently offer over 900 WaterSense
certified products. This investment is not only because we believe in the value of water, but because
consumers are purchasing these products. Regarding customer satisfaction, over 98% of customer
inquiries in 2019 were not associated with high efficiency product flow or flushing performance,
demonstrating that overall, consumers are satisfied with WaterSense certified products.

Additionally, internal retail market research from 2017 offered findings that demonstrated once the
WaterSense program was explained, the majority of panelists stated they would be more likely to
purchase products with the WaterSense label. This supports the position that if the benefits of
WaterSense are shared with the public, customers are more likely to purchase a WaterSense product over
a non-WaterSense product.


-------
KohlerCo. 444 Highland Drive Kohler, Wisconsin 53044 920-457-4441 kohier.com

KOHLER.

Finally, regarding the request for customer satisfaction studies or how to conduct studies, Kohler Co.
acknowledges that consumer satisfaction is an integral part of the success of the WaterSense program.
Prior to lowering flow rates, understanding unintended consequences to public health, infrastructure and
general satisfaction is imperative to the future success of the WaterSense program.

We thank you for the opportunity to provide comments and look forward to our continued partnership
with the EPA WaterSense program

Sincerely,

Steven Westphal

Sr. Legal Director - Commercial


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EPA

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

WaterSense

Commenter: Jerricho Jonker
Affiliation: General Public
Comment Date: July 23, 2020
Document ID: EPA-HQ-OW-2020-0026-0084

Comment Text:

As a science student and currently a LEED Green Associate, I have learned it is very
important to be efficient with our water, as there is so little fresh water left on earth. I
completely support the WaterSense Program and hope they continue to find more ways
to help reduce waste.

162

August 2020


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EPA

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

WaterSense

Commenter: Shyama Orum
Affiliation: General Public
Comment Date: July 23, 2020
Document ID: EPA-HQ-OW-2020-0026-0085

Comment Text:

As an American I urge you to continue the WaterSense program. Water is a previous
resource and we need to conserve it as well as prevent water pollution. Since its
inception, the WaterSense program has saved over 4 trillion gallons of water. It has also
saved consumers over $87 billion dollars in water and energy costs. This is a program
that benefits everyone. Please continue it.

163

August 2020


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Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Morgan Shimabuku, Research Associate, and Peter H. Gleick, President-
emeritus

Affiliation: Pacific Institute

Comment Date: July 23, 2020

Document ID: EPA-HQ-OW-2020-0026-0086

Comment Text:

Please see comments provided in the attached letter.
Attachment

See pages 165 through 167.

4

EPA

WaterSense

164

August 2020


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PACIFIC

INSTITUTE	Research for People and the Planet

July 23, 2020

Mr. Andrew Wheeler
Administrator

US Environmental Protection Agency
Washington, D.C.

Re: Docket ID No. EPA-HQ-OW-2020- 0026
Dear Mr. Wheeler,

The Pacific Institute writes to express our strong support for both maintaining and strengthening the
WaterSense Program at the U.S. Environmental Protection Agency (USEPA) and to share with you
our submitted comments regarding WaterSense. We are filing these comments in response to the
Notice of Recent Specifications Review and Request for Information on the WaterSense Program
published on April 10, 2020 in the Federal Register. Our comments address the recent USEPA review
of the WaterSense Program and highlight the many benefits that residential and non-residential
consumers, communities, and our nation receive from the expanding use of WaterSense labeled
products.

First, the decision to keep in place current WaterSense standards for water-related appliances and
fixtures is the minimum response — those standards have proven tremendously effective at reducing
the water, energy, and economic costs of those water-using fixtures and to have weakened any of
them would have had a huge and adverse economic impact on manufacturers and consumers. We
believe, however, the evidence also supports updating, strengthening, and expanding WaterSense to
cover new technologies. This includes all devices currently under consideration by the WaterSense
Program: soil moisture-based irrigation controllers, ion-exchange water softeners, and bath and
shower diverters. Moreover, some state standards that go beyond the federal code by use of
WaterSense specifications have been in place for nearly a decade, highlighting the need to modernize
and update the WaterSense standards and list of appliances. The USEPA should follow suit and adopt
new national standards and eliminate the risk that 50 different state standards will once again
complicate the efforts of manufacturers to meet market demands.

Second, a primary benefit of high-efficiency appliances, such as toilets, is that they save homes and
businesses money on water and wastewater bills. Homeowners and business owners that update hot-
water using appliances, such as dishwashers or pre-rinse spray valves, receive the added benefit of
cost savings on energy bills. Indeed, many residential and non-residential measures have a "negative

654 13th Street, Preservation Park, Oakland, CA 94612
Phone: (510)251-1600 Email: info@pacinst.org Website: www.pacinst.org


-------
PACIFIC

INSTITUTE	Research for People and the Planet

cost," which means that they save the customer more money over their lifetime than they cost to
implement. As WaterSense has expanded to outdoor water-using devices such as irrigation
controllers, these products can help to save consumers from overwatering their landscape, improving
their landscape's health, reducing nuisance flooding, and contributing to reduced runoff into local
watersheds. USEPA should initiate an effort to quantify these savings nationwide, including both
water and energy savings, as well as additional "co-benefits," following methods such as those
described in the Pacific Institute's publication, Incorporating Multiple Benefits into Water Projects: A
Guide for Water Managers.1

Third, from a community perspective, our research has shown that urban water conservation and
efficiency measures are less expensive than most new water-supply options and are thus the most
cost-effective ways to meet current and future water needs.2 In California, for example, we found that
per unit of water, water conservation and efficiency measures were, in nearly all cases, the least
expensive alternative water supply option when compared to water reuse and recycling, stormwater
capture, and desalination. An additional benefit to communities that actively pursue water
conservation and efficiency is that it can, and already has in many places, reduced or removed the
need to access new water supply at all, saving ratepayers enormous amounts of money over the long
term.3

Finally, at the national level, water savings are measurable. Total water use in US households has
dropped 20% between 1990 and 2015 according to the US Geological Surveys regular five-year
assessment of US water use.4 On a per capita basis, domestic water use has dropped 40% over this
period. A final benefit of water efficiency products is that they contribute to individual as well as
community resilience to water supply shortages and disruptions, lessening the consequences of severe
droughts and increasing resilience to climate-change induced scarcity. The USEPA should evaluate
the role WaterSense programs play in enhancing water resilience for utilities. This work could be
integrated with the ongoing USEPA effort "Creating Resilient Water Utilities (CRWU)."

In closing, we would like to reiterate that water efficiency and water efficient products, such as those
credited by the USEPA's WaterSense Program, provide substantial, measurable benefits beyond

1 https://pacinst.org/publication/incorporating-multiple-benefits-into-water-proiects/

Cooley, H. and R Phurisamban. 2016. The Cost of Alternative Water Supply and Efficiency Options in California.
https://pacinst.org/publication/the-cost-of-alternative-water-supplv-and-efficiencv-options-in-california/. Also, Cooley, Heather,
Rapichan Phurisamban, and Peter Gleick. "The cost of alternative urban water supply and efficiency options in
California." Environmental Research Communications 1, no. 4 (2019): 042001.

For example, see Feinglas, Gray, and Mayer (2013) https://www.financingsustainablewater.org/resource-search/conservation-
helps-limit-rate-increases-colorado-utilitv

4 https://www.usgs.gov/mission-areas/water-resources/science/water-use-united-states7qt-science center obiects=0#qt-
science center objects

654 13th Street, Preservation Park, Oakland, CA 94612
Phone: (510)251-1600 Email: info@pacinst.org Website: www.pacinst.org


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PACIFIC 	

INSTITUTE	Research for People and the Planet

water savings to homeowners, businesses, and communities. These benefits save money and help to
ensure a secure and resilient future for all. We urge the USEPA to not only continue and fully fund
the WaterSense Program, but to strengthen it by measuring the co-benefits of the program beyond
water savings, continuing to improve device specifications, adding new water-using appliances and
devices to the program, and by supporting implementation and distribution of these products
nationwide.

Sincerely,

Morgan Shimabuku
Research Associate
Pacific Institute

Peter H. Gleick
President-emeritus
Pacific Institute

Member US National Academy of Sciences

654 13th Street, Preservation Park, Oakland, CA 94612
Phone: (510)251-1600 Email: info@pacinst.org Website: www.pacinst.org


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Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Anonymous
Affiliation: Anonymous
Comment Date: July 23, 2020
Document ID: EPA-HQ-OW-2020-0026-0087

Comment Text:

EPA's WaterSense program and specifications are cornerstone to increasing household
and commercial water use efficiency. WaterSense provides customers with assurance
that labeled products not only save at least 20% more water than standard counterparts,
but that they have been third-party verified to perform as well or better than standard
counterparts. As the Water Conservation Program Manager for a municipality in a water
supply limited community in the West experiencing high population growth, we rely on
WaterSense specifications to reduce city-wide water demand through our many rebate
and incentive programs that we offer to water customers. Wthout WaterSense products
and specifications, our utility would be forced to look for new costly water supplies
requiring expensive infrastructure upgrades sooner. We rely on WaterSense to support
our water demand management program and our customers value the performance of
WaterSense labeled products.

4

EPA

WaterSense

168

August 2020


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Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Anonymous
Affiliation: Pluvial Solutions
Comment Date: July 24, 2020
Document ID: EPA-HQ-OW-2020-0026-0088

Comment Text-

Docket ID No. EPA-HQ-OW-2020-0026

After working in the water conservation business for almost 15 years, I have seen how
fixtures have performed at these minimun requirements and better. The standards have
been met by most manufacturers and fixtures perform even better than they did 15 years
ago. The cost of these fixtures is the same or insignificant to what has been made for
years. Georgia passed these requirements in 2010 and implemented in 2012. Other
states have as well.

As you should know water is a limited resource and even it is managed properly we will
have issues. Many parts of the world do not have enough water or even safe driving
water. This can and has happen here. We have seen droughts and this has made us
increase standards. Standards should be increased as can when they can.

I have worked several jobs replacing out dated fixtures and we have installed fixtures to
these standards and better. As with all types of fixture water and energy more efficient is
better when it performs as well as the older ones.

See the attached Case Study showing a class A 1990 office building that used 1.28 gpf
toilets and .013 gpf (pint) urinals to upgrade its 3.5 gpf toilets and 1.0 gpf urinals.
Everyone was happy with no issues once installation was complete. Project was
completed in 2013

Attachment

See pages 170 through 171.

4

EPA

WaterSense

169

August 2020


-------
Bank of America Plaza

Atlanta, Georgia

As the tallest building in the Southeastern United States and the most
iconic property in Atlanta, Rank of America Plaza stands at the
pinnacle of the Atlanta .skyline and serves as the anchor between
Midtown and Downtown. In order to achieve LEED Silver certification
and reduce operating costs at the Bank or America Plaza, Water
Management, Inc. (WMI) was hired by Parkway Realty Sei-vices to
provide a comprehensive, innovate and sustainable water savings
program.

In Collaboration with Parkway Realty Services and LEED consultant
Nancy Larson of Sustainable Options, Water Management, Inc.
completed an investment grade water audit in late 2013. The results
of the audit showed that over five million gallons of water could be
cost effectively saved through rest room fixture upgrades. After
gaining ownership approval from CW Capital, Water Management
Inc. replaced i he old 3.5 gpf toilets and 1 gpf urinals with high-
efficiency TO TO toilets and Zuru 0.125 j»pf urinals. To date, a verified
indoor water savings of 57% has been realized.

s.oco.coo

7.UOOOOO
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PROJECT DETAILS

Client;



Parkway Realty Services

Project Cost
5275,310



Savings Per Yean
5161,379



Payback:
1,7 Years



Water Savings Per Yean
5,429,214 gallons

Verified Domestic Savings;
57%

LEED Water Efficiency Credits:
7 Points including Regional
Priority and Exemplary
Performance Credits

Steve Williams
pluvlalsolulionii^inalkom
404-234 1358






-------
Bank of America Plaza:

Atlanta Water Efficiency Program

PROJECT DETAILS
Client:

Parkway Realty Services

Project Cost:

$275,810

Savings Per Year:

$161,379

Payback:

1.7 years

Water Savings Per Year:
5,428,214 gallons

Verified Domestic Savings:

57%

¦	1 point for Regional Priority

¦	1 point for Exemplary Performance for exceeding 40%.

¦	7 points - Maximum Available

Reading Date

Reading Date

Domestic Gallons Savings

Savings

Average

9/30/11

9/27/13

921,732

61%



10/31/11

10/25/13

564,096

49%



11/30/11

11/29/13

759,520

67%



12/31/11

12/27/13

424,012

50%

57%



2,669,360



¦	Metro Atlanta Chamber of Commerce E-3 Award - Liquid Assets for the
Parkway Realty Services Bank of America Plaza - Atlanta 2014

¦	Atlanta Better Buildings Challenge Outstanding Water Project Award for
the Parkway Realty Services Bank of America Plaza - Atlanta 2014,
2015,2016

¦	USGBC LEED Silver v2009 - 2015

¦	EBIE Award USGBC -2016 Water Efficiency in Existing Buildings

¦	USGBC - GA Chrysalis Award - 2019

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¦ 5 points for achieving a 30% reduction


-------
WaterSense

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Gabe Maser, Vice President, Governmental Relations

Affiliation: International Code Council (ICC)

Comment Date: July 24, 2020

Document ID: EPA-HQ-OW-2020-0026-0089

Comment Text:
See attached file(s)
Attachment

See pages 173 through 175.

172

August 2020


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INTERNATIONAL
CODE COUNCIL"

International Code Council

500 New Jersey Avenue, NW
Sixth Floor

Washington, DC 20001
t: 888.ICC.SAFE (422.7233)
t: 202.370.1800
f: 202.783.2348

www.iccsafe.org

July 24, 2020

Environmental Protection Agency
1200 Pennsylvania Avenue, N.W.

Washington, DC 20460

Via regulations.gov

Re: Comments of the International Code Council in Response to the Environmental Protection
Agency's (EPA) Notice of Recent Specifications Review and Request for Information on the
WaterSense Program, Docket Number EPA-HQ-OW-2020-0026

The International Code Council (ICC) is nonprofit organization, driven by the engagement of its more
than 64,000 members, that is dedicated to helping communities and the building industry provide safe,
resilient, and sustainable construction through the development and use of model codes (l-Codes) and
standards used in design, construction, and compliance processes. Most U.S. states and communities,
federal agencies, and many global markets choose the l-Codes to set the standards for regulating
construction and major renovations, plumbing and sanitation, fire prevention, and energy conservation
in the built environment. The Code Council appreciates the opportunity to submit the following
comments in response to EPA's notice of recent specifications review and request for information (RFI)
in the above-named matter.

The l-Codes are widely utilized and supported at the federal, state, and local levels. All 50 states use the
International Building Code (IBC) as the basis for commercial and multifamily housing construction and
safety regulation. The IBC references the International Plumbing Code (IPC), which is adopted or in use
in 37 states. The International Residential Code (IRC) is adopted or in use in 49 states. The IRC addresses
all components, including plumbing, of a house or townhouse less than four stories tall. The IPC and IRC
incorporate all the minimum prescriptive regulations pertaining to plumbing system installations. This
includes water flow (and pressure) specifications along with faucet and fixture design, performance, and
operation criteria.

The 2018 International Green Construction Code (IgCC), a collaboration between the Code Council, the
American Society of Heating, Refrigerating and Air-Conditioning Engineers, and the U.S. Green Building
Council, establishes maximum plumbing fixture consumption rates consistent with WaterSense
specifications for water closets, urinals, residential lavatory sink faucets, and residential showerheads.
The IgCC is in use in 16 states and the District of Columbia. The Code Council also partners with the
American Society of Agricultural and Biological Engineers (ASABE) to publish the ASABE/ICC 802-2014
Landscape Irrigation Sprinkler and Emitter Standard, which ensures adequate safety and performance of
landscape irrigation systems, and which also establishes testing methods that EPA's WaterSense
program utilizes to quantify product performance for pressure-reducing sprinkler bodies. The General

1


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INTERNATIONAL
CODE COUNCIL"

International Code Council

500 New Jersey Avenue, NW
Sixth Floor

Washington, DC 20001
t: 888.ICC.SAFE (422.7233)
t: 202.370.1800
f: 202.783.2348

www.iccsafe.org

Services Administration (GSA) requires the IRC, IPC, and IgCC for all civilian governmental buildings1 and
the Department of Defense (DOD) requires the IRC and IPC for all U.S. military bases.2

ICC's Evaluation Services' (ICC-ES) licensed engineers conduct evaluations of products, components,
methods, and materials including a host of plumbing products. ICC-ES also certifies whether products
conform to required or voluntary standards. The evaluation process culminates with the issuance of
technical reports that manufacturers use to help determine code compliance and regulators use to
enforce building regulations. ICC-ES is a licensed WaterSense certifying body. In addition to ICC-ES's
services, ICC's International Accreditation Service (IAS) is an approved accreditation body under the
WaterSense program that EPA has authorized to provide accreditation services for WaterSense
certifying bodies.

The International Code Council (ICC) and ICC Evaluation Services (ICC-ES), applaud EPA for all it has done
to lead water savings efforts for more than a decade. The ICC Family of Solutions has, and always will,
support the EPA WaterSense program.

I. Customer Satisfaction and WaterSense

The Code Council supports the continued success of the WaterSense program and fully understands the
importance of end-user customer satisfaction. Therefore, it is our belief that EPA should look to the
WaterSense program's market outcomes to inform its understanding of customer satisfaction.

According to EPA data from 2019, since its inception in 2006, the WaterSense public-private partnership
has helped save a cumulative 4.4 trillion gallons of water and more than $87 billion in water and energy
bills.3 These accomplishments are all the more remarkable given the program was not formally
authorized until 2018, and has historically received limited federal investment. For example, in 2017,
EPA's Office of Inspector General found that consumers saved $1,100 for every federal dollar invested in
the program.4 The program's success is a striking indicator of customers' satisfaction with WaterSense
products.

EPA can have confidence in the performance of WaterSense products because, per the RFI "WaterSense
has included strong performance requirements in its specifications and used independent organizations
to certify that labelled products meet the EPA criteria." EPA ensures the performance of WaterSense
products through certifying bodies, like ICC-ES. In certifying that a product conforms to WaterSense's
product specifications, ICC-ES not only ensures the specification's water efficiency criteria are satisfied,
it also ensures that the specification's performance criteria are satisfied.

1	General Services Administration, Facilities Standards for Public Buildings Service ("GSA P-100") (July 2018).

2	Department of Defense, Unified Facilities Criteria, DoD Building Code (General Building Requirements) (Oct.
2019).

3	EPA, WaterSense Accomplishments 2019, (June 2020).

4	EPA, Office of Inspector General, EPA's Voluntary WaterSense Program Demonstrated Success, Report No. 17-P-
0352 (Aug. 1, 2017).

2


-------
INTERNATIONAL
CODE COUNCIL"

International Code Council

500 New Jersey Avenue, NW
Sixth Floor

Washington, DC 20001
t: 888.ICC.SAFE (422.7233)
t: 202.370.1800
f: 202.783.2348

www.iccsafe.org

WaterSense performance criteria rely on the same standards that base plumbing codes require for
products that do not carry the WaterSense label.5 For example, although WaterSense requires water
closets adhere to a maximum flush volume of 1.28 gallons versus 1.6 gallons for the IRC and IPC, both
the IPC/IRC and WaterSense require adherence to the same hydraulic performance requirements (ASME
A112.19.2/CSA B45.1).

EPA should continue to rely on the existing process for verifying product performance, which ensures
products meet defined metrics through independent testing and verification. Manufactures, at their
option, are best and most appropriately positioned to measure customer satisfaction.

II. WaterSense Specifications Review

The Code Council supports EPA's decision to retain current WaterSense specifications for water efficient
plumbing products. Although lower flow rates and water consumption values may be technically
feasible, additional research is necessary to ensure that doing so would not negatively impact the overall
plumbing system's integrity. Per a National Institute of Standards and Technology (NIST) technical note
released in May 2020, "[r]esearch is needed to address these gaps in support of water efficiency and
water quality goals to ensure the effectiveness of these systems today and in the future."6

The Code Council supports sustaining the current WaterSense specifications as written and published.

Thank you for the opportunity to provide comments. If you have any questions concerning ICC's
recommendations, please do not hesitate to contact me.

Sincerely,

Gabe Maser

Vice President, Government Relations
International Code Council
Office: 202-370-1800
Email: gmaserffiiccsafe.org

5	In the RFI, the Agency states its interest in "ensuring] that our performance criteria review is in fact ensuring that
labelled products are meeting the same standards as products on the market before the WaterSense label was
adopted." The question should not be whether WaterSense labeled products are meeting the same standards as
products on the market prior to 2006, the question should be whether WaterSense labeled products are meeting
the same standards as plumbing code-compliant products, that do not have WaterSense labels, today.

6	NIST, Measurement Science Research Needs for Premise Plumbing Systems, Technical Note 2088 (May 2020).

3


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Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Bruce Grimm
Affiliation: General Public
Comment Date: July 24, 2020
Document ID: EPA-HQ-OW-2020-0026-0090

Comment Text:

RE: Docket EPA-HQ-OW-20200026 FRN 2020-07602

The Environmental Protection Agency has administered the WaterSense program in
compliance with Public Law 115-270 Section 4306 of America's Water Infrastructure Act.
The program purports to transform the marketplace for products and services that use
water while promoting a nationwide ethic of water efficiency to conserve water resources
for future generations and proves a reasonable compliance towards relevant legislation
and regulations.

To gauge public acceptance of the WaterSense concept, surveys should target those
that feel that effects of using WaterSense certified products the most. Non-monetary
incentives must rely on the users guilt, health, knowledge, ease of use and community
motivations.

An effective series of survey should appeal to users self-interest. It should contain the
psychological principal of persuasion because people will perform actions such as taking
a survey if many other people have performed this action and it is known. This is always
a socially acceptable practice.

The characteristics outlined here should be considered in the design of future studies or
reviews regarding WaterSense product performance criteria.

Respectfully submitted,

Bruce Grimm, ARM

4

EPA

WaterSense

176

August 2020


-------
Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: N/A

Affiliation: Alliance for Water Efficiency (AWE) et al.

Comment Date: July 24, 2020

Document ID: EPA-HQ-OW-2020-0026-0091

Comment Text:

The Alliance for Water Efficiency submits the attached updated letter, signed by 62
organizations.

Attachment

See pages 178 through 189.

4

EPA

WaterSense

177

August 2020


-------
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July 24, 2020

Mr. Andrew Wheeler
Administrator

US Environmental Protection Agency
Washington, DC

RE: Comments on Docket ID No. EPA-HQ-OW-2020-0026
Request for Information on the WaterSense® Program

Dear Administrator Wheeler:

The Alliance for Water Efficiency (AWE) and the undersigned 62 organizations and businesses
write to express our strong support for the WaterSense program at the Environmental
Protection Agency (EPA) and to share with you our submitted comments regarding WaterSense.
We are filing these comments in response to the Notice of Recent Specifications Review and
Request for Information on the WaterSense Program published on April 10, 2020 in the Federal
Register. Our comments address the recent EPA review of the WaterSense program, the EPA's

1


-------
decision not to revise any of the WaterSense product specifications, and the specific questions
asked within the Federal Register Notice.

Our comments focus on four specific areas of the Request for Information (ROI) in the Federal
Register, the details of which are contained in the attached document. Our basic conclusions
are as follows:

1.	Since its inception in 2006, WaterSense has sought to base its product specifications on
measured values of performance that are tested in a laboratory and certified by a third-
party certifying organization.

2.	Fixture performance has improved since the advent of WaterSense.

3.	The Residential End Use Study results for toilet flushing, showering, and faucet use show
that over 15 years, as fixtures themselves have become more efficient, customer use of
these fixtures has not changed nor has flushing frequency increased.

4.	Customer satisfaction criteria do NOT belong in WaterSense product specifications
themselves, but there are reasonable uses for customer satisfaction information within
WaterSense.

5.	Including a vague, non-scientific concept such as customer satisfaction criteria could
introduce uncertainty and bias into what has until now been a fair and scientific process
for setting WaterSense specifications.

6.	Product-specific customer satisfaction research is best left to the marketplace and
manufacturers themselves.

7.	The scope of customer satisfaction research should be limited to consideration of the
WaterSense brand itself and WaterSense partnerships, like the type of customer
satisfaction research ENERGY STAR has conducted in the past.

8.	Proper uses of customer satisfaction survey results would inform the EPA about
Americans' opinion of the WaterSense brand and their experience with WaterSense
labeled products in homes and businesses. This information could help EPA guide the
direction of the WaterSense brand and program.

9.	While we offer no comments on the EPA's decision not to revise any specifications at
this time, we nonetheless believe that it is important that specifications move forward
and advance over time, based on adequate study and research. WaterSense product
specifications should keep up with changing times and technology.

The WaterSense program has been a tremendous success for EPA. Public and private utilities in
all 50 states tailor successful water conservation programs around consumer use of
WaterSense-labeled products. And because of the nexus between water and energy use, the
4.4 trillion of gallons of water saved by WaterSense since 2006 have resulted in 522.9 billion
kilowatt hours of energy that are not used to heat, pump and distribute water. These savings
have resulted in a financial benefit to consumers on an average of more than $380 annually and
$87 billion total in water, sewer, and energy bills since 2006.

2


-------
Thank you for doing your utmost to ensure this inexpensive, valuable, and effective program
that continues to deliver for the American people.

Sincerely,

The Alliance for Water

Efficiency

Chicago, IL

Alameda County Water

District

Fremont, CA

American Supply
Association
Itasca, IL

American Water
Camden, NJ

American Water Works
Association
Denver, CO

AMWUA
Phoenix, AZ

Amy Vickers & Associates
Amherst, MA

Bottom Line Utility
Solutions, Inc.

Laguna Hills, CA

C+C, Inc.

Seattle, WA

California Water Efficiency
Partnership
Sacramento, CA

City of Ashland
Ashland, OR

City of Bellingham
Bellingham, WA

City of Bend
Bend, OR

City of Big Bear Lake
Department of Water
Big Bear Lake, CA

City of Charlottesville
Charlottesville, VA

City of Durham
Durham, NC

City of Flagstaff
Flagstaff, AZ

City of Mesa
Mesa, AZ

City of Sacramento
Sacramento, CA

City of Westminster
Westminster, CO

Coachella Valley Water

District

Coachella, CA

Denver Water
Denver, CO

EcoSystems, LLC
Miami, FL

HI Commission on Water
Resource Management
Honolulu, HI

IAPMO
Dayton, NJ

Las Vegas Valley Water

District

Las Vegas, NV

Mesa Water,

Costa Mesa, CA

Metropolitan North GA
Water Planning District
Atlanta, GA

Metropolitan Water
District of Southern CA
Los Angeles, CA

Monte Vista Water District
Montclair, CA

Municipal Water District of
Orange County
Fountain Valley, CA

National Wildlife
Federation
Reston, VA

O'Cain Consulting
Santa Monica, CA

Peter Williams Solutions,
LLC

Danville, CA

3


-------
PHCC—National
Association
Falls Church, VA
Rancho Water
Temecula, CA

Regional Water Authority
Citrus Heights, CA

Santa Rosa Water
Santa Rosa, CA

Sacramento Suburban
Water District
Sacramento, CA

San Francisco Public
Utilities Commission
San Francisco, CA

Scottsdale Water
Scottsdale, AZ

SCV Water
Santa Clarita, CA

Sonoma-Marin Saving
Water Partnership
Santa Rosa, CA

Sonoma Water
Santa Rosa, CA

Soquel Creek Water

District

Soquel, CA

Southern Nevada Water

Authority

Las Vegas, NV

T&S Brass and Bronze
Works

Travelers Rest, SC
Tacoma Water
Tacoma, WA

Texas Water Foundation
Austin, TX

Turfgrass Water
Conservation Alliance
Albany, OR

Utah State University,
Center for Water Efficient
Landscaping
Logan, UT

United Association of
Plumbers and Pipefitters
of the U.S and Canada
Annapolis, MD

Upper San Gabriel Valley
Municipal Water District
Monrovia, CA

Utah Water Conservation
Forum

Salt Lake City, UT

Valley County Water
District

Baldwin Park, CA

Valley Water
San Jose, CA

Water - Use It Wisely
Mesa, AZ

Water Supply Citizens
Advisory Committee to
MWRA

Belchertown, MA

WaterDM
Boulder, CO

Waterless Co
Vista, CA

WaterNow Alliance
San Francisco, CA

Western Urban Water
Coalition
Washington, DC

4


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Detailed Comments

1. Should the EPA include customer satisfaction criteria in the WaterSense product
specifications and guidelines?

We believe that customer satisfaction criteria do not belong in WaterSense product
specifications themselves, but there are reasonable uses for customer satisfaction information
within WaterSense. Proper uses of customer satisfaction survey results would inform the EPA
about Americans' opinions of the WaterSense brand and their experience with WaterSense-
labeled products in homes and businesses. This information could help EPA guide the direction
of the WaterSense brand and program. However, it would not be reasonable or correct for EPA
to include customer satisfaction requirements within individual product specifications.

ENERGY STAR hired JD Power and Associates and others to conduct customer satisfaction
surveys about products that receive the ENERGY STAR label.1 All of these surveys were focused
on satisfaction with partnerships, utility programs, and the ENERGY STAR brand. These surveys
did not cover topics like the wattage of light bulbs, the duration of dishwasher cycles, or any
product-specific information. Recent JD Power research answered the question, "Does Energy
Star Partnership Increase Customer Satisfaction?"

Similarly, WaterSense could use customer satisfaction surveys conducted by independent
organizations to evaluate utility partnerships, brand recognition, and overall satisfaction with
WaterSense-labeled products. This information could help guide EPA to improve the
WaterSense program and could even provide insight and general direction for product
categories like toilets, urinals and smart irrigation controllers.

Customer satisfaction is a
comparatively vague concept that
cannot be measured in a laboratory in
the same way as flush volumes and
flow rates can. As shown in Figure 1,
customer satisfaction research
examines the nexus between
customer expectations, perceived
quality, and perceived value.

Customer satisfaction with a

Figure 1: Customer satisfaction research nexus. Source:
plumbing fixture depends greatly on the	https://asq.org/quality-resources/customer-satisfaction

https://www.energystar.gov/sites/default/files/asset/document/Schultz Energy%20Star%20Results JDPower 2R.
pdf

https://www.esource.com/svstem/files/files/corpcomm programs-brand.pdf

https://www4.eere.energv.gov/seeaction/svstem/files/documents/ratepaver efficiency customersatisfaction.pdf

Perceived
quality

Customer
complaints

Perceived
value

Customer
satisfaction

Customer
loyally

Customer
expectations,

5


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quality of manufacturing, the cost of the product, the customers' own expectations, the actual
installation of the fixture, the water pressure in the building, and the appearance of the fixture,
among other factors. These are all difficult to measure. Including customer satisfaction criteria
could introduce uncertainty and bias into what has until now been a fair and scientific process.

Since its inception in 2006, WaterSense has sought to base its product specifications on
measured values of performance that are tested in a laboratory and certified by an authorized
certification body. These measured values include the volume of water used to flush a toilet, or
the maximum flow rate of a showerhead or faucet aerator under specific pressure conditions.
These measured test values ensure that products that receive the WaterSense label are tested
and are thus capable of meeting established, measurable performance criteria under laboratory
conditions. This fundamental adherence to measured performance has provided a level playing
field for manufacturers who have produced WaterSense products since 2006. The playing field
is level because the measured requirement of each specification is understood by product
manufacturers.

Customer satisfaction research is best left to the marketplace and manufacturers themselves.
Product manufacturers conduct customer satisfaction research frequently and keep the results
to themselves so they can use it strategically to develop their products and brand to
competitive advantage. This is truly the proper use of and location for product-specific
customer satisfaction research, not with the EPA, but with product manufacturers.

The WaterSense approach of basing specifications on measured values of performance that are
tested and certified has had tremendous positive impact on the American economy. Americans
can choose from more than 34,000 available models of WaterSense-labeled products for
bathrooms, commercial kitchens and irrigation systems. The EPA has estimated that
WaterSense-labeled products have saved more than $87 billion on American families' water,
sewer, and energy bills. To date more than 2,000 manufacturers, retailers and distributors,
water and energy utilities, state and local government, non-profit and trade organizations,
irrigation training organizations, and home builders strengthen their businesses through
partnerships with WaterSense.

2. How should EPA design studies to inform future reviews that might incorporate customer
satisfaction considerations?

Measuring customer satisfaction is a complex task that requires statistical surveying and careful
research. It becomes particularly challenging when trying to understand customer satisfaction
with a product and to distinguish that from the brand and style and manufacturing of the
fixture, the installation of the fixture, the local water pressure, and other factors. The task of
measuring customer awareness of and satisfaction with the WaterSense brand as a whole
would be quite different than measuring customer satisfaction with specific WaterSense-
labeled plumbing fixtures such as toilets or showerheads.

6


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This is not the type of research that can or should be conducted by the EPA itself. To protect
WaterSense partners and the integrity of the WaterSense brand, the EPA should rely on the
services of professional independent researchers (like JD Power, Edmunds, or KBB) or who
specialize in this type of work.

Our recommendation is to limit the scope of customer satisfaction research to consideration of
the WaterSense brand itself and WaterSense partnerships, like the type of research ENERGY
STAR has conducted. This is much more likely to yield useful information to the EPA. If EPA
chooses to conduct customer satisfaction research into specific labeled product categories, it
must be designed and conducted by experts with knowledge of both customer satisfaction
survey methods and plumbing fixtures.

Superior products will gain market share and it is industry that knows best how to conduct
customer satisfaction research. Product category research has been conducted in the
marketplace by industry and product manufacturers and distributors who all want this
information to make popular products that customers want, to thus gain competitive
advantage and market share. Product-specific customer satisfaction research does not need to
be and should not be conducted with public funds. Industry may not wish to share the results of
the research they have privately conducted, but that is their prerogative. During the
WaterSense product specification and review process, information that industry deems
relevant can be introduced.

3. What information, data, surveys, and studies are available that to help assess customer
satisfaction with WaterSense-labeled products which could help inform future product
specification?

In 2002, four years before WaterSense was created, all toilets sold in the US were required to
comply with ASME Standard A112.19.2, which required testing with media comprised of plastic
"granules", nylon balls, sponges and kraft paper. In 2003, in response to water utilities'
concerns over the performance of toilets they rebated, engineers John Koeller and Bill Gauley
created Maximum Performance Testing (MaP Testing) and began bench-testing toilets using far
more realistic test media comprised of dense bean paste. MaP also began publishing testing
results on a regular basis so that water utilities could provide toilet fixture performance
information to their customers. Manufacturers voluntarily submitted their toilets for MaP
Testing so that they could be part of large rebate programs in California, Texas, Georgia, and
elsewhere.

By June 2006, when the WaterSense program was introduced, there were already about 500
different tank-type toilet models submitted for MaP Testing, the results of which were released
to the public. These toilets could remove an average of 420 grams each (see Figure 2 below).
As the WaterSense toilet specification for tank-type toilets was developed, many parties
recommended that MaP Testing (or similar testing using realistic test media) be incorporated
into the specification and, ultimately, the WaterSense tank-toilet minimum performance
specification was set at 350 grams of waste removal using the MaP approach.

7


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Avg. Grams of Waste Removed in a Single Flush
~Fixure Models Tested

> • Minimum Grams Removed to Achieve WaterSense

Figure 2: Fixture models tested and average grams of waste removed by tank-type toilets, 2003 - 2020

(Source: MaP Testing)

The WaterSense tank-type toilet specification was released in 2007, and since that time the
number of MaP-tested fixture models has gone from 500 to 3,390, and the average flushing
performance has improved from 500 grams of waste removed in a single flush to almost 900
grams. To be perfectly clear, 900 grams is nearly two (2) pounds of waste in a single flush,
which is over 7 times the median wet weight for daily fecal output by healthy individuals in high
income populations (128 grams) and 3.6 times the median wet weight for daily fecal output by
healthy individuals in low income populations (250 grams).2

The impact of MaP Testing in improving toilet performance has been so significant that it was
incorporated into the national product standard (ASME A112.19.2-2013/CSA B45.1-13) in 2013.
Figure 2 shows the progression of fixtures tested and the improvement in average flushing
performance since the advent of MaP Testing and WaterSense.

American consumers have expressed a high level of satisfaction with WaterSense-labeled
products that have been tested through this and other processes. Customers of the Home

2 The Characterization of Feces and Urine: A Review of the Literature to Inform Advanced Treatment Technology,
C. Rose, a A. Parker, a , * B. Jefferson, a and E. Cartmell a - 2015

https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4500995/

8


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Depot were so satisfied with WaterSense products that the company chose to sell WaterSense-
labeled products exclusively in all of their stores. At competitor Lowe's, the overwhelming
majority of eligible product offered for sale carry the WaterSense label. If there were a problem
with customer satisfaction, these retail giants would know it and would offer something
different. Home Depot and Lowe's both know that the products carrying the WaterSense label
perform better than the competition that is not subject to rigorous performance testing.

WaterSense has operated on a very modest budget since 2006, but nonetheless has become
remarkably successful and popular. WaterSense manufacturer partners have produced over
4,200 different WaterSense-labeled tank-type toilet models; 9,300 models of WaterSense-
labeled showerheads; and 18,000 WaterSense-labeled lavatory faucet and accessory models3.
American consumers have voiced their satisfaction with their purchases. Industry agrees, and
more than 2,000 manufacturers, retailers and distributors, water and energy utilities, state and
local government, non-profit and trade organizations, irrigation training organizations, and
home builders strengthen their businesses through partnerships with WaterSense.

Based on this success, the popularity of WaterSense is expected to grow. Research from
Plumbing Manufacturers International found that within the next 15 years, most bathroom sink
faucets and showerheads installed in the United States will be WaterSense-certified or meet
the requirements of the WaterSense program. Within the next 30 years, most residential tank-
type toilets will also be WaterSense-certified or meet the requirements of the WaterSense
program. Within the next 40 years, most flushometer-valve toilets and flushing urinals will be
WaterSense-certified or meet the requirements of the WaterSense program.4

While not addressing customer satisfaction or WaterSense products directly, the 1999 and 2016
Residential End Uses of Water Studies5 measured how people use water at home in their daily
lives. The studies reveal how frequently people use toilets, faucets, and clothes washers, and to
what extent those behaviors have changed over time. This information can be a strong
indicator of customer satisfaction. These paired residential end use studies offer the best
available measurements of key metrics such as the frequency of toilet flushing, the duration of
shower and faucet usage, and the flow rate of these fixtures. This information provides valuable
insight about water use patterns and indicates if people are using fixtures the same or more
frequently as the flow rates and flush volumes of the fixtures have changed.

The results for toilet flushing, showering, and faucet use show that over 15 years, fixtures
themselves have become more efficient, but the use of these fixtures has not changed. The

average volume of water used to flush a toilet has decreased, but the average number of

3	Federal Register. April 10, 2020. EPA-HQ-OW-2020-0026 - Request for Information on the WaterSense Program.
Vol. 85, No. 70.

4	IBID

5	DeOreo, W.B., P. Mayer, J. Kiefer, and B. Dziegielewski. 2016. Residential End Uses of Water, Version 2. Water
Research Foundation. Denver, CO.

Mayer, P., W. DeOreo, J. Kiefer, E. Opitz, B. Dziegielewski, and J.O. Nelson. 1999. Residential End Uses of Water.
Water Research Foundation, Denver, CO.

9


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flushes per person per day has stayed the same. The average number of minutes spent in the
shower has likewise stayed the same. The average faucet use per person per day has also
stayed the same. Subsequent analysis on shower patterns using the same Residential End Uses
of Water data sets found "on average, people do not compensate for lower flow rates by
increasing the duration of their shower and that lower flow rate showerheads do, on average,
result in a lower overall shower volume".6

WaterSense has also driven performance improvement for showerheads. ASME industry
standards for showerheads have been made more rigorous directly as a result of WaterSense
with the addition of spray force and spray coverage test requirements taken directly from the
WaterSense specifications.

Under section "V. Request for Information on Consumer Satisfaction" of the April 10 Federal
Register Notice it states the following (emphasis added):

"Understanding consumer satisfaction is important to the EPA as the Agency seeks to
ensure that our performance criteria review is in fact ensuring that labeled products are
meeting the same standards as products on the market before the WaterSense label was
adopted."

This statement is problematic for several reasons. First, the statement correctly states that
products that achieve the WaterSense label are meeting different standards than products that
do not receive the label. Both then and now, all plumbing products and fixtures must meet the
same set of basic national product standards established by ASME/CSA A112.19.2-2013/CSA
B45.1-13 for fixtures and ASME A112.18.1-2018/ CSA B125.1-18 for fittings. Since 2013,
however, the requirements contained within the WaterSense specifications for plumbing
products have been incorporated into the relevant ASME/CSA standards. As a result,
certification to the national product standard can also result in certification to the WaterSense
specification if the manufacturer so desires.

Appendix A shows the current standards that all tank-type toilets must meet in 2020 along with
a history of these specifications since 2003.

Second, the statement wrongly implies that customer satisfaction for plumbing fixtures was
higher before 2006 when the WaterSense label was adopted and that products met a different
standard back then. The tremendous success and popularity of WaterSense-labeled products
(described above) is due in large part because WaterSense specifications include measurable
performance requirements that result in products that work better for consumers than the
products they had before. Achieving the WaterSense label requires that products be tested to
a higher standard, and this statement wrongly implies that these don't meet the same

6 Gauley, B. and J. Koeller. 2017. How Showerhead Flow Rates Impact Shower Duration and Volume, www.map-
testing.com

10


-------
minimum basic standards as other fixtures. The confusion evident in this statement in the
Federal Register should be corrected.

4. Comments on EPA's recent review of the WaterSense program.

The April 10 Federal Register Notice also included a summary of the review of WaterSense
product performance criteria, conducted as required under the authorizing legislation under
the America's Water Infrastructure Act (AWIA) of 2018. Based on this review, the EPA made the
decision not to revise any specifications.

While we offer no comments on the EPA's decision not to revise any specifications at this time,
we nonetheless believe that it is important that specifications move forward and advance over
time, based on adequate study and research. WaterSense product specifications should keep
up with changing times and technology.

11


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Appendix A - History of Tank-Type Toilet Standards 2003 - 2013

ASME/CSA National Product Standard - Water Closets (toilets) - 2003 to today

0'

McP

Maximum Performance





Current Standard



2013 Standard



2008 Standard



2003 Standard



ASME A112.19.2-2018/CSA B45.1-
18

ASME A112.19.2-2013/CSA B45.1-
13

ASME All2.19.2-2008/CSA B45.1-
08

ASME A112.19.2-2003



Pro-
cedure

Requirements

Pro-
cedure

Requirements

Pro-
cedure

Requirements

Pro-
cedur

(3

Requirements

Water consumption

7.3

Maximum flush volumes:
Low consumption models: 1.6 gal
High-Efficiency models: 1.28 gal
Dual-flush models-full flush*: 1.6

7.4

Maximum flush volumes:
Low consumption models: 1.6 gal
High-Efficiency models: 1.28 gal

7.4

Maximum flush volumes:
Water-saving models - 3.5 gpf
Low-consumption models: 1.6 gal
High-Efficiency models: 1.28 gal

8.4

Two thresholds for maximum flush
vol.: Water-saving water closets - 3.5

gpf

Low-consumption water closets - 1.6

Granule and ball test

7.5

2500 granules in bowl - not more
than 125 granules visible after
flush. 100 Nylon balls (0.25 in.
diameter) in bowl - not more than 5
balls visible after flush

7.5

2500 granules in bowl - not more
than 125 granules visible after flush.
100 Nylon balls (0.25 in. diameter)
in bowl - not more than 5 balls
visible after flush

7.5

2500 granules in bowl - not more
than 125 granules visible after
flush. 100 Nylon balls (0.25 in.
diameter) in bowl - not more than 5
balls visible after flush

8.5

2500 granules in bowl - not more
than 125 granules visible after flush.
100 Nylon balls (0.25 in. diameter) in
bowl - not more than 5 balls visible
after flush

Surface wash test
(ink line test)

7.6

Ink line around interior
circumference of bowl 1 inch below
rim - after flushing, remaining line
= 2-inch maximum; no segment
more than 0.5 inch

7.6

Ink line around interior
circumference of bowl 1 inch below
rim - after flushing, remaining line =
2-inch maximum; no segment more
than 0.5 inch

7.6

Ink line around interior
circumference of bowl 1 inch below
rim - after flushing, remaining line
= 2-inch maximum; no segment
more than 0.5 inch

8.6

Ink line around interior circumference
of bowl 1 inch below rim - after
flushing, remaining line = 2-inch
maximum; no segment more than 0.5
inch

Mixed media test

TEST DELETED IN 2018 >>>>

7.7

20 sponges and 8 kraft paper balls
(15 lb. paper) in bowl. After
flushing, at least 22 sponges/paper
balls fully discharged

7.7

20 sponges and 8 kraft paper balls
(15 lb. paper) in bowl. After
flushing, at least 22 sponges/paper
balls fully discharged

8.7

20 sponges and 8 kraft paper balls (15
lb. paper) in bowl. After flushing, at
least 22 sponges/paper balls fully
discharged

Drainline transport

7.7

100 polypropylene balls (0.75-in.
diameter) in bowl. After flushing,
average distance traveled in plastic
drainline at least 40 ft.

7.8

100 polypropylene balls (0.75-in.
diameter) in bowl. After flushing,
average distance traveled in plastic
drainline at least 40 ft.

7.8

100 polypropylene balls (0.75-in.
diameter) in bowl. After flushing,
average distance traveled in plastic
drainline at least 40 ft.

8.8

100 polypropylene balls (0.75-in.
diameter) in bowl. After flushing,
average distance traveled in plastic
drainline at least 40 ft.

Waste extraction
test (MaP test
orocedure^

7.9

350 gram minimum waste extration

7.10

350 gram minimum waste extration









Consistent water
level test (non-pilot-
type fill valves only)

7.10

Maintain tank water level at ± 0.5
inches

7.11

Maintain tank water level at ± 0.5
inches









Fill valve shutoff
integrity test with
increased water
pressure (non-pilot-
type fill valves only)

7.11

Maintain tank water level at ± 0.5
inches at 20 to 80 psi

7.12

Maintain tank water level at ± 0.5
inches at 20 to 80 psi

<<<<< REQUIREMENTS ADDED IN 2013

Adjustability test for
tank-type gravity-
fed toilets

7.12

Single-flush maximum = 1.68 gal
Dual-flush maximum = 2.0 gal (full)
and 1.4 gal (reduced)

7.13

Single-flush maximum = 1.68 gal
Dual-flush maximum = 2.0 gal (full)
and 1.4 gal (reduced)









*-Maximum flush volume of 1.1 gal for the reduced flush is specificed in ASME A112.19.14-2013_R2018, section 3.2.2

12


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EPA

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

WaterSense

Commenter: Brett Little
Affiliation: GreenHome Institute
Comment Date: July 24, 2020
Document ID: EPA-HQ-OW-2020-0026-0092

Comment Text:

The WaterSense program is a very helpful program that allows people to easily
understand water conservation on new products and landscape installs. This help's them
easily save water and money without sacrificing function, comfort, or landscape design
beauty Please keep the program going to help keep American's water use down and
save money for Americans. This all helps keep our construction and remodeling industry
more innovative and competitive. Thank you.

190

August 2020


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WaterSense

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Jaclyn S. Toole, Assistant Vice President, Sustainability & Green Building

Affiliation: National Association of Home Builders (NAHB)

Comment Date: July 24, 2020

Document ID: EPA-HQ-OW-2020-0026-0093

Comment Text:
See attached file(s)
Attachment

See pages 192 through 212.

191

August 2020


-------
NAHB.

National Association
of Home Builders

July 24, 2020

Sustainability & Green Building
Jaclyn S. Toole
Assistant Vice President
jtoole@nahb.org

Mr. Andrew Wheeler
Administrator

U.S. Environmental Protection Agency
1200 Pennsylvania Avenue NW
Washington, DC 20460

(Submitted electronically to https://www.regulations.gov/ )

Re: Comments on Docket ID No. EPA-HQ-OW-2020-0026

Dear Administrator Wheeler,

On behalf of more than 140,000 members, the National Association of Home Builders (NAHB) submits these
comments to the U.S. Environmental Protection Agency (EPA) on the 'Notice of Recent Specifications Review
and Request for Information on WaterSense Program', published in the Federal Register, Vol. 85, No. 70, on
April 10, 20201.

The EPA has announced the completion of the review of WaterSense product performance criteria as
required under the America's Water Infrastructure Act (AWIA) of 2018. The AWIA required the EPA to
consider for review and revision, if necessary, specifications which were released prior to 2012. The EPA has
completed its review of the five product types released prior to 2012 (flush toilets, lavatory faucets,
showerheads, flush urinals, and weather-based irrigation controllers) and made the decision not to revise
any specifications.

Additionally, the Notice announced that the EPA is seeking input and requesting information on the
following:

1)	Information on any data, surveys, or studies that have assessed consumer satisfaction with
WaterSense labeled or standard products;

2)	Input on how it [EPA] could design a study or studies for use in future reviews that incorporate
customer considerations;

3)	Input on the collection method, frequency, and source of the information as EPA seeks to balance
any burden the collection would impose on the public with the usefulness the information would
provide the Agency; and

4)	Input on whether there are specific consumer satisfaction considerations, test methods, or
additional criteria it should consider adding to the WaterSense Labeled Products guidelines.

1 httDs://www.federalregister.gov/documents/2020/04/10/2020-07602/notice-of-recent-SDecifications-review-and-reauest-for-information-on-

watersense-proeram


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Mr. Ross

U.S. Environmental Protection Agency
July 24, 2020
Page 2

NAHB is a Washington, D.C. based trade association that works to ensure housing is a national priority and
that all Americans have access to safe, decent and affordable housing. The federation includes more than
700 state and local associations in all fifty states, the District of Columbia, and Puerto Rico. NAHB's members
are involved in home building, remodeling, multifamily construction, land development, property
management and light commercial construction. Collectively, NAHB's members construct about 80 percent
of all new housing units constructed within the United States each year.

NAHB promotes sustainable and green home building, including water efficient strategies, through the
implementation of voluntary, above-code practices, such as certification to the National Green Building
Standard (NGBS). WaterSense is a voluntary partnership program sponsored by the EPA which was initially
launched in 2006 as an initiative to educate American consumers on making smart water choices that save
money and maintain high performance standards. The WaterSense label makes it easier for building
professionals and consumers to identify water-efficient products, new homes, and programs that meet the
EPA's criteria for efficiency and performance. Builders have confidence when choosing WaterSense labeled
products because they have been independently tested and certified to provide water savings and meet
established performance criteria. Thousands of products have earned the WaterSense label, providing
builders with flexibility in product selection if they are designing and constructing for water efficiency. It is
important that builders have choices so they can best meet the needs of their client, the project, and
certification programs while also having the confidence that those choices maintain a consistent level of
rigor, provide quality output and are cost-effective.

NAHB applauds EPA for conducting a comprehensive specification review that considers factors such as
market penetration, adoption in local regulations, performance, potential public health concerns, cost-
effectiveness, and available customer satisfaction information. NAHB is providing the following comments in
response to EPA's request for input and information:

NAHB Input and Information per EPA Request

EPA Request #1: Data, surveys, or studies that have assessed consumer satisfaction with
WaterSense labeled or standard products

NAHB regularly conducts surveys targeting both consumers and builders to assess market trends and
perceptions in residential building. Overall trends from NAHB surveys conducted over the past few decades
indicate that water efficiency has become increasingly important to homeowners, confirming that
consumers value savings achieved through practicing conservation and using efficient fixtures.

Although consumer satisfaction with WaterSense labeled products has not been a direct ask of either
consumers or builders, several survey topics like product attributes and preference, indirectly provide
insight into general satisfaction with WaterSense labeled products and the WaterSense program as a whole.
Applicable information from relevant surveys is presented below.

I. NAHB/Wells Fargo HMI Survey - Water Efficient Fixtures - January 2020

For more than 25 years, the National Association of Home Builders (NAHB) has conducted a monthly
survey of its builder members that is used to generate the NAHB/Wells Fargo Housing Market Index
(HMI). The main section of the HMI survey asks builders to rate market conditions for the sale of


-------
Mr. Ross

U.S. Environmental Protection Agency
July 24, 2020
Page 3

new homes at the present time and expected over the next 6 months, as well as the traffic of
prospective buyers. The results are combined into a single composite index that measures the
overall strength of the market for new single-family housing. In addition to the questions that
provide the data needed to compute the HMI, the survey often also includes a set of targeted
questions on a topic of current interest to the housing industry. The January 2020 survey included
questions relating to installing plumbing products that are more efficient than federal standards in
homes built during the past year. The results are based on 301 responses to these targeted
questions. The results are summarized graphically in this section; detailed data tables are contained
in Attachment 1.

Builders were asked "Did you install any plumbing products more efficient than the federal standard
in homes you built in the past year?" As seen in the bar chart on the left, one-third of the
respondents installed toilets, showerheads and bathroom faucets more efficient than the federal
standard. The next question was "Were the above-standard plumbing products installed
WaterSense labeled?" As seen in the bar chart on the right, builders responded that approximately
60% of those above-standard plumbing products were WaterSense labeled, showing both use of the
products and WaterSense brand recognition by builders.

J No
¦ Yes

Toilets
{FS= 1.6 GPF)

Showerheads
{FS = 2^ GPM)

Bathroom faucets
(FS= 22 GPM)

Showerheads Bathroom faucets

Use of the above-standard plumbing products were most prevalent in the West, followed by the
South and Northeast with the Midwest having a somewhat lower implementation rate.

Toilets	Showerheads	Bathroom faucets

¦ Northeast ¦ Midwest ¦ South uWest


-------
Mr. Ross

U.S. Environmental Protection Agency
July 24, 2020
Page 4

The following three bar charts show the distribution of the flush and flow rates of the above-
standard plumbing products installed in 2019 by the respondents.

80% of the above-standard toilets were 1.28 gallon per flush (gpf), with 15% 1.00 gpf and only 5%
less than 1.00 gpf. WaterSense labeled toilets have a maximum flush rate of 1.28 gpf.

Toilets

1.28 GPF	80%

1.00 GPF	15%

Less than 1.00 GPF | 5%

~
I

About half of the above-standard bathroom faucets were 1.5 gallon per minute, with one-third at
1.2 gpm and only 8% at 1.0 gpm. WaterSense labeled lavatory faucets have a maximum flow rate of
1.5 gpm.

Bathroom Faucets

Half of the above-standard showerheads were 2.0 gpm with about one-third 1.8 gpm and 15% less
than 1.8 gpm. WaterSense labeled showerheads have a maximum flow rate of 2.0 gpm.

Showerheads

2.0 GPM

49%

1.8 GPM

36%

Less than 1.8 GPM

15%


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Mr. Ross

U.S. Environmental Protection Agency
July 24, 2020
Page 5

II.	SmartMarket Brief- Green Single Family and Multifamily Homes 20202

The National Association of Home Builders, teamed with Dodge Data and Analytics, have been
surveying home builders since 2006. The latest survey was conducted in 2019; builders and
remodelers of both single-family and multifamily homes were asked about their perceptions on
several aspects of the green building industry, including their use of water-conserving plumbing
fixtures and faucets (they were not asked specifically if the products were WaterSense certified).
72% of all respondents reported using these products on at least half of their projects, regardless of
if they identified themselves as being green builders, indicating water-conserving products are
widely used in residential construction.

III.	What Home Buyers Really Want, 2019 Edition3

Conducted by NAHB, the What Home Buyers Really Want survey, with over 4,000 respondents, asks
recent and prospective home buyers a wide range of questions regarding their home preferences to
identify what consumer want in a home. The water fixture related responses are summarized here;
the applicable data tables from the study are contained in Attachment 1.

Respondents were asked about their awareness of green certification programs for homes.

Between 10% and 24% of respondents were aware of programs that include water efficiency as part
of the certification and 21% were aware of the WaterSense program by name. Consumer program
brand recognition infers a level of familiarity with these programs, which can contribute to market
demand.

Figure 3-5.

Buyers Who Are Aware of Green Certification Programs for Homes

(Percent of Respondents)

ENERGY STAR

| 81%

IEED for Homes

" 24%

HERS (Home Energy Rating System)

22%

WoterSense

21%

NGBS (National Green Building Standard)

15%

Indoor AirPLUS

14%

2ERH (Zero Energv Ready Homes)

13%

Green Globes

11%

Lfwlng Building Challenge

10%

PHIU5 (Passive House institute US)

8%

2 https://www.nahb.org/Advocacv/lndustrv-lssues/Sustainabilitv-and-Green-Building/Green-Sinartmarket-Reports

3 "What Home Buyers Really Want, 2019 Edition", NAHB tconomics and Housing Policy Group.


-------
Mr. Ross

U.S. Environmental Protection Agency
July 24, 2020
Page 6

Figure 8-6 from the survey shows 68% of respondents were willing to pay at least $100 and 45% of
respondents were willing to pay $1,000 or more for a green certification showing their home met an
above-code standard for water efficiency. Figure 8-7 shows the median amount respondents were
willing to pay was $500, while the average was $1900.

Figure 8-6. How Much Buyers Are Willing to Pay for Green Certifications

(Pef cent of Respondents)

Certification (hat the home meets an
above-code standard for energy
efficiency

Cfrtificatlonthot (ho home meet* an
-above-code startdard fur water
efficiency

Certllication that the Home meets an

above-cade standard lor Indciai
environmental quality

Comprehensive, holistic green
standard (hat encompasses all of the
above fjlui general efficient ose of
resources and environmentally
friendly lot design

27%

11$

U7

32%

2t

M



32%

13% 1

LOWf,

32%

iawi



36%



Lot

29%

li*.



36%

4.1%

8%

25%

20%

¦ than $100 ¦ $100 !o $499 «$500 to $999 $1,000 to $4,999 ¦ $5,000 or more

Figure 8-7. How Much Buyers Are Willing to Pay for Green Certifications

(Average and Median)

Certification that ihe home meets an
abuve-tocfe standard for energy
efficiency

Certification th«t ttie home meets an
above-tcde standard for w,rier efficiency

$2,625.

$1,000

$1,300

I Average
Median

$503

Certification that the ticvme meei? an
above-code starnlard tor indogr
ynvirortrrientdl qualily

Comprehensive, holistic gruen st«n:larU
that encompasses all of the above alus
general efficient use of resources and
environmentally friendly lot design

$1,87G

$503

$2,972

$501


-------
Mr. Ross

U.S. Environmental Protection Agency
July 24, 2020
Page 7

The survey also captured preferences for many types of green features using a four-tier scale
(essential/must have, desirable, indifferent, or "Do Not Want"). The categories are defined in terms
of how they influence the home buyer's purchase decision, and while not a direct question, it could
be reasonable to infer that the essential/must have and desirable features reflect consumer
satisfaction. The top 26 green features rated 'essential' or 'desirable' are shown in Figure 8-8.
Water-conserving toilets (flush volume < federal standards) ranked 7th with 19% of respondents
saying they are essential and 44% stating they are a desirable feature. Reduced flow bathroom
faucets ranked 17th with 14% saying they are essential features in a home and 36% listing them as
desirable. Reduced flow showerheads followed at 18th, with 14% saying they are essential features
in a home and 35% listing them as desirable. Consumer preference on reduced flow showerheads is
quite divided however - 23% of respondents rated them as a 'do not want' feature (only 11% did not
want water-conserving toilets and 16% did not want reduced flow bathroom faucets.) A detailed
breakdown of results is located in the Q32 table in Attachment 1.

figure s-a Green Features Rated Essential or Desirable

(Percent o\ Reap&noerris j

• 1	hw ¦ tteilrp

ENEFG* STAR nfeCd h.irKfcwt
INEFG* STAR fated *p*antK
ENEFliL'f STAR i a-'mih far harm

li,«hhn* ||»«.% 11»"!IUn li^ulllKrVil linfc--|

fnp|p-?nnF r-jnihfrrig; (*«>. wnpw*
i^ijiaruin (NfttiBr r-quhiH try-cods
WJttr ciKdBm^a K»4K5 tfllsli *Mimr	starwariKl

LjuW SUlJtrllfc *1*^ MrlTCteWi

Valar wvfUr hiMHnx/Btoclric

Whote Ivmi" reecfunkjl YWfclatfcsn
Lpw VCt msfcerrafc Ipjlnt itoarnt

E £-£Fi £r*JL air UbiftCi

"•Wl |Tbic*" ||3'IM |p!L--dL#i4S r, MirfJ'	< £. <. u6riuit"fcj|

Kitiuind flnui tMlhrcxjm imai'tv
ILdt^i ihrrpc vw
GenttwfTml hwtlrn/coDinj
CDn^pancrcs biiit from sustanafcty hnveKtc umber
Cwi&QM&a made 'rem total v araducfto mjur^ts

U** fetal |Aiyiun ii tpliHt! ir-'iilLiliiii1 fi jv-
Hiirnr r timqcri*rrts ->ii:ir til r Brutal imUnnh

|Urnyfe/rtrti*m -rc4 rpmwirre* ior It®*fcHetJU

Bflcf mean ted. electrlciLv fenfTiwu-f wd luittne
Frehdb'icaEw upradncpfes I,will pjncb-.iruiSiii..prL|
paiHadp or .j r^Ksiv Liimi'rwd by plants


-------
Mr. Ross

U.S. Environmental Protection Agency
July 24, 2020
Page 8

IV.	Single-Family Green Practices Survey - 20174

The 2017 Green Practices Survey was conducted by NAHB to gather information on sustainable and
high performance building practices being used in single-family home building in 2016. Survey
questions were created to capture which green construction methods and strategies were
incorporated as standard practice in a typical home built that year.

Builders were asked to select the irrigation practices applied in their typical home build from a list of
options. Of the 233 responses, 36.5% of builders reported using an irrigation system controlled by
an irrigation controller. While not a direct measure of customer satisfaction, this result does
illustrate the level of customer demand for this type of product.

Builders were also asked about the types of flush and flow fixtures they installed in their typical
homes. Many are using water-conserving products that meet or are even more efficient than the
WaterSense certification thresholds. 230 responses were obtained regarding installed showerhead
flow rates ; 57.8% reported flow rates of 1.6-1.9 gpm and 23% reported flow rates of less than 1.6
gpm. 222 responses were obtained regarding bathroom faucets; 68.9% were 1.5 gpm or less. 228
responses were obtained for toilet installations - only 17.1% reported typically installing toilets with
> 1.28 gpf rate. 47.8% reported using 1.21-1.28 gpf toilets with the rest installing toilets with < 1.2
gpf. The WaterSense Labeled Products program provides value to builders by enabling them to
easily identify and select water-saving products that have been certified to performance standards.

V.	Residential Ends Uses of Water, Version 2 - 2016

An NAHB analysis of this study5 showed that in homes built since 1999, 71% have toilets with flow
rates of < 1.6 gpf, and 51% of those are < 1.28 gpf (the maximum allowable flush rate for
WaterSense labeled toilets). These percentages are higher than for homes built earlier, showing that
high-efficiency fixtures, including WaterSense labeled products, are accepted by and popular with
consumers and that the voluntary WaterSense Labeled Products program is influencing the
residential industry's use of water efficiency strategies.

4 https://www. nahb.org/Advocacv/lndustrv-lssues/Sustainabilitv-and-Green-Building/Green-Practices-Survev

5 Paul Emrath. "Residential Water Use." www.HousingEconomics.com. October 2017, NAHB.


-------
Mr. Ross

U.S. Environmental Protection Agency
July 24, 2020
Page 9

Figure 8. Efficient Share of Water Using Features in
Single-family Homes by Year Built

¦	ENERGY STAR clothes washer ¦ < 1.6 gat toilets

¦	$ 1.28 gal toilets

Before 1950 1950s 1960s 1970s 1980s 1990s After 1999

NAHB tabulation of data from Residential End Uses of Water, Version 2. Water Research Foundation.

EPA Request #2: Input on designing a study or studies for use in future reviews that incorporate
customer considerations and on the collection method, frequency, and source of the information
as EPA seeks to balance any burden the collection would impose on the public with the
usefulness the information would provide the Agency

It is important to note that the following NAHB response to EPA Request #2 includes suggestions for the
Agency to consider should they decide to move forward with collecting customer satisfaction data. Products
receiving a WaterSense certification verifying the water efficiency and performance of the product compete
on the open market with non-certified high-efficient products and products meeting the minimum Federal
standards. Market forces, including builder confidence and customer satisfaction, determine sales and
continued production of the preferred products.

If data is to be collected, a study with a relatively small sample of a few thousand without a complex
stratification scheme could provide information on customer consideration at a regional or national level.
One option to field a survey effectively to obtain this information would be to sponsor the Census Bureau to
conduct it, taking advantage of its trained field operatives and established procedures for sampling,
following up, etc.

A complication in collecting information from a broad sample of consumers is that most consumers know
nothing about flow rates of their plumbing fixtures, or about the details of WaterSense labeled products.
However, surveys targeting consumers confirmed to have WaterSense labeled fixtures in their homes may
be a more reliable option to obtain information about customer satisfaction with WaterSense labeled water
efficient features.

A survey could be provided to homeowners purchasing WaterSense Labeled Homes and/or homes that
achieve a water efficiency certification through the administrators of programs such as HERSH20 or WERS,


-------
Mr. Ross

U.S. Environmental Protection Agency
July 24, 2020
Page 10

and/or the administrator of a whole home certification program such as the ICC 700 National Green Building
Standard®. (The verifier/rater for the applicable program could easily confirm the presence of WaterSense
labeled products.) These homebuyers could be given the opportunity to opt in to a short reoccurring survey
that could be conducted annually or semi-annually over a predetermined period of time to measure their
satisfaction with WaterSense labeled products.

Conclusion

NAHB supports voluntary, above-code options that encourage water-efficient construction practices in new
and existing single-family, multifamily and remodeled homes. WaterSense labeled products provide
builders defined guidelines and performance assurance when choosing water fixtures for their projects,
increasing the likelihood that their customers will be satisfied with the operation of the fixtures.

NAHB has provided input and information in this comment letter from internal surveys conducted by NAHB
over the past few years as well as an analysis by NAHB's economics team of an external study. NAHB has
also provided general comments on potential survey ideas as requested by EPA.

NAHB appreciates the opportunity to provide input and information in response to the 'Notice of Recent
Specifications Review and Request for Information on WaterSense Program'. Our members support the
continued availability of WaterSense labeled products, providing water-efficient choices that perform as
well or better than standard products, and their use in voluntary, above-code programs including the
National Green Building Standard and the WaterSense Labeled Homes programs. NAHB supports the
continued evolution of both the voluntary WaterSense Labeled Products and WaterSense Labeled Homes
programs to continue providing avenues for our members to demonstrate their achievements in high
performance building, while also setting themselves apart in their local market.

Please contact my colleague Michelle Dusseau Diller, at (202)266-8375 or mdiller@nahb.org if you have any
questions regarding this letter. NAHB looks forward to future opportunities to engage with the EPA and
WaterSense.

Sincerely,

Jaclyn S. Toole, Assoc. AIA, CGP

Assistant Vice President, Sustainability & Green Building


-------
Attachment 1 - Data tables from January 2020 HMI Survey

Q5a. Of the plumbing products listed below, did you install any that were more efficient than the federal

standard in homes you built during the past year?

(Percent of Respondents)



Total

Region

Total No. of Units Started in 2019



NE

MW

S

W

5 or Fewer

6 to 24

25 to 99

100+

Toilets (federal standard = 1.6 GPF)

Yes

34

32

27

34

45

33

36

27

39

No

66

68

73

66

55

67

64

73

61

Responses

300

31

74

146

49

126

91

49

33

Showerheads (federal standard = 2.5 GPM)

Yes

32

32

24

32

43

31

33

27

36

No

68

68

76

68

57

69

67

73

64

Responses

298

31

74

144

49

125

90

49

33

Bathroom faucets (federal standard =

2.2 GPM)













Yes

30

29

23

30

43

30

32

24

36

No

70

71

77

70

57

70

68

76

64

Responses

298

31

74

144

49

125

90

49

33

Q5b. Of the plumbing products listed in question 5a, were the plumbing products WaterSense labeled?
		 (Percent of Respondents)	



Total

Region

Total No. of Units Started in 2019



NE

MW

S

W

5 or Fewer

6 to 24

25 to 99

100+

Toilets

Yes

59

45

71

53

68

56

61

71

53

No

41

55

29

47

32

44

39

29

47

Responses

118

11

24

58

25

48

41

14

15

Showerheads

Yes

56

33

77

47

70

60

53

71

47

No

44

67

23

53

30

40

48

29

53

Responses

112

12

22

55

23

42

40

14

15

Bathroom faucets

Yes

56

25

75

48

73

56

53

75

47

No

44

75

25

52

27

44

48

25

53

Responses

108

12

20

54

22

41

40

12

15


-------
Attachment 1 - Data tables from January 2020 HMI Survey

Q5c. Of the plumbing products listed in question 5a,what was the typical standard for the efficient

plumbing products you installed?

(Percent of Respondents)



Total

Region

Total No. of Units Started in 2019



NE

MW

S

W

5 or F ewer

6 to 24

25 to !H>

100+

Toilets

1.2 S GPF

80

100

65

83

81

S5

81

75

64

LOO GPF

15



20

13

19

10

16

17

27

Less than LOO GPF

5



15

4



5

3

8

9

Responses

95

8

20

46

21

41

31

12

11

Shower beads

2.0 GPM

49

86

50

53

26

55

44

42

55

1.8 GPM

36

14

28

38

47

37

44

33

18

Less than 1.8 GPM

15



22

9

26

8

11

25

27

Responses

89

7

18

45

19

38

27

12

11

Bathroom faucets

1.5 GPM

52

67

47

63

26

62

46

36

45

1.2 GPM

34

33

29

28

53

30

42

36

27

1 0 GPM

8



6

7

16

3

8

9

11

Less than 1.0 GPM

6



18

2

5

5

4

18



Responses

85

6

17

43

19

37

26

11

11


-------
Attachment 2 - Selected data tables from What Home Buyers Really Want - 2019 Edition

Q27, Pirate indicate haw much crtru wouid you pay for a frame m/fth a particular fjreen certification,
asjuimiirgi the certification ii performed try a audible and independent third party
{Percent of respondents/



A.II Harm;
6uyers

Geography |Nuie CercwjsDfviikim|

Buyer Type

New

EZngUnd

Middle
A "J jnLn

Cas? North
Central

Wes I

Nort.1i
Cen5r.il

Sennit

AUahliL

ZaM Souih
Certixal

West
South
Cenlral

Mountain

Pacific

" > 11 • Mi

Repeal

C« Lfru_ation that Itie home nw*eLs. an

























jtiave code standard For enel^y

























efficiency

























Lesv than $100

27

29

27

30

20

30

30

28

23

26

26

28

$100 to 5499

LI

6

11

12

14

10

15

14

7

9

17

1G

5500 IO $399

9

6

7

a

11

i:

5

8

12

9

9

5

$1,000 La 54,999

32

31

34

34

41

29

28

28

35

32

33

32

$5,000 of mure

20

28

21

16

15

la

22

22

23

23

li

#

Mom

$2,625

$1,229

$2,645

$2,154

$3,065

$2,033

$2,525

$2.41S

$2,511

$3,603

$2,059

$2,705

Median

$1,000

$1,000

$1,000

$1,000

$1,000

$500

$1X300

5950

$1,000

$1,000

$5 DO

$1,000

hmtrruifctJfl

























aftawe code stamtard tor walw

























ellldeivwv

Lt=ii than $100

32

31

30

32

32

13

33

37

26

29

30

32

$100 10 $499

13

6

13

14

13

12

19

14

10

10

n

12

$500 to $999

10

9

9

10

12

13

5

8

13

11

10

10

$1,000 to $4,993

32

34

35

35

34

11

28

29

31

32

33

32

$5,000 &i more

13

19

13

9

10

LJ

15

12

20

18

10

14

(Hi 0

$1,900

$1,929

$2,223

$3,598

$1,433

$1,733

$1,700

$1,532

$2,020

$2,634

31.72&

$1,925

Median

$500

$UM0

$500

$500

$500

$509

; • .y

$400

$1,000

$1,000

$500

$soc

CerUftustlan ttvm trie home meets .in

























above cade standard for Indoor

























wivirritmeriLil quafity

























Less than $100

36

36

33

36

30

37

39

38

37

34

32

3b

$100 to $499

13

7

12

14

15

12

16

15

10

11

17

12

$500 to $999

10

S

8

10

I ~

12

6

9

10

13

10

11

$1.00010 $4,999

29

30

li

11

29

29

24

28

29

28

31

2?

$5,000 ar more

12

19

15

9

11

10

16

10

15

15

11

13

r.-'-

$1,£76

$2,594

$2,403

$1,567

$1,439

$1-573

$2,023

$M26



$2,633

$1,600

$1,687

Mtditn

$500

$500

$500

$300

$500

$500

$200

$250

$500

$500

$503

$500

027- Pi'f me indicate /tow much extra would ymu pay for a home with a particular preen certification,
aiiuming the certification a performed by a credible end independent third party
i Percent of respondent*}



A^e e( Household h ead

feneration lyear born J

Household CompLiy Lion



LhderlS

35 to 44

45 to 54

55 In 64

65 years

Mil Jenni-

Gen>

Boomers

Stsikjrs

Man led

Married

sngfe

One



es (s^ian-



(1<*4R-

(IQftSrtr

r w

ruiplfk



i-iid rtf





ysars old

years aid

year> old

ultl

older

laler I

1973

19641

nrlierl

children

cMkben

parent

person

Certllicafion Hiat the frjrfte merti an



























jbijw code standard for energy



























ellfcpdnty



























Less Ihan $100

23

22

26

32

29

23

24

30

29

26

30

23

27

$100to $490

:i

14

14

E

7

10

14

s

B

12

D

ID

Ll

$500to $999

12

12

9

ID

6

..

10

E

g

11

8

10

3

5L/X0 to $4,999

32

33

31

3D

34

32

31

33

31

30

35

28

31

$5,GOT uf mare

12

m

20

20

23

15

21

21

23

21

17

20

22

Mean

52,174

52,971

$2,782

$U47

M9

$2,456

$2,327

$2,560

$2-3£8

$2,371

$2,231

$2235

$2,975

Mb In

$500

$1,003

$lrQ0G

:i

$1,000

$500

$1,000

$ i aoo

$1,000

$1,000

$1,000

$i m

S1.CKJC

l on that the hart* mi*!ts an



























itinvw aide staiulM d tei wjtet



























effpoisncv

Usi Ihan $ 100

24

21

29

34

37

25

28

35

42

28

36

24

34

$100 to $439

22

15

15

9

10

20

14

10

7

13

10

20

13

$500 to $999

12

li

10

13

7

12

12

10

7

12

10

11

9

$1,0C0 to $4,999

3C

31

33

32

33

ii

33

32

35

30

34

33

12

55jQCQ Of mofifi

12

15

13

i:

13

13

14

13

8

17

10

12

12

Mean

52,215

$2,767

$1,731

$1,573

$1,702

5

$1,334

$1J03

$1,316

$2,506

$1,458

$1,599

$1,732

fv't :¦ ji

$5®

$555

5500

>500

$500

$500

$530

$500

$500

$500

1

$500

$50C

Cerr! Ik: alien thai the home meets an



























iiLtunc i-u'dc atdnfJiai U tui iildiX^C



























envit jnmmLdl QUAfity



























Levi Ihan $100

27

25

34

36

42

27

11

40

44

32

40

27

33

5100 to $499

21

15

16

9

8

19

16

9

9

13

10

21

14

5500 to $999

14

::

9

13.

8

11

ID

10

10

11

10

12

10

51,003 ta $4,999



31

27

28

30

3D

29

29

26

29

29

29

27

S3.CCC or rnure



l:

14

12

11

13

13

11

12

13

11

11

11

Mejh

$1,905

$2,773

$2V206

$1,385

$1,573

$2,354

$2.3iS

$1,545

$1,252



51.443

$1,707

$1,735

Median

$500

$50]

5500

;500

5300

$500

$530

5500

5250

$500

5500

$500

$250


-------
Attachment 2 - Selected data tables from What Home Buyers Really Want - 2019 Edition

027. Please indicate how much extra would yoa pay for a heme with a particular green certification.
aasum/nQ the certification a performed by a credible and independent third party
iPercent of respondents*



Race/Ithnkity

Nome Buyers Irorne Bradcel

Price Expect to Pay



Cauca-

African





Under

550.000

275,0011

$100,000

5150,000

Less than

$150,000

$250,000

$500,000













to





sian

American

is parte



S SO ,000

to
574.999





more

$150,000

5J49.W9

to

^499 999

or more

Certification that tfie home meets ;n



























above node 3«xndard for energy



























efficiency



























Leu than J100

29

24

25

if

30

27

•



29

31

28

23



$100 ta 5499

9

20

17

10

13

12

12

9

10

15

10

11

7

S5D0 ta $999

9

10

9

9

S

.

8

9

12

8

12

9

5

Si,000 ta $4,999

11

13

31

43

32

36

35

33

25

32

32

34

29

$5,000 or mare

21

13

19

22

17

17

25

23

23

14

15

23

23

Mean

$2.G£1

$2,ooa

S2.7GG

$2,M0

$2,266

$2J32

$3,136

$2,848

$2,919

$1,825

$2,362

$3,121

$3,245

N't". !'

$1,000

$500

$900

$1,000

$500

$1,000

$i c.v

$1,000

$600

$500

$1,000

$1,000

$1,000

:



























above code Hatidwd lot *ah-r



























tffiwncv

L»!i3 than $100

34

26

28

19

34

30

21



36

15

31

29

3.

$1D0 to $499

U

19

16

10

14

14

11



11

1G

12

12

i

$SC0 to $999

10

i:

10

10

10

B

10

11

12

9

13

10

10

$1,000 to $4,999

32

i

30

40

31

35

33

37

28

30

33



IE

$5,000 oj more

13

a

16

20

11

13

".9

13

13

10

12

14

i?

Mean

$1,792

$1,515

$2,912

$2,312

$1,490

$&£&

$2,722

$1,942

$1323

$a -hu

$1,534

$2,137

$2,664

i'

$500

$500

$500

$1,000

$500

$500

$1,0)0

$1,000

$500

$300

$500

$SQ0

$1,000

C«int!?ii;u^k3i- that Ul u bwrnt rrwiti itf-



























above code %tand ard for indoor



























environmental quallsy



























Less than $100

38

30

30

25

38

35



32

39

4G

34

33

33

$100 to $499

U

20

17

9

n

15

:

11

10

1G

13

l:

S

$500 to $999

10

10

8

15

10

7

ic

12

13

8

12

tx

n

$1,000 to $4,999



33

30

33

29

30

n

33

24

27

30

32

27

$5,000 or more

12

9

15

18

9

13

16

13

14

9

11

13

21

Mean

$1,609

$1,492

$2,685

$2,103

$1,459

$XG47

$2,473

$1,723

52,445

|| j-f-

$1,516

$2,113

$2,706

Median

$500

$500

$500

$1,000

$250

$500

5500

$500

$500

	

$500

$500

	m

QZS. Are you cwort of any oj the futiowbiy specific green certification frogrums for homo ?
/Percent of respondents I



Ail Home
Buyers

Geography [Nine Census Divisions!

3uyet Type

New
England

Middle
Atlantic

D M S- "vi
"efrtral

West
North

SOuIh
Atlantic

Lril South
Central

Wesr
South

Mountain

Pacific

First-time

Repeal

Living. Suiidtrig Qi^lien^t

























Yes

::

7

if

7

8

9

U

10

7

14

11



roo

90

93

B4

93

92

91

89

90

93

8G

B9



WG85 | National Green Building

























EtondurdJ

























Ves

15

17

20

12

11

15

15

12

13

18

14

-

W»

85

83

B0

£3

89

85

B5

SB

87

82

66

B5

PHI US [Passive Hsusfc iMiiule US)

























•iti-

8

7

13

6

6

7

13

7

4

11

7

9

no

92

93

B7

94



93

87

93

9G

B9

93

91

WalerSetee

























Yes

21

19

25

16

17

20

IB

23

27

26

20

21

He-

79

61

75

84

83

80

82

77

73

74



79

ZOli l (Zero Energy Rea-Jy Homes|

























Yesk

13

12

17

11

10

10

19

13

11

15

12



Na

87

88

B3

89

90

90

3*

87



85

88

B7



3.996

163

527

611

227

987

250

.-SB

335

506

395

3.101


-------
Attachment 2 - Selected data tables from What Home Buyers Really Want - 2019 Edition

Q28. Are pou aware of any of the fotbwing specific green certification programs for hanrm ?
(Percent of responde nts)



Age of Household Head

Generation (year bornl

Huuiclioki CorripasitiCHi



Jridef 35
yean old

35 tu 44
years old

45 ta 54
years old

55 to 54
yea/a old

65 Years,
aid or
ulder

Mil lunni-

aii fisao-

1 .iter I

Gen X
11965-
19791

Boom«f is
11946-
19641

Seniors
(1945 Of

i il -i

Married
couple:*
Lhiidren

Ma it ied
couple (va
children

SriJgie
parent

One
person

Living; Budding Challenge
Yes

26

24

9

6

2

37

11

4

a

17

4

20

|

No

74

76

91

94

98

73

39

96

98

83

96

80

34

NGBS 1 National Green Building



























Standard)



























YC4

28

28

14

12

7

29

17

ID

4

22

10



11

Na

72

72

86

88

93

71

83

90

96

7-

90

75

nq

PHIUS (Paasjvfc Hixise Institute L.S|



























1

23

21

E

3

2

23

: -

3



16

3

If

5

No

77

79

92

97

98

77

89

97

100

5-

97

8*

95

WtferSemt



























Yes

35

34

22

17

13

35

;.r

16

7

28

15

34

17

No

65

6E

78

81

88

65

-

34

93

72

85

56

S3

Zf RH (ZfefO Energy Ready Homes)
¥»

26

24

13

8

7

27

15

8

5

18

9

25

10

No

74

76

87

92

93

73

85

92

95

82

91

75

90

ReiuOn&es

1.558

333

620

583

402

2,014

939

9S6

77

1544

883

4'35

653

02 S. Are you aware of any of the following speafk green certification programs for homes ?
(Percent of rexporxients)





Race/E

tonicity



Home Beyers Into-nte Bracked

Price EJcpect to Pay



Cauca-
sian

Afncan-
Ameritan

Hispanic

Asian

Under
550,000

550XXJ0

to
$74,999

$75,000

to
$99,999

5100.000
to

S14&99S

$150,000

or rnare

Less than
$150,000

SlSWMM
to

S249.999

$250,000
to

5499.999

5500,000
or more

Lvng Building Challenge



























Ye

7

17

24

18

a

9

13

:i

S3

S

S

11

IA

Na

93

83

76

62

92

91

37

39

88

92

92

69

86

NGflS (Nation*' Green Building



























Standard)



























Ye

13

19

27

19

1J

15

17

16

20

12

13

17

19

No

87

81

73

61

89

85

3D

¦o.

30

08

B7

83

81

PHIUS (Passive House IratiSute US)



























Yes

¦

13

22



7

7

9

9

12

7

7

8

14

N

94

87

78

90

93

93

91

91

88

93



92

86

Witerisna!



























Yes

18

30

32

29

18

21

22

24

25



19

23



Nc

82

70

b8

71

82

79

7 "



75

83

81

77

71

ZERN (2ero Energy Ready Homes}



























Yea

10

17

26

18

11

11

14

16

15

11

10

15

17

N

fid

83

74

K2

39

89

86

34

85



90

85



Revuomea

2,530

486

605

209

1.500

832

617

SIS

329

1.2S0

900

1.2 60

433


-------
Attachment 2 - Selected data tables from What Home Buyers Really Want - 2019 Edition

Q321 Haw wE ui'd tile foifawmg frunauS rfesigvns and features influence your purchase decision?
(Percent of respondents)





Geography {INIIrw Census Dtvivom)

fiu\«r Type



All Hone
fruyen,

New

Lr^'and

Md d*
Atlanta

East North
-Central

West
North
Central

South
Atlantic

Last South
Central

West
South
.

Mountain

Pacific

First time

fitepoat

GftfciN *tATDRAS

























1 ankles water heater

























Uo not want

|

7

7

?

Is

9

11

7

7

8

11

8

Indifferent

12



14

17

4?

28

.14

2ti

JO

li

IS

31

Desirable

43

47

42

41

34

44

41

44

47

44

is

SJ

Essential,'Must Have

iu

iii

17

14

11

is

i4

22

15

21

15

18

5oiar water headn^'e^BCtr i cys.

























Da not want

li

iti

ill

113

li

11

11

14

9

5

11

10

Irdiffarent

31

29

10

19

JJ

29

J j

13

li

27

12

31

Desirable

48

44

47

11

44

45

4

19

5d turbine

























Da nat want

28

11

24

.lU

11

27

28

2a

31

22

n

28

Indifferent

36

it.



U

"



!-4

ii

36

36

16

16

DesirabJe

£B

21

J 2

jJ

AU

29

27

2a

39

32

11

2L

Esaentlal.'ft/ust Have

8

li!

9

&

i

e

11

a

&

ID

11

8

Ml lmro Komo I'praducac. at rjiuc-h

























energy from renewable sources aa -1

























caniumel

























Da not want

9

11

a

ID



11

31

31

4

6

11

-

Indifferent

38

14

17

42

4



3"

17

35

38

17

18

Desirable

42

41

ID

39

49

44

18

-

50

46

39

43

Esjientialj'Muat Have

11

12

15

3

9

ID

12

13

11

ID

12

11

h-acrf partially or canaieicly covered

























by plants

























Do not want

SO

49

43

4a

V.

•-

SG



sa

46

18

J

Indifferent

17

25

28

33

26

.'1:

23

20

J:

27

J1

26

D< :.;r,rj I

1?

19

21

14

17

V

12

17

i-

19

24

is

EsunEial/M-ust Have

i

a

3

5

3

7

8

9

¦i

S

7

?

Da not want

I-

m

15

SB

14

18

2L

21

11

13

20

n

Indifferent

13

n

15

37

37

30

18

31

2a

34

36

13

Desirable



n

14

17



17

20

13

47

40

12

37

EsaenlialijV^jUHav^^

14

15

15

ID

li

15

lb

14

12

15

12

14


-------
Attachment 2 - Selected data tables from What Home Buyers Really Want - 2019 Edition

Q32. How would the /iVJcuring vorfocet designs and features influence your pirrzhate decision?
(Pc rccnt of reipan-dentif



Age of Momeli-aki Head

"Generation {year txirnl

Household CampasHton



'Jrtder 35

35 tz> 44
years old

45 to 54
yean old

55 to 64

65 yeAtt

old o»J
older

Milieu ni
aMlSfiO
late*1*

GenX
(1965
L--'

Boomer*
(1946-
13641

Senkwi
11945 or
earlier!

Vlarried
couple w
children

Warned
couple no
tMidren

Single
parent

Otic
pervjT!

GRECN FEATUHtS



























TcmMesi Mater heater



























Do ikX want

9

7

9

7

8

B

9

7

9

7

9

B

i

Indifferent

35

30

35

31

29

33

32

32

20

28

35

34

:r

L :• MlIS

33

42

39

44

45

39

41

44

48

43

42

3B

l{

HiMyiti al/M a'jt Have

IS

21

17

17

17

20

IS

16

22

23

15

19

17

Saial wale-r heating/electric syi.



























Do ikM wirtT

8

8

11

10

12

£

10

U

16

9

11

9

Sfl

Indifferent

32

30

31

32

31

31

30

31

33

28

36



2't

!T m •

43



c.i

44

-7

42

45

46

: -

45

A4

40



Essential/Mailt Have

IS

19

13

14

10

19

14

12

7

IS

9

22

13

Geo thermal heating/coating



























Da jk3€ watt!

9

7

12

10

17

9

11

13

20

8

16

7

M

Indifferent

37

36


-------
Attachment 2 - Selected data tables from What Home Buyers Really Want - 2019 Edition

QJ2. How would ElSe foJiowiirq various dtnigru and features influence your ptircfwse derision?
I Percent of mpandeivis)



Race/EttmlciSy

Home Buyers xicome Dratites

F*nce Expect to Pay



Cauca-
sian

African
American



Asian

Under
550,000

$50,000

to
574399

$75,000

to
£99.999

$100,000
Co

$149,999

$150,000
or more

Les thin
SlSOjQOG

$150,000

to

$249,999

$250,000

ID

$499,999

$500,000
or more

GREEN FLATURES



























T^nUesa water heater



























Du not Want

6

a

s

11

9

10

5

a

fi

12

6

7

7

Indifferent

22

30

27

38

32

31

as

29

31

34

34

28

31

Desirable

4k

42

41

U

42


-------
Attachment 2 - Selected data tables from What Home Buyers Really Want - 2019 Edition

Q32- How would the following various designs and features influence your purchase dechion?
(Percent of responderrtsJ





Geography {Nine Census Divisions!

Suyer Type



All Harm:
E-jyert.

New
England

Middle
¦Ml k

Lii.t North
Central

Weil
North
Central

South
Atlcntk

East South
Central

West
South
Central

Mountain

Pacific

First-time

Repeat

GREEN FEATURES

























Reduced flciw i.trawe- headt

























Do rtat Waril

23

29

21

25

21

22

27

29

20



24

23

Indifferent

28

29

33

29

30

27

:r

26

27

2 -

33

2a

Desirable

35

31

31

36

36

36

34

29

44

35

30

35

EssentldMMu&fi Nave

14

11

1G

10

13

15

13

ifi

10

IS

S3

14

Water-cdnaueftln# Iciieti. 1 ItUih

























wulume bekow tli-e f ederel

























curaetvulton standard)

Da not want

11

11

12

10

12

.0



17

7

8

13



Indifferent

26

21

25

28

30

24

27

25

24

27

31

25

Desirable

M

50

47

46

44

46

41

15

45

43

33

45

Essential/Musi Hav»e

19

IE

17

1G

15

20

2d

23

21

22

*6

20

BUWdi/drttniId called tiiinwalei

























foT irrigation, toilet flushing, etc.

























Da nat want

24

22

19

23

29

23

31

26

26

20

23

24

Indifferent

36

39

39

37

31

3£

33

35



36

35

37

Desirable

31

27

32

32

36

3D

23

r.

23

34

31

31

Esseritlisl/Mui! Have

9

11

11

S

•J

9

13

9

7

11

11

9

Home components made of recycled

























materludi

























Co not want

11

12

13

9

10

13

17

15

3

8

15

11

Indifferent

47

41

43

51

48

47

45

45

52

47

41

43

Durable

33

36

32

34

38

3D

24

31

35

34

31

33

Cssentlal/Mutl llarve

9

n

12

G

4

10

33

9

5

11

13

9

Components made from locally

























produced materUb

























Da not want

a

G

7

5

6

10



11

4

8

12

7

Indifferent

47

46

42

49

49

£C-

46

45

51

46

41

47

Desirable

36

is

3£

56

3E

"l

32

33

33

3fi

35

37

Essentlsl/MuM Have

9

12

13

B

G

9

10

11

6

10

11

3

Cotnpr-nenLv llutt. using certified

























vtistainafciy harveiSied lunibti

























Do nat want

ID

ID

U

9

B

12

15

12

7

Q



9

Indifferent!

44

42

40

45

47

42

in

44

47

47

4"

44

Desirable

36

37

36

40

36

3D

33

35

4 •

35

35

37

Esseritlarl/Musl H^ve

ID

11

13

6

9

11

10

10

7

10

10

10


-------
Attachment 2 - Selected data tables from What Home Buyers Really Want - 2019 Edition

QJ2. fk?w woukl the fo Hawing various designs ond features influence y&ur purchase decision?
{Percent of respondents)



Age Household Head

Generation fyeai born I

Huiaehakl Composition



Under 15
yeuri old

35 to 44
yead old

45 to 54
imn 'ji'-i

5510 64

yjjrj, aid

65 yean,
ofd or
alder

Millenni-
al* 11930-
laterl

Gen K
11965-
19791

Boomers
11946-
19641

Seniors

(1945 or

Married
couple w
children

Married
Louple mi
d'lkben

Single
parent

One
person

GREEN FEATURES



























Reiiut^d Row Shower tedda



























Do ftot want

IB

21

23

24

25

20

21

23

30

18

25

21

::

Indifferent

34

28

15

26

24

12

32

26

24

11

27

30



Deiiiable

31

32

11

37

37

30

13

37

31

34

37

28

•



17

19

11

13

14

19

13

13

12

17

11

21

15

Water-cOfi^rving fOfletJ (fluifl



























malume bekj*» ll* fesiriaJ



























tor lervatlon £Ufidard)|

Da f... w«t»t

:c

::

12

14

9

10

u

11

10

9

10

14

j:

Indifferent

29

28

29

25

22

29

28

24

19

25

24

29

>

L'- -ii

42

42

41

45

48

40

43

46

45

•ii:.

47

38



CiierHjl/Muil Haw:

19

21

17

17

21

21

IB

IB

26

21

19

19

21

Bin els/ciHerra. tu collect rainwater



























Iu» irrigation^ Luilet Rushing, etc.



























to rteft want

15

15

22

24

31

15

21

27

36

18

27

21

n

Indifferent

14

14

37

36

IS

14

16

3E

35

33

36

35

37

Dt II .! •

35

13

10

33

27

13

11

30

25

33

32

31

2"

E3&Bnti*!/lV§Ugt Have

17

IE

ID

B

3

19

12

5

4

16

4

U

3

Home component. ttiAite at recycled



























material.



























Do not want

11

-

13

12

12

10

--1

11

IS

10

13

10

IJ

Indifferent

39

IB

47



54

38

44

51

48

i-

52

45

4?

Desirable

33

35

12

.r

29

13

34

32

31

35

30

29

H

Esieplul/MuaJ Have

17

IB

9

6

5

19

10

5

6

14

5

17

7

Cun»0cinen!L made from locally



























produced material?
Do itaft want

::

7

5

6

9

9

3

7

8

6

9

9

I

Indifferent

m

40

49

46

50

39

47



56

41

49

38

1,"

Desirable

13

16

32

40

38

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Attachment 2 - Selected data tables from What Home Buyers Really Want - 2019 Edition

Q3L How wouid the /bJJowmp various designs, and feature* influence purchase decision?
iPercent of respondents)



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14


-------
WaterSense

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Clayton Traylor, Vice President
Affiliation: Leading Buildings of America
Comment Date: July 23, 2020
Document ID: EPA-HQ-OW-2020-0026-0094

Comment Text:

Thank you for allowing Leading Builders of America to submit the attached comments
related to EPA's RFI on the Watersense program.

Attachment

See pages 214 and 215.

213

August 2020


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1455 Pennsylvania Ave NW, Suite 400 • Washington, DC 20004
(202) 621-1815 • www.leadingbuildersofamerica.org

July 23, 2020

Stephanie Tanner, Office of Water
Environmental Protection Agency
1200 Pennsylvania Avenue, NW (Mail code 4202M)

Washington, DC 20460

RE: Docket ID No. EPA-HQ-OW-2020-0026, regarding gauging consumer satisfaction in the WaterSense
program.

Dear Ms. Tanner,

On behalf of Leading Builders of America, I appreciate this opportunity to provide our thoughts on the
EPA's request for information related to the WaterSense program, and how to most appropriately gauge
consumer satisfaction with WaterSense products.

Leading Builders of America (LBA) is a Washington, DC based trade association representing twenty of
the largest public and private homebuilders in the United Sates. LBA's twenty member companies
construct nearly 40% of the new homes built annually in the U.S.

In today's competitive homebuilding market, LBA members are continuously focused on meeting and
exceeding consumer expectations. These include delivering homes that conserve water and consume
less energy. Our builder members find that these concepts are increasingly important to American
consumers across the country, and because of that, LBA members work diligently to identify products
and construction methods that assist them in providing the best possible product to homebuyers.

LBA members embrace voluntary efficiency and conservation programs like WaterSense and Energy Star
because they provide builders with the flexibility to balance efficiency and conservation goals against
the need to deliver homes that meet performance expectations, and that are affordable for typical
American families. The WaterSense program is particularly valuable in this regard as it takes both a
holistic and incremental approach to water conservation.

Our members in the private sector marketplace are always carefully considering the continued use of
products such as those in the WaterSense program. We are as a matter of business particularly attuned
to consumer interests, needs, and concerns with all home-related products in the marketplace.
Additionally, our members maintain business relationships with homebuyers post-closing as we work on
final "punch-list" items. This provides us with an ongoing opportunity to ensure that customers are
happy with fixtures and other items installed in their homes. Given that experience and direct
interaction with consumers, our members continue to be supportive of the Watersense program. We
know that the EPA is seeking ways to better gauge consumer satisfaction with these products. LBA
believes it would be difficult for the government to take a role that would be any nimbler and more
responsive than that which already happens in the residential construction marketplace.


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p

I

i

Leading Builders of America

LBA looks forward to working with the U.S. Environmental Protection Agency to build on the success of
the current WaterSense program as we continue to lower the operating costs of new homes for
American consumers. We hope that EPA will continue to offer its full support for the WaterSense
program, and we look forward to being a resource for EPA as you consider the importance and impacts
of programs such as this in the future.

Thank you for giving consideration to our views.

Sincerely,

Vice President

Leading Builders of America


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WaterSense

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Dain M. Hansen, Executive Vice President

Affiliation: International Association of Plumbing and Mechanical Officials (IAPMO)

Comment Date: July 24, 2020

Document ID: EPA-HQ-OW-2020-0026-0095

Comment Text:
See attached file(s)
Attachment

See pages 217 through 220.

216

August 2020


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INTERNATIONAL ASSOCIATION OF
PLUMBING AND MECHANICAL OFFICIALS

101 Constitution Avenue, NW Suite 825 East
Washington, D.C. 20001

Ph: 202 445.7514

http://www.iapmo.org/GR

July 24, 2020

Mr. Andrew Wheeler
Administrator

US Environmental Protecti on Agency
Washington, DC

Subject: IAPMO's Comments on Docket ID No. EPA-HQ-OW-2020-0026 - Request for
Information on the Water Sense® Program

Dear Administrator Wheeler:

On behalf of the International Association of Plumbing and Mechanical Officials (IAPMO), we
appreciate the opportunity to provide input on EPA's Request for Information on the WaterSense®
Program.

IAPMO is a nearly 100-year old trade association for the plumbing industry. Our members and
clients include plumbing and mechanical contractors, inspectors, engineers, code officials, water
and energy experts, and manufacturers of plumbing, mechanical, and building products—all of
which benefit from the EPA's WaterSense® labelling program.

We are the developer of the Uniform Plumbing Code, the Uniform Mechanical Code, the
Uniform Solar Energy Code, the Uniform Swimming Pool, Spa and Hot Tub Code and the
Water-Efficiency and Sanitation Standard (WE-Stand), an American National Standard, which
provides safe and effective water efficiency provisions for residential and commercial buildings.
IAPMO codes and standards are developed employing an ANSI-accredited open consensus
development process and are published as American National Standards. IAPMO R&T, a
division of IAPMO, is an ANSI-accredited third-party certification agency and the industry-
preferred certifier of WaterSense labelled plumbing products in North America.

We'd like to preface our comments by stating that IAPMO fully supports the WaterSense®
program. Despite its meager funding levels, the WaterSense® program is a model of a successful
public-private sector partnership. Independent research on residential water use and has shown
that WaterSense® labelled products are performing well. To date, over 3.4 trillion gallons of
valuable potable water have been saved since the introduction of the program in 2006 resulting
in over $84 billion in water, sewer and energy bill savings for American consumers. Very few
government programs yield such profound benefits to industry, consumers and the environment.


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In the development of numerous WaterSense® specifications, IAPMO staff has worked with the
technical leaders of the WaterSense plumbing program. We have found the EPA's outreach to
stakeholders to be comprehensive, inclusive and fair to all concerns. The EPA is to be
commended in their fact-finding process as specifications for the plumbing industry are

considered and updated. We hope that this process will continue without being compromised by
non-technical concerns.

Regarding the EPA's request for specific commentary in the Federal register, IAPMO offers the
following comments:

1.	Should the EPA include customer satisfaction criteria in the WaterSense® specification
and guidelines?

IAPMO recommends that such criteria not be included in the program's specifications and
guidelines. While such information might provide insights into the user experiences with
WaterSense® labeled products, writing satisfaction criteria into the specifications would be
problematic. Rather, IAPMO recommends that consumer satisfaction research be conducted by
independent, qualified organizations capable of developing surveys that are scientifically
developed to eliminate biases.

However, IAPMO recognizes that the best measure of consumer satisfaction is the market place
itself. Manufacturers of plumbing products compete every day for American consumer dollars.
Products that do not perform to consumer expectations are readily eliminated from the
competitive marketplace.

2.	How should the EPA design studies to inform future reviews that might incorporate
customers satisfaction considerations?

The plumbing industry understands that measuring customer satisfaction, especially as it pertains
to plumbing products, is difficult to accurately measure, especially through the use of surveys.
User perceptions are shaped by many variables, including brand selection, problems encountered
with the installation of the product that are specific to a given installation, conditions particular
to the plumbing system or water distribution system (such as supply pressure and water
hardness), and appearance.

Importantly, consumer opinions on the use of products that are considered environmentally
friendly or "green", have unfortunately become increasingly polarized due to political
discussions. These biases are real and will be difficult to overcome when measuring consumer
satisfaction. Thus, any studies that seek to inform such reviews would need to take this into
account.

3.	What information, data, surveys, and studies are available to help assess customer
satisfaction with WaterSense® labelled products which could help inform future product
specifications?

2


-------
Due to the difficulties with measuring customer satisfaction, as discussed above, we are not
aware of any scientific surveys or studies that were specifically developed to measure customer
satisfaction with WaterSense® labelled products. However, a great deal of data exists on the
performance of WaterSense® labelled toilets.

The well-established MaP Testing (Maximum Performance Testing) began testing 1.6 gallon per
flush toilets (gpf) in 2003, prior to the introduction of the EPA's WaterSense® program, in
response to complaints of poor performance on some early 1.6 gpf toilet models. Since then, the
market has transitioned to High Efficiency Toilets (HETs) that flush at 1.28 gpf, a 20% reduction
from 1.6 gpf models. Today, almost 3400 toilet models have been voluntarily submitted for
testing by manufacturers and the published MaP results over the years clearly indicates that
performance has continuously improved. Many of today's HETs are capable of flushing over
1000 grams of test media and toilet paper, providing performance that exceeds consumer
expectations despite the transition to HETs.

It should also be noted how the WaterSense® program has impacted and advanced industry
standards in recent years. Tests that were originally developed through the WaterSense®
specification process have been considered and have been incorporated into industry standards.
For example, when the WaterSense® specification on water efficient showerheads was
developed, two performance tests were included in that specification that investigated spray
coverage area and spray force, attributes that directly relate to consumer satisfaction. Both tests
were later incorporated into the ASME A112.18.1 / CSAB125.1 industry standard for all
showerheads.

The showerhead specification is especially noteworthy as the our nation benefits from both the
water and energy related efficiencies that result from the use of WaterSense® labeled
showerheads. To provide some perspective on the importance of the water and energy savings,
The Alliance for Water Efficiency (AWE) has analyzed the future impact that might result if
showerhead flow rates were raised, using data describing the installed base of showerheads in
2011-2012 from the Residential End Uses of Water Study1 which has documented actual flow
rates in the field. Based on projections for new development and for existing home showerhead
replacements, AWE estimates that 2.5 gpm showerheads provide 11 billion gallons per year in
water savings and 5 trillion Btu per year in energy savings. Ultra-efficient showerheads (<1.6
gpm) provide 19 billion gallons per year in water savings and 9 trillion Btu per year in energy
savings. These are significant savings; in ten years the savings for 2.5 gpm showerheads at the
federal standard alone accumulate to the equivalent of supplying 1 million homes with water and
670,000 homes with energy. We urge the EPA to continue to support the WaterSense
showerhead specification as currently written.

4. Comments on EPA's Recent review of the WaterSense® program.

IAPMO supports the EPA's decision to not revise current WaterSense® specifications for water
efficient plumbing products. While lower flow rates and water consumption values may be
technically achievable, research is required to better understand the resulting impacts on

1 Residential End Uses of Water Study, 2016 Update. Water Research Foundation.

3


-------
infrastructure and the relationship between reduced flows and declining water quality, as
discussed in NIST's Measurement Science and Research Needs for Premise Plumbing Systems
report. IAPMO is equally opposed to any revisions to WaterSense® specifications that would
increase flow rates or consumption values. Such changes would harm the WaterSense® program
and would add to the proliferation of new regulations that mandate new and varying water
efficiency requirements at State and local levels that would result in considerable market
confusion.

We thank the EPA for their commitment to water efficiency and their consideration of our
recommendations regarding the WaterSense® program.

Sincerely,

Dain M. Hansen

Executive Vice President

The IAPMO Group

4


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Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Eric Olson, Senior Product Manager, and Louis Starr, Energy Codes and
Standards Engineer; Megan Geuss, Policy Associate

Affiliation: Northwest Energy Efficiency Alliance (NEEA); Appliance Standard

Awareness Project (ASAP)

Comment Date: July 24, 2020

Document ID: EPA-HQ-OW-2020-0026-0096

Comment Text-
Dear Ms. Tanner,

Northwest Energy Efficiency Alliance (NEEA) and Appliance Awareness Standards
Project (ASAP) submit the following comments in response to the Notice of Recent
Specifications Review and Request for Information on WaterSense Program.

Thank you,

Attachment

See pages 222 and 223.

4

EPA

WaterSense

221

August 2020


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July 24th, 2020
Via Electronic Mail

Ms. Stephanie Tanner,

Office of Water (mail code 4204M)

Environmental Protection Agency
1200 Pennsylvania Avenue,

NW, Washington, DC, 20460

Re: NEEA and ASAP WaterSense Specifications Review and Request for Information
Comments; Docket Number EPA-HQ-OW-2020-0026, FRL-10007-06-OW

Dear Ms. Tanner,

Northwest Energy Efficiency Alliance (NEEA) and Appliance Awareness Standards Project (ASAP)
submit the following comments in response to the Notice of Recent Specifications Review and
Request for Information on WaterSense Program.

Comments

NEEA strongly supports EPA's decision to maintain current WaterSense product performance
criteria.

The average household with an electric water heater will save 86 kWh (Kilowatt Hour) per year
using WaterSense faucets1 and 330 kWh per year using WaterSense showerheads2. These
savings provide excellent energy savings while providing the same utility for the customer.

According to a 2014 Government Accountability Report3, 40 out of 50 state water managers
expect water shortages under average conditions in some portion of their states over the next
decade. The WaterSense program has effectively alleviated these water shortages. Through the
end of 2018, WaterSense has helped Americans save a cumulative 3.4 trillion gallons of water,
462.5 billion kilowatt-hours of electricity, and more than $84.2 billion in water and energy bills4.
Furthermore, as of 2018, manufacturers had voluntarily developed over 30,000 WaterSense
labeled models4.

NEEA supports EPA on its commitment to consumer satisfaction and encourages EPA to
investigate whether more stringent performance criteria, as the most cost-effective path to
ensuring high consumer satisfaction with WaterSense products, are warranted.

1	https://www.epa.gov/watersense/bathroom-faucets

2	https://www.epa.gov/sites/production/files/2017-01/documents/ws-products-factsheet-
showerheads.pdf

3	http://www.gao.gov/products/GAO-14-430

4	https://www.epa.gov/sites/production/files/2019-06/documents/ws-aboutus-
2018_watersense_accomplishments.pdf


-------
We are supportive of EPA creating the ENERGY STAR arid WaterSerise trademarks, which
consumers have grown to trust as an indication of budget-friendly products of the highest
quality. To maintain consumer trust in the WaterSense label, the products in the program must
deliver the expected consumer utility. To that end, the WaterSense program has included
several performance criteria in its specifications to ensure customer utility. For example, for
showerheads, the WaterSense specification assesses not only water efficiency, but also spray
force and spray coverage5.

To continue to ensure consumer satisfaction with WaterSense labeled products, we encourage
EPA to identify opportunities to make current performance criteria even more representative of
field performance. Customer feedback may be a useful component of this discovery process.
However, we anticipate that using customer satisfaction panels to routinely assess WaterSense
products will be costly and suffer from issues of repeatability, reproducibility and difficulty in
quantifying results.

Thank you for considering our comments.
Sincerely,

neea

Eric Olson

SENIOR PRODUCT MANAGER
Northwest Energy Efficiency Alliance
Direct 503.688.5435

n a

Louis Starr, P.E.

Energy Codes and Standards Engineer
Northwest Energy Efficiency Alliance
Direct 503.688.5438

Megan Geuss
Policy Associate

Appliance Standards Awareness Project

818-590-4168

rngeuss@standardsasap.org

5 https://www.epa.gov/sites/production/files/2018-07/documents/ws-products-specification-
showerheads -vl -1 ,pdf


-------
WaterSense

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Stan Hazan, Sr. Director, Regulatory Affairs

Affiliation: NSF International

Comment Date: July 24, 2020

Document ID: EPA-HQ-OW-2020-0026-0097

Comment Text:
See attached file(s)
Attachment

See pages 225 and 226.

224

August 2020


-------
NSF International

July 24, 2020

Ms. Stephanie Tanner
Office of Water

Environmental Protection Agency
1200 Pennsylvania Ave., NW
Washington, DC 20460

Re: Docket EPA-HQ-OW-2020-0026-0065

Dear Ms. Tanner:

NSF International (NSF) is an independent, not-for-profit organization founded in 1944 in Ann
Arbor, MI that develops consensus national standards, provides product inspection, testing and
certification, auditing, education, and related services in public health and safety. The core
purpose of NSF is to "protect and improve human and environmental health." NSF has a long
history of working with the EPA, FDA, USD A, CDC, and health related governmental entities at
the state and local levels, as well as international bodies. NSF is a Collaborating Centre of the
World Health Organization for Food Safety, Water Quality, and Indoor Environment.

NSF International is accredited by the Occupational Safety and Health Administration (OSHA),
the Standards Council of Canada, the American National Standards Institute (ANSI), and the
International Accreditation Service. NSF laboratories worldwide are ISO/IEC 17025 accredited
for testing and calibration. Additionally, our Ann Arbor location is an OSHA Nationally
Recognized Testing Laboratory.

NSF appreciates the opportunity to provide comments to the EPA request for information on the
WaterSense program. As an independent certifying body for the WaterSense program, NSF is
accredited to certify bathroom faucets, residential toilets, showerheads and urinals. We strongly
support periodic review of the program specifications to ensure product categories are
maximizing water efficiency while achieving the same or better performance than non-program
models. When reviewing product category specifications, we would encourage the EPA to use
sound science and data to inform its decision-making process. Doing so will ensure consumers
are able to purchase water efficient models that meet their performance expectations.

The use of independent entities to perform conformity assessment activities related to the
WaterSense specifications is consistent with long-standing US government policy outlined in
OMB circular No. A-l 19 and placed in federal law by the National Technology Transfer and
Advancement Act. Independent verification provides assurance to the consumer of the products
performance. Certifying bodies are accredited in accordance with certifiers in accordance with
ISO/IEC 17065, a requirement we encourage be maintained. NSF tests WaterSense product in


-------
ISO 17025 accredited laboratories. The use of these ISO standards sets minimum requirements
for the certifying bodies providing consumers the confidence of purchasing product with the
WaterSense label.

NSF appreciates the opportunity to make comment on the EPA WaterSense program.
Sincerely,

St* /fazcvt

Stan Hazan

Sr. Director, Regulatory Affairs

2


-------
Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Patrick Eilert, Manager, Codes & Standards; Karen Klepack, Senior
Manager, Building Electrification and Codes & Standards; Kate Zeng, ETP/C&S/ZNE
Manager, Customer Programs

Affiliation: Pacific Gas and Electric Company; Southern California Edison; San Diego

Gas and Electric Company

Comment Date: July 24, 2020

Document ID: EPA-HQ-OW-2020-0026-0098

Comment Text:

Attached, please find the comment letter from the Pacific Gas and Electric Company,
San Diego Gas and Electric, and Southern California Edison in response to the request
for information made by the U.S. Environmental Protection Agency for comments on the
WaterSense Program.

Attachment

See pages 228 through 231.

4

EPA

WaterSense

227

August 2020


-------
__/¦»0	I SOUTHERN CALIIORNI*

MM Pacific Gas and £2*E	EDISON

ElCompany A^SempraEnergy utility* Energy for What's Ahead®

July 24, 2020

Stephanie Tanner
Office of Water - 4204M
Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Washington, DC, 20460

Docket ID: EPA-HQ-OW-2020-0026-0001
RIN: Not assigned

Dear Ms. Tanner:

This letter comprises the comments of the Pacific Gas and Electric Company (PG&E), San Diego Gas
and Electric (SDG&E), and Southern California Edison (SCE) in response to the United States (U.S.)
Environmental Protection Agency (EPA) request for information (RFI) on the WciterSense® program.

The signatories of this letter, collectively referred to herein as the California Investor-Owned Utilities
(CA IOUs), represent some of the largest utility companies in the Western U.S., serving over 32 million
customers. As energy companies, we understand the potential of appliance efficiency standards and
voluntary standards to cut costs and reduce consumption while maintaining or increasing consumer utility
of products. We have a responsibility to our customers to advocate for standards that accurately reflect the
climate and conditions of our respective service areas, so as to maximize these positive effects.

Since its inception in 2006, EPA's WciterSense program has remained critical to the preservation of
freshwater resources nationwide, particularly in drought-stricken states like California. The WciterSense
program has saved 3.4 trillion gallons of water nationwide, which has further saved 462.5 billion
kilowatt-hours (kWh) of energy1 nationwide due to the mitigated need to move and heat water. We
commend EPA for maintaining the stringency of the existing voluntary WciterSense requirements for
tank-type toilets, lavatory faucets, showerheads, flushing urinals, and weather-based irrigation controllers.
Furthermore, we maintain that the WciterSense label remains a mark of quality and environmental
stewardship in the market, and we strongly urge EPA to consider the following comments in furtherance
of the WciterSense mission.

1 According to EPA, https://www.epa.gov/sites/production/files/2019-06/documents/ws-aboutus-
2018 watersense accomplishments.pdf

1


-------
1.	The CA IOUs strongly support the WaterSense program as a critical tool to help ensure
California can mitigate water hardships caused by drought.

California is one of the world's largest and most prosperous economies, yet the state has faced a
water crisis for decades due to prolonged drought. Over 11 million California residents (31 percent of
the state population) reside in areas currently affected by drought,2 and this number increases as
drought conditions grow across the state. Demand for water has significant impacts on energy usage
in California. For example, moving water from Northern California to Southern California is
estimated to use 12,700 kWh per million gallons;3 as such, the efficient use of water by California
ratepayers is of the utmost importance to the CA IOUs.

California has built upon EPA's WaterSense specifications to improve water use efficiency. In 2015
California Assembly Bill 723 required the California Energy Commission to consider EPA
WaterSense standards when setting efficiency levels for plumbing fixtures4 More recently, California
has set Title 20 Appliance Efficiency Regulations for many of the indoor plumbing products
discussed in this RFI. Consequently, as of 2018, showerheads in California are required to have a
maximum flow rate of 1.8 gallons per minute (gpm);5 60 percent of WaterSense labeled showerheads
have a maximum flow rate of 1.8 gpm in line with the California regulation.

The CA IOUs view the WaterSense program as critical to maintaining water security in California.
We urge EPA to continue to support the proliferation of WaterSense products in the market. We also
encourage EPA to strengthen the efficiency levels and performance requirements of the WaterSense
specifications for products contained in this RFI in future rulemaking efforts, aligning with existing
California regulations.

2.	The CA IOUs note that existing EPA specifications for WaterSense products already
address consumer satisfaction issues; representative test methods remain the best method to
ensure WaterSense products perform to consumer expectations.

The CA IOUs appreciate the importance of consumer satisfaction to help ensure that the WaterSense
label remains a trusted mark of quality for products in the program. In our experience, WaterSense
specifications already include cost-effective, quantifiable, repeatable, and reproducible procedures for
ensuring that products meet consumer needs, such as the waste extraction methodology outlined in
American Society of Mechanical Engineers (ASME) A112.19.2/CSA B45.1 for tank-type toilets.6 We
encourage EPA to continue to support cost-effective, quantifiable, repeatable, and reproducible
methodologies that speak to consumer satisfaction beyond the existing specifications.

For indoor plumbing products, the Energy Policy and Conservation Act of 1975 (EPCA), as well as
the federal test procedures that determine compliance with EPCA, govern minimum water-use
efficiency metrics. Neither the federal standards nor test procedures for these EPCA-regulated
products include consumer satisfaction metrics. We encourage EPA to carefully consider the benefits
of new criteria beyond what is already defined in EPCA or the associated industry test procedures
which will add additional test burden on manufacturers participating in the voluntary program. Over
2,000 organizational partners and 30,000 labeled models demonstrate the importance of the
WaterSense program in ensuring that the industry can deliver quality water-saving products to the

2	https://www.drought.gov/drought/states/califomia

3	https://fas.org/sgp/crs/misc/R43200.pdf

4	http://digitalcommons.law.ggu.edu/cgi/viewcontent.cgi?article=1569&context=caldocs assembly. Page 1

5	20 CA ADC § 1605.3 - Table H5

0 Section 4.0 (Flush Performance Criteria): https://www.epa.gov/sites/production/files/2017-01/documents/ws-products-spec-
toilets.pdf

2


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marketplace. Costly, burdensome, and imprecise consumer satisfaction requirements would only
serve to limit participation in the program.

From our perspective, existing specifications for the products outlined in this RFI already address
many historical consumer satisfaction issues, and we maintain that further improvements to the
specifications are the cheapest and most effective way to ensure that only quality products earn the
Water Sense label. We encourage EPA to work with energy and water efficiency advocates,
manufacturers, and other stakeholders to improve the representativeness of specifications for
WaterSense products where EPA has evidence that products are not performing in practice as
claimed.

3. The CA IOUs note that data exist confirming that WaterSense products in the marketplace
are meeting customer expectations for performance.

To better understand consumer satisfaction with WaterSense products, we reviewed Consumer
Reports® for product categories that are rated by both programs (e.g., tank-type toilets and
showerheads). For over 80 years Consumer Reports has been providing independent ratings of
consumer products and currently serves over six million members.

Our analysis confirmed that WaterSense products are included in Consumer Reports' list of
recommended products for both tank-type toilets and showerheads. For example, of the 46 toilets
listed in the Consumer Reports database, 34 (or nearly 74 percent) of the models are WaterSense
certified products. Note that our analysis likely undercounts the percentage of WaterSense certified
products in the Consumer Reports database since we anticipate that model numbers in the WaterSense
database are updated more often than the Consumer Reports reviews. This analysis showed that
WaterSense labeled products for at least two significant product categories meet rigorous standards
for customer satisfaction. Furthermore, this data strongly suggests that WaterSense's approach to
ensuring customer satisfaction through representative, cost-effective, repeatable, and reproducible
specifications has been successful.

3


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In conclusion, we would like to reiterate our support for EPA's WctterSense program and commend EPA
on creating specifications that have resulted in critical water savings and high consumer satisfaction for
WaterSense-\abc\cA products. We do not support the addition of non-repeatable qualitative consumer
satisfaction requirements as part of the specifications, as these would create an unnecessary additional
burden for manufacturers with limited benefit to consumers. Instead, we encourage EPA to continue to
pursue representative specifications that will ensure that products meet consumer needs, so that the
program remains attractive to both manufacturers and consumers alike.

Sincerely,

Patrick Eilert

Manager, Codes & Standards
Pacific Gas and Electric Company

Karen Klepack

Senior Manager, Building Electrification and
Codes & Standards
Southern California Edison

Kate Zeng

ETP/C&S/ZNE Manager

Customer Programs

San Diego Gas & Electric Company

4


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WaterSense

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: David Hochschild, Chair
Affiliation: California Energy Commission (CEC)
Comment Date: July 24, 2020
Document ID: EPA-HQ-OW-2020-0026-0099

Comment Text:
See attached file(s)
Attachment

See pages 233 through 238.

232

August 2020


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CALIFORNIA
ENERGY COMMISSION

CALIFORNIA/-

mml natural
mpresources

AGENCY

July 24, 2020

WaterSense Program

U.S. Environmental Protection Agency

Office of Wastewater Management (4204M)

Attn: Mr. Andrew Wheeler

1200 Pennsylvania Avenue, N.W.

Washington, D.C. 20460

Via Regulations.gov

RE: Notice of recent specifications review and request for information on
WaterSense program

Docket number: EPA-HQ-OW-2020-0026

Dear Administrator Wheeler:

The California Energy Commission (CEC) is the primary energy policy and
planning agency for the State of California. One of the chief mandates of the CEC
is to reduce the inefficient consumption of energy and water by prescribing
efficiency standards and other cost-effective measures for appliances whose use
requires a significant amount of energy or water statewide. Such standards must
be technically feasible and reduce total costs to consumers over the designed life
of the appliance. In response to California's driest year in 2014,1 the CEC is
required to adopt performance standards and labeling requirements for landscape
irrigation equipment, including emission devices, for reducing the wasteful,
uneconomic, inefficient, or unnecessary consumption of energy orwater.2 The
CEC recognizes the importance of working closely with U.S. Environmental
Protection Agency's (EPA) WaterSense Program, to promote water efficiency of
appliances in homes and businesses.

1	Based on annual runoff and annual precipitation.

https://ca.water.usgs.gov/california-drought/california-drought-comparisons.html

2	Water Efficiency: Landscape Irrigation Equipment Act (Assembly Bill 1928,
Campos, Chapter 326, Statutes of 2016)

energy.ca.gov
1516 9th Street, Sacramento, CA 95814


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Mr. Andrew Wheeler
July 24, 2020
Page 2 of 6

The CEC is committed to helping ensure water conservation remains a California
way of life by taking all necessary actions to prepare and respond to drought
conditions and acknowledges that the WaterSense program has saved consumers
3.4 trillion gallons of water, more than $84 billion in water and energy bills, and
over 460 billion kilowatt-hours of electricity.3

The CEC supports EPA reviewing existing WaterSense product specifications for
tank-type toilets, flushing urinals, lavatory faucets and accessories, showerheads,
and weather-based irrigation controllers for potential improvements to water
efficiency and/or product performance as required by the provisions of The
American Water Infrastructure Act (AWIA) of 2018. Although EPA has determined
in this notice not to revise any specifications at this time, should the EPA make the
decision to revise any of the WaterSense specifications, we strongly encourage the
specifications align or surpass existing California appliance efficiency regulations,
which have been demonstrated to be technically feasible, cost-effective, and safe,
in order to achieve greater water and energy savings.

The WaterSense label on a product is a symbol to consumers that these products
are more efficient than average products available in the market. Data available
through California's Modern Appliance Efficiency Database System (MAEDbS) and
EPA's WaterSense product database indicate there are many water efficient
products that exceed the minimum WaterSense performance requirements, are
readily available in the market, and continue to gain traction with consumers.
Unfortunately, when the majority of products bear the WaterSense label
consumers will not be guided to select the most efficient products and
manufacturers will be less inclined to develop and innovate more efficient products.
It is therefore appropriate that EPA's WaterSense performance specifications for
lavatory faucets, flushing urinals, and showerheads, at minimum, align with
California's existing appliance water efficiency standards to be representative of
the more water efficient products and be consistent with the water saving goal of
the program. The CEC requests that the EPA consider the following to prevent
unnecessary and wasteful use of water, while saving consumers money with
products readily available in the market:

High-Efficiency Lavatory Faucet Specification

The CEC recommends EPA update its current water efficiency requirement of 1.5
gallons per minute (gpm) at 60 pounds per square inch (psi) to a maximum flow
rate of 1.2 gpm at 60 psi for lavatory faucets and lavatory faucet accessories to

3 Cumulative savings through the end of 2018.
https://www.epa.gov/watersense/accomplishments-and-history


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Mr. Andrew Wheeler
July 24, 2020
Page 3 of 6

provide a consistent standard to manufacturers and achieve the increased savings
described above. The CEC also recommends the EPA expand the scope to
include kitchen faucets and apply a maximum flow rate of 1.8 gpm at 60 psi to
harmonize with California standards. California water efficiency standards are
achievable, as evidenced in Figure 1 which shows more than 9,000 models
registered to MAEDbS. The WaterSense product database demonstrates 9,754
lavatory faucet models out of 19,614 models have a maximum flow rate of 1.2 gpm
or less.4

Figure 1. Number of Registered Lavatory Faucet and Kitchen Faucet Units in

MAEDbS:































\





















V \

























































I :



















>



















1

0 1000 2000 3000 4Q00 5000 6000 7000 8000 9000 10000

Model (n)

Lavatory Faucets -¦—Kitchen Faucets

Specification for Flushing Urinals

The CEC recommends the EPA apply a maximum flush volume of 0.125 gallons
per flush (gpf), as required in California for products manufactured on or after
January 1, 2016, instead of the current maximum current flow rate of 0.5 gpf. Data
available through MAEDbS demonstrates more than 165 wall-mounted urinals are
available in the market that meet this standard. There are 726 models recorded in
the WaterSense product database and 299 models have a flush volume of 0.125

4 WaterSense product search as of June 2020.

https://lookforwatersense.epa.gov/products/


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Mr. Andrew Wheeler
July 24, 2020
Page 4 of 6

gpf or less.5 California's water efficiency standards for urinals are achievable and
reasonable. The CEC also encourages the EPA to research and develop
performance and quality requirements that exceed current specifications for tank-
type toilets.

Specification for Showerheads

California transitioned from a water efficiency standard of 2.0 gpm at 80 psi, for
showerhead products manufactured on or after July 1, 2016, to its current standard
of 1.8 gpm at 60 psi for products manufactured on or after July 1, 2018. This
standard is estimated to have saved Californians 14 billion gallons of water, 75
million therms of natural gas, and 493 gigawatts-hour (GWh) of electricity per
year.6 The CEC recommends EPA apply a maximum flow rate of 1.8 gpm at 80 psi
for showerheads providing an additional opportunity to increase water efficiency.
There are more than 8,000 showerhead units registered in MAEDbS (see Figure
2). In addition, 6,251 models out of 9,758 models recorded in WaterSense's
product database are showerheads that have a maximum flow rate of 1.8 gpm or
less.7

5	WaterSense product search as of June 2020.
https://lookforwatersenseepa.gov/products/

6	Steffensen, S. (2015). Staff Analysis of Water Efficiency Standards for
Showerheads. CEC-400-2015-027. Sacramento: Californa Energy Commission.

7 WaterSense product search as of June 2020.
https://lookforwatersenseepa.gov/products/


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Mr. Andrew Wheeler
July 24, 2020
Page 5 of 6

Figure 2. Number of Registered Showerhead Units in MAEDbS:







<1









































L





















"i











































	





























0	1,000 2,000 3,000 4,000 5,000 6,000 7,000 8,000 3,000

Model {n)

Data available through the CEC's appliance rulemakings, MAEDbS, and
WaterSense databases demonstrate that it is feasible and appropriate for the
WaterSense Program to update performance criteria for flushing urinals,
showerheads, and lavatory faucets to higher efficiency standards. In addition to
being used to monitor compliance, these databases provide useful research data
about energy consumption and product characteristics of regulated appliances.
This helps in the development of future standards and enables consumers to
compare efficiency of products that meet the standards. As the CEC investigates
new opportunities for water efficiency, we ask the EPA to align its specifications
with California's existing water efficiency standards.

Consumer Satisfaction Data

Regarding the request for information (RFI) on collecting consumer satisfaction
data to inform future decisions on WaterSense specifications and program
guidelines, the CEC believes that using consumer satisfaction as an evaluation
factor in the specification development process is inappropriate. Although
consumer satisfaction studies can provide some insight on performance of a
product, it is ultimately subjective. In contrast, product performance testing using
established methods that are accurate and repeatable ensures quality products
and ultimately consumer satisfaction.


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Mr. Andrew Wheeler
July 24, 2020
Page 6 of 6

The EPA has successfully approved specifications for seven products using
current specification guidelines.8 The program guidelines specify that products
shall be evaluated on potential water savings, performance, technical feasibility,
and cost-effectiveness. Evaluating the technical feasibility and performance of a
product as required by WaterSense's program guidelines, already encompasses
criteria that helps ensure consumer satisfaction.

The specification development process is a collaborative, iterative, and transparent
process. The WaterSense specifications reference existing, industry-approved
national standards as the basis for water efficiency and performance testing
methods. In cases where an existing industry-approved standard does not exist or
needs improvement to meet WaterSense's program guidelines, the EPA works
with standards organizations and industry stakeholders to develop test methods
that provide accurate and reproducible results that are representative of real-world
applications.

The CEC appreciates the opportunity to provide comments on this RFI related to
WaterSense specifications. If there are any questions about these comments,
please contact Jessica Lopez at (916) 654-5125 or at
Jessica. Lopez@energy.ca.gov

cc: Jessica Lopez, Appliances Office

Michael Murza, Office of the Chief Counsel

sWaterSense Program Guidelines, version 5.5, May 2020.

https://www.epa.gov/sites/production/files/2017-02/documents/ws-program-

guidelines.pdf

Sincerely,

David Hochschild
Chair

California Energy Commission


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Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Denise L. Schmidt, Administrator of the Division of Water Utility Regulation
and Analysis, and Kristy Nieto, Administrator of the Division of Digital Access, Consumer
and Environmental Affairs

Affiliation: Public Service Commission of Wisconsin

Comment Date: July 24, 2020

Document ID: EPA-HQ-OW-2020-0026-0100

Comment Text:

Comment submitted by Denise L. Schmidt, Administrator of the Division of Water Utility
Regulation and Analysis, and Kristy Nieto, Administrator of the Division of Digital
Access, Consumer and Environmental Affairs on behalf of the Public Service
Commission of Wsconsin.

Attachment

See pages 240 and 241.

4

EPA

WaterSense

239

August 2020


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Public Service Commission of Wisconsin

Rebecca Cameron Valcq, Chairperson
Ellen Nowak, Commissioner
Tyler Huebner, Commissioner

4822 Madison Yards Way
P.O. Box 7854
Madison, WI 53707-7854

July 24, 2020

Mr. Andrew Wheeler, Administrator
US Environmental Protection Agency

Re:

EPA-HW-OW-2020-0026 WaterSense Program

Dear Administrator Wheeler:

Thank you for the opportunity to comment on consumer satisfaction regarding the EPA
WaterSense program. The Public Service Commission of Wisconsin (Commission) is the
financial and consumer protection regulator for over 570 water utilities in the State. As part of
our role, we ensure that water utility conservation and efficiency programs reduce water use,
water loss, and energy consumption. Achieving each of those goals provides cost effective
outcomes for the utilities and the customers they serve. The WaterSense program has been an
indispensable tool for the Commission in helping Wisconsin water utilities achieve resource and
financial sustainability goals.

WaterSense provides a tested and trusted source of information for Wisconsin water utilities and
their customers. As such, utilities are required to use WaterSense certified products in
Commission-approved water efficiency rebate programs. The list of products that meet
WaterSense standards streamlines the work of Commission and utility staff and provides an
objective, consistent source of information for all stakeholders. Using WaterSense program
materials reduces the cost both of approving and implementing conservation and efficiency
rebate programs. Utilities throughout Wisconsin rely on the resources and tools available through
WaterSense to design their programs and communicate with their customers.

Without the WaterSense program, Commission staff would need to invest time and resources in
order to ensure ratepayer funded conservation and efficiency programs deliver in terms of both
performance and efficiency. The void of a trusted third party resource would result in costly,
unnecessarily duplicative efforts by the Commission, utilities across the state of Wisconsin, and
water utilities nationwide.

Water and energy are uniquely linked. Water savings not only protect water supplies and reduce
customers' water utility bills, but also reduce the energy required to extract and deliver water to
customers, resulting in lower energy utility bills. The Commission has statutory oversight of
Focus on Energy, Wisconsin's utility-funded energy efficiency and renewable resource program.
Focus on Energy incentivizes the adoption of a variety of energy saving devices and
technologies, including devices designed to save customers both water and energy. Focus on
Energy offers customers free or discounted WaterSense labeled faucet aerators and showerheads.
The WaterSense label provides program participants the assurance that the products will meet

Telephone: (608) 266-5481	Fax: (608) 266-3957

Home Page: http://psc.wi.gov	E-mail: pscrecs@wisconsin.gov


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Mr. Andrew Wheeler
Page 2

performance expectations and deliver reliable water and energy savings. Year-after-year, Focus
on Energy has seen high customer satisfaction with the offerings designed to save customers
energy and water.

The Public Service Commission of Wisconsin supports the continued use of the WaterSense
label. The Commission appreciates the opportunity to comment in support of the WaterSense
program and thanks EPA for the continued efforts to improve the standards of water
conservation, efficiency and performance.

Sincerely,

Denise L. Schmidt

Division Administrator

Water Utility Regulation & Analysis

Kristy Nieto
Division Administrator

Digital Access, Consumer & Environmental Affairs

DS:KN:RJP:kle DL:01753450


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Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Jennifer L. Jurado, Director and Chief Resilience Officer
Affiliation: Broward County's Environmental Planning and Community Resilience
Division

Comment Date: July 24, 2020
Document ID: EPA-HQ-OW-2020-0026-0101

Comment Text:

Please see attached from Broward County's Environmental Planning and Community
Resilience Division

Attachment

See pages 243 and 245.

4

EPA

WaterSense

242

August 2020


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ENVIRONMENTAL PROTECTION AND GROWTH MANAGEMENT DEPARTMENT
ENVIRONMENTAL PLANNING AND COMMUNITY RESILIENCE DIVISION

115 S. Andrews Avenue, Room 329H • Fort Lauderdale, Florida 33301 • 954-519-1270 • FAX 954-519-1496

July 24, 2020

Environmental Protection Agency
1300 Pennsylvania Avenue
Washington, D.C. 20004
Attn: Andrew Wheeler

Subject: Comments on Docket ID No. EPA-HQ-OW-2020-0026 Request for Information on the
WaterSense® Program

Dear Administrator Wheeler:

On behalf of Broward County's Environmental Planning and Community Resilience Division, I
am writing to express our strong support for the Environmental Protection Agency's (EPA)
WaterSense® Program, in response to the Notice of Recent Specifications Review and Request
for Information. Thank you for the opportunity to comment on this essential program.

The WaterSense® Program has provided the platform to save trillions of gallons of water and
billions of kilowatt hours of energy. The Program's products have resulted in exceptional
performance, savings on water bills, and the opportunity to delay investments in alternative
water supplies. The program provides tangible savings for residents and businesses and has a
demonstrated track record of success. Therefore, we take the stance that the specifications
should not include customer satisfaction criteria without first conducting adequate research and
analyses. The program, as it currently operates, has been successful in conducting third party
testing and providing a service to the public. Moreover, in a recently conducted survey in
Broward County, almost 80% of people responded that they are "very satisfied" or "satisfied"
with their high efficiency toilet.

Broward County has multiple water conservation programs that rely on WaterSense®
specifications and branding. Below you will find some accomplishments:

•	We use the WaterSense® specifications for recommendations for local residential and
commercial properties.

•	Since 2011, the Broward Water Partnership, a joint partnership between the County and
several local municipalities and utilities, has saved over 2.5 billion gallons of through the
distribution of WaterSense® labeled showerheads and aerators and providing toilet
rebates.

•	Based on an informal survey conducted to Broward County residents, over 80% are
either satisfied or highly satisfied with their WaterSense® labeled toilet(s).

Broward County Board of County Commissioners
Mark D. Bogen • Lamar P. Fisher • Beam Furr • Steve Geller • Dale V.C. Holness • Nan H. Rich • Tim Ryan • Barbara Sharief • Michael Udine

Broward.org


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• One of our water conservation programs, the Broward County NatureScape Irrigation
Services program has been able to provide rebates to successfully install over 70
WaterSense® labeled controllers and sprinklers in a new program that is less than 1
year old.

Due to the local, regional, and national success of the WaterSense® program, Broward
County's Environmental Planning and Community Resilience Division believes that customer
satisfaction criteria do not belong in WaterSense® product specifications themselves. Instead,
we recommend that further revisions to any specifications center on adequate study, research,
and a focus on future needs.

Thank you for doing your utmost to ensure that this inexpensive, valuable, and effective
program continues to deliver.

JENNIFER L.JURADO, PH.D., DIRECTOR and CHIEF RESILIENCE OFFICER
Environmental Protection and Growth Management Department
ENVIRONMENTAL PLANNING AND COMMUNITY RESILIENCE DIVISION

115 S Andrews Ave, Room 329-H | Fort Lauderdale, Florida 33301
954.519.1464 (o) 954.520.1086 (c)

BROWARD

' COUNTY


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Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Kerry Stackpole, Chief Executive Officer (CEO) and Executive Director

Affiliation: Plumbing Manufacturers International (PMI)

Comment Date: July 24, 2020

Document ID: EPA-HQ-QW-2020-0026-0102

Comment Text:

Please find attached Plumbing Manufacturers International comments in regards to
EPA's Request for Information (RFI) on the WaterSense Program.

Attachment

See pages 246 and 250.

4

EPA

WaterSense

245

August 2020


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pmi

PLUMBING
MANUFACTURERS
INTERNATIONAL »

July 24, 2020

The Honorable Andrew Wheeler
Administrator

U.S. Environmental Protection Agency
1200 Pennsylvania Ave, N.W.

Washington, D.C. 20460

Subject: Request for Information on the EPA WaterSense Program - Consumer Satisfaction [Docket
No. EPA-HQ-OW-2020-0026]

Dear Administrator Wheeler:

On behalf of Plumbing Manufacturers International (PMI), we appreciate the opportunity to submit
comments concerning the Environmental Protection Agency's (EPA) Request for Information on the
agency's WaterSense program published in the Federal Register on April 10, 2020 (FR Vol. 85, No. 70,
page 20268).

The agency is specifically requesting comments on:l) data, surveys, or studies to help assess consumer
satisfaction with WaterSense-labeled products, which could inform future product specification
development; 2) input on how to design a study or studies to inform future reviews that incorporate
customer satisfaction considerations; and, 3) advice on whether the agency should include consumer
satisfaction criteria in the WaterSense program guidelines and, if included, what criteria should be
considered and how.

PMI and its members have been proud supporters of the WaterSense program since its inception in
2006. A true public-private partnership, WaterSense is a voluntary product efficiency labeling program
that identifies efficient and high-performing water-saving products. It has resulted in strong consumer
and industry confidence in and reliance on, as well as broad stakeholder support for, WaterSense-
labeled products.

Sales of WaterSense products and the number of WaterSense-labeled products have continued to
increase year after year. In fact, the program has grown significantly since 2007, when the first
WaterSense-labeled products-high-efficiency toilets of 1.28 gallons per flush or less, and bathroom
sink faucets of no more than 1.5 gallons of water per minute - were made available to consumers. Just
120 toilet models and 30 models of faucets and faucet accessories earned the WaterSense label in
2007.1 Today, more than 34,000 WaterSense plumbing product models are available, according to the
WaterSense 2019 Accomplishments Report.2 The program has been expanded beyond toilets and
faucets to include showerheads, urinals, commercial pre-rinse spray valves, and landscape irrigation
controllers and sprinklers.

12007 Accomplishments, EPA's WaterSense® Program: Making Water Efficiency Easy, U.S. Enviromnental Protection
Agency, Office of WaterSense, April 2008, https://www.epa.gov/sites/production/files/2017-02/documents/ws-aboutus-
2007-accomplishments.pdf

2WaterSense Accomplishments 2019. U.S. Enviromnental Protection Agency, Office of WaterSense, EPA-832-R-20-002 -
June 2020, https://www.epa.gov/sites/production/files/2020-07/documents/ws-aboutus-
2019 watersense accomplishments.pdF


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When consumers look for the WaterSense label, they know they will find a product that performs well,
conserves water, and saves money. Using water more efficiently will conserve supplies now and for
future generations.

PMI has provided comments to the questions posed by EPA in the RFI, which are found in our
attachment. In response to those questions, PMI concluded that:

¦	Should EPA revise existing specifications or create new product specifications in the future, then
PMI believes that customer satisfaction data is one consideration that should be taken into account
during the performance criteria evaluation process.

¦	We believe there are reasonable uses for customer satisfaction information within WaterSense, but
caution should be exercised in developing any such study because of a variety of factors, which we
explain in our response. Additionally, we firmly believe the key WaterSense stakeholders must be
allowed to provide input before any consumer satisfaction survey is released publicly.

PMI is the nation's leading trade association for the plumbing fixtures and fittings manufacturing
industry. Producing 90 percent of the United States' plumbing products and representing more than 150
brands, PMI's members are industry leaders in manufacturing innovative, reliable and water-efficient
plumbing products and related supplies.

Our highly-engineered plumbing products, sold and distributed in all 50 states, include toilets, kitchen
and bathroom faucets, showerheads, bathtubs, sinks, urinals, drinking fountains, and eye wash stations,
as well as hundreds of types of components, and valves and piping, which are key to our nation's
indoor plumbing systems. These products are readily available at home improvement stores, hardware
stores and showrooms in all 50 states, as well as online. Our members supply these products to
residential, commercial, and not-for-profit customers, including schools, hospitals, nursing homes,
restaurants, hotels, manufacturing facilities, correctional facilities, and military bases.

Today, plumbing manufacturers, along with their wholesale and retail partners, contribute $85 billion to
the U.S. economy, provide more than 460,000 jobs, generate $26 billion in wages, and pay $11 billion
in tax revenues.

PMI values our partnership with WaterSense and appreciates the opportunity to provide these
comments. Please do not hesitate to reach out to us with any questions.

Kerry Stackpole
CEO/Executive Director
Plumbing Manufacturers International
kstackpole@safeplumbing.org

cc: David Ross, Assistant Administrator, Office of Water

D. Lee Forsgren, Deputy Assistant Administrator, Office of Water
Andrew D. Sawyers, Director, Office of Wastewater Management

Sincerely,

2


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ATTACHMENT

PMI Comments on EPA's WaterSense Request for Information on
Consumer Satisfaction- EPA-HQ-QW-2020-0026

The agency is specifically requesting comments on:l) data, surveys, or studies to help assess consumer
satisfaction with WaterSense-labeled products, which could inform future product specification
development; 2) input on how to design a study or studies to inform future reviews that incorporate
customer satisfaction considerations; and, 3) advice on whether the agency should include consumer
satisfaction criteria in the WaterSense program guidelines and, if included, what criteria should be
considered and how.

Overview

Plumbing Manufacturers International (PMI) has been a strong proponent of the U.S. Environmental
Protection Agency's (EPA) WaterSense program since its inception more than a decade ago. We are
proud of how this voluntary public-private partnership that develops specifications for water-efficient
plumbing products has evolved and how it offers consumers a straightforward way to make product
choices that use less water, without sacrificing quality or product performance.

Consumer, utility, state and local government, and private sector support for the program has grown not
only due to the program's successful outcomes, but also because of the quality and integrity of the
products bearing the WaterSense label, which are the result of federal government oversight and
independent, third-party certification.

The program has created a water efficiency benchmark for plumbing products that has allowed
plumbing manufacturers to confidently invest millions and millions of dollars in product development
and marketing initiatives.

Thanks to the collaborative nature of the WaterSense partnership and its national scope, not only
manufacturers, but consumers, retailers, utilities, and state and local governments have been able to use
this program effectively. Key examples include:

¦	The popularity of the program is proven by its growth. Plumbing manufacturers have expanded
the number and types of WaterSense products from 150 labeled products in 20 073to more than
34,000 products by 2019, according to the most recent WaterSense 2020 Accomplishments
Report.4

o WaterSense-labeled product models have been expanded to include a wide variety of toilets,
showerheads, faucets, faucet accessories, urinals, commercial kitchen faucets, and landscape
irrigation controllers.

¦	WaterSense offers a recognizable label for consumers who are seeking to identify and
considering purchasing water-efficient plumbing products for homes, schools, restaurants, and other
commercial businesses that conserve water with no sacrifice to quality or performance.

32007 Accomplishments, EPA's WaterSense® Program: Making Water Efficiency Easy, U.S. Enviromnental Protection
Agency, Office of WaterSense, April 2008, https://www.epa.gov/sites/production/files/2017-02/documents/ws-aboutus-
2007-accomplishments.pdf

4WaterSense Accomplishments 2019. U.S. Enviromnental Protection Agency, Office of WaterSense, EPA-832-R-20-002 -
June 2020, https://www.epa.gov/sites/production/files/2020-07/documents/ws-aboutus-
2019 watersense accomplishments.pdF

3


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¦	Rather than having state and/or local officials make their own determination on how to achieve
more water efficiency than federal minimum standards, WaterSense provides the national
specifications agreed to by key stakeholders, including plumbing product manufacturers and the
federal government. The WaterSense label is the government and industry's guarantee to consumers
and other purchasers that the products meet those specifications.

¦	The program's water-savings results are measurable. The WaterSense program has saved $4.4
trillion gallons of water, and consumers have saved $87 billion of water and energy expenses since
2007.5

¦	KB Home, one of the largest home builders in the nation, constructs homes optimized for water
conservation. As of 2019, the company has built more than 15,000 WaterSense-labeled and
Water Smart homes and installed more than 600,000 WaterSense-labeled fixtures.6

¦	Public and private utilities in all 50 states tailor successful water conservation programs
around consumer use of WaterSense-labeled products, including rebate programs7to encourage the
utilization of WaterSense-labeled products.

¦	As many states face severe drought conditions, WaterSense is helping consumers reduce their
water use and conserve water.

¦	Plumbing fixture performance has improved significantly since the advent of WaterSense.
Manufacturers continue to develop new, innovative, and technologically driven plumbing product
models.

¦	More and more consumers are focused on minimizing their carbon footprint and placing
more emphasis on "green" products and homes, including water-saving plumbing products.

¦	More than 2,000 WaterSense partners, including all major U.S. plumbing manufacturers,
consumer groups, water utilities, builders, retailers, distributors, water efficiency advocates, and
communities, collaborate with EPA to make this a successful program.

Below you will find PMI's specific comments concerning the collection of consumer satisfaction data.

Response to EPA Questions on Consumer Satisfaction

1. EPA is seeking input and requesting information on any data, suri'eys, or studies to help assess
consumer satisfaction with WaterSense-labeled products.

a.	There are numerous public sources of data relating to consumer satisfaction of WaterSense-
labeled plumbing products. Product reviews can be found online through retailer websites (e.g.,
home improvement stores), online marketplaces such as Amazon and Build.com, independent
reviews by Consumer Reports, Home Advisor, and home improvement magazines, and on some
individual manufacturer's websites.

b.	Plumbing manufacturers gather consumer input at various times in the development and the
lifecycle of a plumbing product as part of a broader product development plan. For example,
consumer feedback can take place during field trials, when a product is brought to the
marketplace, from the abundance of online reviews, as well as in the early development stages.
However, to the extent that manufacturers have consumer satisfaction data on WaterSense or
non-Water Sense plumbing products, such information is considered confidential and
proprietary.

5WaterSense Accomplishments 2019, U.S. Environmental Protection Agency, Office of WaterSense, EPA-832-R-20-002 -
June 2020, https://www.epa.gov/sites/production/files/2020-07/documents/ws-aboutus-
2019 watersense accomplishments.pdF

6KB Home Wins 2019 WaterSense Sustained Excellence Award for Advancing Water Efficiency, Business Wire, October 4, 2019,

https://www.bloomberg.eom/press-releases/2019-10-04/kb-home-wins-2019-watersense-sustained-excellence-award-for-

advancing-water-efficiencv

7Don't flush money down the toilet - Durham program offers money for toilet upgrades, ABC11, J Wilson, January 28, 2020
- https://abc 11 .com/toilets-watersense-durham-nc/5879675/

4


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c. Should EPA revise existing specifications or create new product specifications in the future,
then PMI believes consumer satisfaction data is one consideration that should be taken into
account during the performance criteria evaluation process. For example, past specification
processes included consumer satisfaction data submitted during the stakeholder public comment
period by third parties, as well as data gathered by EPA.

2. The EPA also is seeking input on how to design a study or studies to inform future reviews that
incorporate customer satisfaction considerations.

a.	An EPA-conducted customer satisfaction survey could capture consumer understanding and
evaluate brand recognition and perception of the WaterSense label and program, such as
satisfaction with water and energy savings. But attempting to focus on individual product
performance would be challenging^ because performance is influenced by numerous
variables including individual product design and engineering, the age of the home and/or
building and the municipal plumbing systems. These critical factors impact water pressure
and drain line carry. The majority of consumers don't fully understand their plumbing
systems and are most likely unaware of how these issues influence product performance.

b.	Product-focused surveys can be difficult for consumers to differentiate a product-specific
feature versus a water efficient/WaterSense-related feature. For example, is the consumer
responding to satisfaction with the performance of the product's efficiency or is the
response based on aesthetic issues? Survey questions may not be able to ascertain such
distinctions.

c.	It is important to know whether the customer is a renter or owner. Renters likely would not
have purchased the plumbing products and thus would not have any decision in the
selection. Owners, however, have the purchasing power and control over the types of
plumbing products that are installed.

d.	Caution should be used when collecting and/or reviewing customer satisfaction comments
about WaterSense products because results can be skewed based on how the questions are
asked and which customers are responding.

e.	A consumer satisfaction survey should have input from the key WaterSense stakeholders
before being publicly distributed.

The WaterSense brand and program deliver value on many levels, creating efficiency targets for
manufacturers, measurable and significant gains in water use that utilities and regulators can count on,
and a recognizable label the consumer can look for when purchasing products. Annual water and
energy savings continue to rise, resulting in a significant financial benefit to both consumers and to
water, sewer, and energy utilities. PMI is proud of our ongoing WaterSense partnership and the
thousands of plumbing products manufactured under this successful program.

PMI Members

*Bradley Corporation *CSA Group *Delta Faucet Company *Duravit USA
*Fisher Manufacturing Company *Fluidmaster, Inc. *Franke *Global OEM *Globe Union Group
*Hansgrohe*Haws Corporation *IAPMO * International Code Council Evaluation Service *KEROX *Kohler Co

* Lave lie Industries, Inc. *1.1X11. *Moen Incorporated *NEOPERL, Inc.

*NSF International *Pfister *Reliance Worldwide Corporation *Similor AG * Sloan Valve Company *Speakman
Company * Sprite *Symmons Industries, Inc. *T & S Brass and Bronze Works, Inc.*TOTO USA *UL LLC

*Viega LLC *WaterPik *WCM Industries, Inc.

Plumbing Manufacturers International I 1750 Tysons Blvd. I Suite 1500 | Tysons Corner, VA 22102

Tel: 847-481-5500 - Visit us at www.safeplumbing.org

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EPA

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

WaterSense

Commenter: Medea Villere
Affiliation: General Public
Comment Date: July 24, 2020
Document ID: EPA-HQ-OW-2020-0026-0103

Comment Text:

I am urging the US EPA to remain committed to fully supporting the continuation of this
successful program (WaterSense). Since its creation in 2006, the WaterSense program
has saved more than 4.4 trillion gallons of water. The program has saved users more
than $87 billion in water and energy bills during that time. WaterSense still saves U.S.
residents billions of gallons of water every year, with 871 billion gallons saved in 2019
alone. Please refrain from using consumer satisfaction ratings as a factor in WaterSense
certification. Product performance alone should govern the certification.

251

August 2020


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WaterSense

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: N/A

Affiliation: Plumbing Industry Leadership Coalition (PILC) et al.

Comment Date: July 24, 2020

Document ID: EPA-HQ-OW-2020-0026-0104

Comment Text:
See attached file(s)
Attachment

See pages 253 through 255.

252

August 2020


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IJI

PLUMBING INDUSTRY LEADERSHIP COALITION
July 24, 2020

Mr. Andrew Wheeler
Administrator

US Environmental Protection Agency
Washington, DC

Subject: Comments on Docket ID No. EPA-HQ-OW-2020-0026 - Request for Information on the
WaterSense® Program

Dear Administrator Wheeler:

The Plumbing Industry Leadership Coalition (PILC) is a cross-sectional representation of executives
from the plumbing industry in the United States. The PILC is comprised of the largest and most
influential associations, professional societies, nonprofits and third-party certification bodies
representing manufacturers, plumbers' unions, contractors, engineers and water efficiency
experts. The undersigned PILC member organizations appreciate the opportunity to comment
regarding the U.S. EPA WaterSense Program in response to the Notice of Recent Specifications
Review and Request for Information on the WaterSense Program published on April 10, 2020 in the
Federal Register.

We'd like to preface our comments by stating that the entire breadth of the plumbing industry in the
United States fully supports the WaterSense program. Despite its meager funding levels, the
WaterSense program is a model of a successful public-private sector partnership. Independent
research on residential water use and has shown that WaterSense labelled products are performing
well. To date, over 3.4 trillion gallons of valuable potable water have been saved since the
introduction of the program in 2006 resulting in over $84 billion in water, sewer and energy bill
savings for American consumers. Very few government programs yield such profound benefits to
industry, consumers and the environment.

Regarding the EPA's request for specific commentary in the Federal register, the PILC offers the
following comments:

1. Should the EPA include customer satisfaction criteria in the WaterSense specification and
guidelines?

The PILC recommends that such criteria not be included in the program's specifications and
guidelines. While such information might provide insights into the user experiences with
WaterSense labeled products, writing satisfaction criteria into the specifications would be
problematic. Rather, the PILC recommends that consumer satisfaction research be conducted by
independent, qualified organizations capable of developing surveys that are scientifically developed
to eliminate biases.

However, the PILC recognizes that the best measure of consumer satisfaction is the market place
itself. Manufacturers of plumbing products compete every day for American consumer dollars.

1


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IJI

PLUMBING INDUSTRY LEADERSHIP COALITION

Products that do not perform to consumer expectations are readily eliminated from the competitive
marketplace.

2.	How should the EPA design studies to inform future reviews that might incorporate
customers satisfaction considerations?

The plumbing industry understands that measuring customer satisfaction, especially as it pertains to
plumbing products, is difficult to accurately measure, especially through the use of surveys. User
perceptions are shaped by many variables, including brand selection, problems encountered with
the installation of the product that are specific to a given installation, conditions particular to the
plumbing system or water distribution system (such as supply pressure and water hardness), and
appearance.

Importantly, consumer opinions on the use of products that are considered environmentally friendly
or "green", have unfortunately become increasingly polarized due to political discussions. These
biases are real and will be difficult to overcome when measuring consumer satisfaction. Thus, any
studies that seek to inform such reviews would need to take this into account.

3.	What information, data, surveys, and studies are available to help assess customer
satisfaction with WaterSense labelled products which could help inform future product
specifications?

Due to the difficulties with measuring customer satisfaction, as discussed above, we are not aware
of any scientific surveys or studies that were specifically developed to measure customer satisfaction
with WaterSense labelled products. However, a great deal of data exists on the performance of
WaterSense labelled toilets.

The well-established MaP Testing (Maximum Performance Testing) began testing 1.6 gallon per flush
toilets (gpf) in 2003, prior to the introduction of the EPA's WaterSense program, in response to
complaints of poor performance on some early 1.6 gpf toilet models. Since then, the market has
transitioned to High Efficiency Toilets (HETs) that flush at 1.28 gpf, a 20% reduction from 1.6 gpf
models. Today, almost 3400 toilet models have been voluntarily submitted for testing by
manufacturers and the published MaP results over the years clearly indicates that performance has
continuously improved. Many of today's HETs are capable of flushing over 1000 grams of test media
and toilet paper, providing performance that exceeds consumer expectations despite the transition
to HETs.

It should also be noted how the WaterSense program has impacted and advanced industry
standards in recent years. Tests that were originally developed through the WaterSense specification
process have been considered and have been incorporated into industry standards. For example,
when the WaterSense specification on water efficient showerheads was developed, two
performance tests were included in that specification that investigated spray coverage area and
spray force, attributes that directly relate to consumer satisfaction. Both tests were later
incorporated into the ASME A112.18.1 / CSA B125.1 industry standard for all showerheads.

2


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iJ\K

PLUMBING INDUSTRY LEADERSHIP COALITION

4. Comments on EPA's Recent review of the WaterSense program.

The PILC supports the EPA's decision to not revise current WaterSense specifications for water
efficient plumbing products. While lower flow rates and water consumption values may be
technically achievable, research is required to better understand the resulting impacts on
infrastructure and the relationship between reduced flows and declining water quality, as discussed
in NIST's Measurement Science and Research Needs for Premise Plumbing Systems report. The PILC is
equally opposed to any revisions to WaterSense specifications that would increase flow rates or
consumption values. Such changes would harm the WaterSense program and would add to the
proliferation of new regulations that mandate new water efficiency requirements at State and local
levels and would result in considerable market confusion.

On behalf of all PILC member organization, we thank the EPA for their commitment to water
efficiency and their consideration of the concerns of the U.S. plumbing industry.

Sincerely,

Alliance for Water Efficiency
American Society of Plumbing Engineers (ASPE)

American Supply Association (ASA)

American Society of Sanitary Engineering
Copper Development Association Inc.

International Association of Plumbing and Mechanical Officials (IAPMO)

International Code Council (ICC)

Mechanical Contractors Association of America (MCAA)

Mechanical Hub

Plumbing Contractors of America (PCA)

Plumbing-Heating-Cooling Contractors—National Association

Plumbing & Mechanical Group (BNP Media, Inc.)

Plastic Pipe and Fittings Association (PPFA)

Plumbing Industry Leadership Coalition (PILC)

The American Rainwater Catchment Systems Association (ARCSA)

The United Association of Journeymen and Apprentices of the Plumbing and Pipe Fitting Industry of
the United States, Canada (UA)

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WaterSense

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: David Searcy, Conservation Coordinator
Affiliation: Medford Water Commission
Comment Date: July 24, 2020
Document ID: EPA-HQ-OW-2020-0026-0105

Comment Text:
See attached file(s)
Attachment

See page 257.

256

August 2020


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MEDFORD WATER COMMISSION

July 24, 2020

Mr. Andrew Wheeler
Administrator

US Environmental Protection Agency
Washington, DC

RE: Comments on Docket ID No. EPA-HQ-OW-2020-0026
Request for Information on the WaterSense®

Program Dear Administrator Wheeler:

In 1922 the 12,000 citizens of Medford Oregon wanted a better solution for their water system, thus
Medford Water Commission (MWC) came into being. Today MWC serves over 130,000 people. Our
Conservation Program has been in existence since the mid 1990's practicing "Conservation Without
a Crisis" beginning with outdoor landscape irrigation evaluations. In 2009 MWC Toilet Rebate
Program was launched based on the success of the EPA Water Sense labeling program with third
party MaP testing. Prior to that, low flush toilets were quite unreliable, even at 1.6 gallons per flush
(gpf). WaterSense set a higher standard for manufacturers with a maximum 1.28 gpf while able to
flush a minimum 12 ounces of solids. Consumers could believe in the Water Sense Ultra Low Flow
toilets.

Over the past 20 years MWC's population served has grown by 25% while our gallons produced has
gone up by only 10%. Our Conservation program using Water Sense labeled products has allowed
MWC to keep our cost of delivery down, therefore a lower cost to our customers, as well as a lower
water bill because of less gallons consumed.

In the past 10 years of our Toilet Rebate Program there have been only two issues brought up
during our premise inspection of the installed toilets. In neither case was it a product issue. Both
times were installation issues: One a clogged roof vent pipe and the second a rubber band from the
packing that had not been removed. In each case when the issue was resolved, the customers were
satisfied with their new ultra-low flow toilets.

MWC's Toilet Rebate Program has enjoyed great success over the years as satisfied customers tell
their friends, neighbors and family. To date MWC has processed over 2,000 toilet rebates that
translates to almost 9 million gallons of water saved in one year.

Thank you for doing your utmost to ensure this inexpensive, valuable, and effective program that
continues to deliver for the American people.

Sincerely,

David Searcy
Conservation Coordinator

Wl 00% Post-Consumer Recycled Fiber

200 S. Ivy Street Room 1 7 /
Medford, Oregon 97501
Phone (541) 774-2430

www.medfordwater.org
water@medfordwater.org
Fax (541) 774-2555


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WaterSense

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Candice Rupprecht, Water Conservation Manager

Affiliation: City of Tuscon (Arizona)

Comment Date: July 24, 2020

Document ID: EPA-HQ-OW-2020-0026-0106

Comment Text:

Comment submitted by Candice Rupprecht, Water Conservation Manager, City of
Tucson

Attachment

See pages 259 and 260.

258

August 2020


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July 24, 2020

Mr. Andrew Wheeler
Administrator

Environmental Protection Agency
1200 Pennsylvania Ave NW
Washington, DC 20460

Dear Administrator Wheeler:

As the water conservation manager for Tucson, Arizona, a city that is a proud national leader in
water conservation, I am writing express support for the EPA's WaterSense program.
WaterSense, as a voluntary federal program, has had remarkable success in just over a decade.
Operating with a small staff and budget, the program has transformed the market for plumbing
fixtures and irrigation controllers, saving American consumers over 4.4 trillion gallons of water
and more than $87 billion in water and energy bills. In Tucson, water rates are 15% lower today
due to decades of water conservation as a result of not needing to acquire and treat additional
water supplies. Like many cities across the county, Tucson has reduced its total use by 31%
while population grew by 40%. One of the strongest drivers of water conservation is through
adoption of technology that increases efficiency. WaterSense ensures that increases in
efficiency of these conservation devices does not impact performance. In fact, establishing
product specifications to meet WaterSense requirements has often increased fixture
performance.

Tucson Water, along with over 2,000 organizations across the county, is a proud partner of the
EPA's WaterSense program. There is consensus across sectors that WaterSense is a wise
investment toward ensuring resource sustainability in our communities. Like many water
providers across the county, Tucson Water depends on the WaterSense program's product
labeling criteria to identify rebate-eligible products. To date, rebates relying on WaterSense
criteria have saved Tucsonans 500 million gallons of water!

WaterSense has ensured national consistency in rebate programs and product quality that
meet rigorous standards; high-quality products and a common language, similar to EnergyStar,
have elevated the conversation about water efficiency and conservation to a national platform.
WaterSense is a necessary partner in effectively administering water conservation incentive
programs and their standards-based approach has resulted in strong support for the
manufacturing and retail partners that develop and sell WaterSense-certified products. The
R&D invested in WaterSense products cannot be understated; these specifications have driven
innovation that has saved our country billions of dollars. Adding customer satisfaction criteria
to what is currently a measured, analytical approach to determining product eligibility will
devalue the science and engineering process and convolute otherwise straightforward
requirements. Customer satisfaction has no place in establishing federal standards for fixture

Public Information and Conservation Office • P.O. Box 27210 • Tucson, AZ 85726-7210

520.791.4331 • tucsonaz.gov/water


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performance; this should be left to manufacturers and consumers when selecting among
products that have all met the same criteria.

I offer my strong support for the WaterSense program, including the effective education and
outreach that have been developed and the specifications that have been rigorously researched
and evaluated to determine WaterSense product labeling. WaterSense brand recognition is
strong throughout the country, symbolizing efficient and effective products that save American
consumers dollars and protect our country's water supplies.

Sincerely,

Candice Rupprecht
Water Conservation Manager
Tucson Water
City of Tucson

Public Information and Conservation Office • P.O. Box 27210 • Tucson, AZ 85726-7210

520.791.4331 • tucsonaz.gov/water


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WaterSense

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: John Farner, Government and Public Affairs Director

Affiliation: Irrigation Association

Comment Date: July 24, 2020

Document ID: EPA-HQ-OW-2020-0026-0107

Comment Text:
See attached file(s)
Attachment

See pages 262 and 263.

261

August 2020


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\

Irrigation

"association

8280 Willow Oaks Corporate Drive | Suite 4001 Fairfax, VA 22031

Tel: 703.536.70801 Fax: 703.536.7019

www.irrigation.org

Docket ID Number: EPA-HQ-OW-2020-0026

Recent Specifications Review and Request for Information on WaterSense Program
July 24 2020

The Honorable Andrew Wheeler

Administrator, U.S. Environmental Protection Agency

Dear Administrator Wheeler:

On behalf of the approximate 1,600 member companies of the Irrigation Association, I am writing to
notify you of our continued support for the EPA's WaterSense program, in response to the review of
WaterSense product performance criteria as required under the America's Water Infrastructure Act
(AWIA) of 2018.

Since its inception in 2006, WaterSense has served as a successful public-private partnership. The
collaboration between industry, public and private water providers, along with the federal government,
has helped expand the water efficient product marketplace. As our nation works to develop ways to
address water shortages and its aging infrastructure system, the successes of the WaterSense program
should not be overlooked.

The Irrigation Association collaborated with the EPA and other NGOs to create the WaterSense program.
Driven by our mission statement, to promote efficient irrigation, the Irrigation Association represents
experts in all aspects of irrigation, including agriculture, landscape, turfgrass and golf, among others.
Irrigation manufacturers, distributors and contractors have proudly partnered with WaterSense since its
inception to strengthen the marketplace for efficient water-use technologies and practices.

As you are well aware, WaterSense is a non-regulatory, voluntary program that is not duplicative of any
programs offered by the federal government, relating to turfgrass and landscape irrigation. This national
effort allows for the elimination of possible federal regulations that could burden both consumers and
industry. The voluntary water-efficient performance measures created by WaterSense allow
manufacturers to better plan and allocate resources.

Page 1 of 2


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Local entities can then determine how best to proceed with promoting water-efficient products in their
communities, showing a true commitment to federalism. Local water authorities, utilities, and city
governments to encourage the use of WaterSense-labeled products through various rebates.

In addition to having industry support for the program, the Irrigation Association has been an official
WaterSense partner since the program's inception. Having certified the most irrigation professionals
through our WaterSense labeled irrigation contractor, designer, and auditor certifications, we are
familiar with the benefits of WaterSense. With the WaterSense label for certification programs,
consumers are more aware of our certified irrigation professionals. This helps in the promotion of a
strong workforce that consumers can rely upon for industry expertise.

WaterSense is supported by consumers, manufacturers, and public and private agencies charged with
supplying water to American households and businesses. Thanks to WaterSense, American families and
businesses have greater access to water-efficient products, including irrigation controllers that can
reduce an average home's irrigation water use by more than 20 percent, while making irrigation system
management significantly easier to perform. This means that an average home can save nearly 8,000
gallons of water annually. Since 2006, indoor and outdoor WaterSense-labeled products have saved
more than 1.5 trillion gallons of water. The benefits of WaterSense directly affect the pocketbooks of
Americans - with $36.2 billion in water and energy bill savings. These savings have not gone unnoticed
by the consumers. In fact, these savings are a tool contractors, distributors and manufacturers use to
sell WaterSense-labeled technologies.

With that said, our only concern regarding the WaterSense program is the effort of various state
legislatures to make WaterSense-labeled technologies mandatory. The Irrigation industry
enthusiastically supports the continuation and growth of the WaterSense program, specifically the
voluntary aspect of the program. The IA also continues to participate in ANSI standard setting processes
for other irrigation technologies. There is room for both in the water efficiency discussion, but our
stance is that the WaterSense program should be leading the national discussion on water efficient
technologies and enhancing the market for these technologies. However, this label should remain
voluntary. This is crucial to the future success of the program.

Maintaining America's drinking water supply is also of concern. Water is one of our most precious
national resources. Reducing landscape water use, which can account for up to 70 percent in some parts
of the country, is a critical way we can help address the seasonal scarcity. As mentioned earlier, the
Irrigation Association's mission statement is to promote efficient irrigation. Our industry is at the cutting
edge of developing technologies and practices that are designed to significantly reduce the amount of
water used in landscapes across the U.S., while ensuring that Americans continue to enjoy all of the
benefits that managed landscapes have to offer.

Sincerely,

John Farner

Government and Public Affairs Director


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WaterSense

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Gregory J. Walch, Chairman
Affiliation: Western Urban Water Coalition
Comment Date: July 24, 2020
Document ID: EPA-HQ-OW-2020-0026-0108

Comment Text:

Attached please find the comments submitted by the Western Urban Water Coalition
(WUWC).

Thank you for your consideration of these comments.

Attachment

See pages 265 through 268.

264

August 2020


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WUWC

WESTERN URBAN WATER COALITION

July 24, 2020

Submitted via //www.regulations.gov/

Andrew Wheeler
Administer

Environmental Protection Agency

1200 Pennsylvania Avenue, NW, MC 4101M

Washington, DC 20460

RE: Comment on the "Notice of Recent Specifications Review and Request for

Information on WaterSense Program," 85 Fed. Reg. 20268 (Apr. 10, 2020), Docket
No. EPA-HQ-OW-2020-0026

The Western Urban Water Coalition (WUWC or Coalition) appreciates this opportunity to
comment on the U.S. Environmental Protection Agency (EPA) Notice of Recent Specifications
Review and Request for Information on WaterSense Program," 85 Fed. Reg. 20268 (Apr. 10,
2020).

WUWC was established in 1992 to address the West's unique water supply and water quality
challenges that threaten the economic sustainability and growth of the large western population
centers. WUWC consists of the largest urban water utilities in the West, who together serve more
than 40 million urban water consumers in 18 major metropolitan areas across seven states.1
Some of these utilities also operate wastewater, natural gas and electric, including hydroelectric,
facilities for their customers.

WUWC is committed to presenting a new and different perspective on the management and use
of water resources in the modern West. WUWC articulates the needs and values of Western
cities to provide a reliable, high quality urban water supply for present and future generations. As
operators of urban water supply systems, WUWC members serve the health, environmental, and
economic needs of their communities around the clock, every day of the year. WUWC advocates
for effective and practicable approaches to the development of new water supplies to increase
reliability and resiliency in a time when critical water supplies are becoming more scarce.

1 Arizona (Central Arizona Project, City of Phoenix and Salt River Project); California (Eastern Municipal Water
District, Los Angeles Department of Water and Power, The Metropolitan Water District of Southern California, San
Diego County Water Authority, Santa Clara Valley Water District, and City and County of San Francisco Public
Utilities Commission); Colorado (Aurora Water, Colorado Springs Utilities, and Denver Water); Nevada (Las
Vegas Valley Water District, Southern Nevada Water Authority, and Truckee Meadows Water Authority); New
Mexico (Albuquerque Bernalillo County Water Utility Authority); Utah (Salt Lake City Public Utilities); and
Washington (Seattle Public Utilities).


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A. General Comments

WUWC has historically been, and will continue to be, an ardent supporter of the goals of the
WaterSense Program and federal policy that strives to ensure the effective use of the nation's
water resources. WUWC strongly supports the EPA's development of the WaterSense Program
that strives to foster efficient use of water, and we commend its effort to support WaterSense as a
means of ensuring water availability and mitigating the risks of future drought and other water
supply challenges across the country. WUWC members have experienced high customer
satisfaction with the WaterSense program.

WUWC members are nonprofit public utilities dedicated to providing a reliable, high-quality
urban water supply. Water conservation is critical to WUWC members' efforts to meet current
and future demands in the arid, water-constrained West. Their mission is more critical now than
ever considering the essential role of clean water in combatting the spread of COVID-19 and
maintaining public health, livelihoods and sustenance during this time of crisis. Programs such as
WaterSense that promote an ethic of water efficiency to conserve water resources for future
generations and reduce water and wastewater infrastructure costs are now more important than
ever. WUWC strongly encourages the EPA to continue this successful and innovative
partnership program and stresses the critical importance to WUWC members that the EPA
receive permanent funding for WaterSense.

It is also important for the EPA to focus on the benefits and importance of water use efficiency
gains as a primary goal when developing specifications for future products, while also
acknowledging that the widespread adoption and use of products, industry and customer
perceptions of water use efficiency products, and the market penetration/adoption rate of
WaterSense products, will be heavily dependent on customer and industry attitudes and
perceptions toward WaterSense labeled products. Many states, including WUWC states, have
tied state water use efficiency language to WaterSense standards, so that incremental
improvements to WaterSense technologies and performance standards move utilities closer to
meeting their goals with little to no opposition or cost to their customers.

WUWC joins the Alliance for Water Efficiency (AWE) and other water organizations in the
submission of detailed comments submitted on the above-referenced docket on July 24, 2020.
WUWC members, experienced with the unique challenges facing the Western states, also offer
the following additional specific comments that could be beneficial in efforts to improve the
WaterSense Program.

B. Specific Comments

1. Increase standards for existing WaterSense devices

It is essential that efficiency standards of WaterSense products are increased over time,
consistent with what the Energy Star Program has done with a wide variety of products. WUWC
recommends that EPA use this opportunity to implement higher efficiency standards for existing
WaterSense products and devices—in line with improvements in technology and performance of
these devices. WUWC members have had rebate programs for water-efficient devices for
decades, and their current standards are often more efficient than the current WaterSense
standards. Overall customer satisfaction with these rebate programs has been high, and WUWC

2


-------
members have achieved significant reductions in indoor and outdoor water usage from the
installation of devices they rebate. WaterSense products that should have higher efficient
standards include:

•	High-efficiency toilets and urinals

•	Faucet aerators and low-flow showerheads

•	Weather-based irrigation controllers

2.	New devices for WaterSense certification

EPA should consider adding new devices for WaterSense certification that have a high potential
for water savings but are not currently a part of the program, including:

•	Rotating nozzles

•	Drip irrigation

•	Leak detection metering devices

WUWC also recommends that higher water efficiency standards be evaluated when higher
energy standards are considered for Energy Star products that use water, like clothes washers.

3.	Continued and collaborative use of studies and customer surveys, and use of
more recent information

While WUWC appreciates the goals and efforts of the WaterSense Program, we are concerned
that much of the information used by the EPA to frame its recommendations is anecdotal. We
recommend that EPA not only continue its use of studies and customer surveys to help educate
and shape the WaterSense Program, but also use more recent information and current
technological advances. For example, the Notice references a customer satisfaction survey
conducted by the Metropolitan Water District of Southern California in 1999, conducted when
the technology was much different than it is today.

WUWC members frequently conduct their own studies and customer surveys to help assess
consumer satisfaction with their water use efficiency programs and products, including
WaterSense labeled products. The EPA may be able to improve its reach by collaborating with
WUWC, its members and other utilities, and water use efficiency trade organizations (such as the
Water Research Foundation) to administer surveys that could help develop standardized
questions for data collection, providing greater consistency in how surveys are administered and
reductions in the cost of gathering survey information for both utilities and the EPA studies—
surveys that these utilities could incorporate into their customer research that would inform
future product specification development. Such surveys, studies, and data collection efforts could
be administered to customers on a voluntary basis and reported to the EPA to improve the
WaterSense Program.

This collaborative effort could result in more robust and reliable information that can be used to
set performance standards, evaluate the effectiveness of water use efficiency programs, and
evaluate water savings potential, among other benefits. It would also likely strengthen the
partnership between the EPA and the water community, which would be beneficial for future
data gathering and partnering on water use efficiency issues.

3


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The EPA should also incorporate surveys of the industry and studies of the actual impacts of
WaterSense technologies on water use. Several studies, like the Residential End Uses of Water
Study update published by the Water Research Foundation, and some other smaller efforts,
demonstrate the impacts of WaterSense on actual usage. A survey of the number of fixture and
equipment models that exceed WaterSense efficiency and performance standards would be
valuable and some of that information is very easily obtained. WUWC also suggests that the
EPA outreach to specific utilities, including WUWC member utilities, to identify studies the
EPA can reference about customer satisfaction and brand recognition (such as recognition of the
WaterSense Program compared to Energy Star).

C. Conclusion

Based on this extensive background and our members' experience being on-the-ground partners
with the EPA, WUWC is prepared to assist the EPA in its efforts to both improve and encourage
the use of WaterSense Program. Further, WUWC looks forward to continued dialogue and
collaboration on how the WaterSense Program can benefit water providers in the West and
across the country.

Thank you for the opportunity to provide these comments. If you have any questions regarding
these comments, please contact me at 702-258-7166 or greg.walch@lvvwd.com, or the WUWC
national counsel, Don Baur at 202-654-6234 or dbaur@perkinscoie.com.

Very truly yours,

Gregory J. Walch
Chairman

cc: Donald C. Baur
Perkins Coie LLP
700 Thirteenth St., NW, Suite 600
Washington, D.C. 20005

4


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WaterSense

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Mary Ann Dickinson, President and Chief Executive Officer
Affiliation: Alliance for Water Efficiency (AWE) et al.

Comment Date: July 22, 2020
Document ID: EPA-HQ-OW-2020-0026-0109

Comment Text:

Alliance for Water Efficiency and 60 organizations submit the attached as comment. 1 of
3

Attachment

See pages 270 through 281.

269

August 2020


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July 22, 2020

Mr. Andrew Wheeler
Administrator

US Environmental Protection Agency
Washington, DC

RE: Comments on Docket ID No. EPA-HQ-OW-2020-0026
Request for Information on the WaterSense® Program

Dear Administrator Wheeler:

The Alliance for Water Efficiency (AWE) and the undersigned 60 organizations and businesses
write to express our strong support for the WaterSense program at the Environmental
Protection Agency (EPA) and to share with you our submitted comments regarding WaterSense.
We are filing these comments in response to the Notice of Recent Specifications Review and
Request for Information on the WaterSense Program published on April 10, 2020 in the Federal
Register. Our comments address the recent EPA review of the WaterSense program, the EPA's

1


-------
decision not to revise any of the WaterSense product specifications, and the specific questions
asked within the Federal Register Notice.

Our comments focus on four specific areas of the Request for Information (ROI) in the Federal
Register, the details of which are contained in the attached document. Our basic conclusions
are as follows:

1.	Since its inception in 2006, WaterSense has sought to base its product specifications on
measured values of performance that are tested in a laboratory and certified by a third-
party certifying organization.

2.	Fixture performance has improved since the advent of WaterSense.

3.	The Residential End Use Study results for toilet flushing, showering, and faucet use show
that over 15 years, as fixtures themselves have become more efficient, customer use of
these fixtures has not changed nor has flushing frequency increased.

4.	Customer satisfaction criteria do NOT belong in WaterSense product specifications
themselves, but there are reasonable uses for customer satisfaction information within
WaterSense.

5.	Including a vague, non-scientific concept such as customer satisfaction criteria could
introduce uncertainty and bias into what has until now been a fair and scientific process
for setting WaterSense specifications.

6.	Product-specific customer satisfaction research is best left to the marketplace and
manufacturers themselves.

7.	The scope of customer satisfaction research should be limited to consideration of the
WaterSense brand itself and WaterSense partnerships, like the type of customer
satisfaction research ENERGY STAR has conducted in the past.

8.	Proper uses of customer satisfaction survey results would inform the EPA about
Americans' opinion of the WaterSense brand and their experience with WaterSense
labeled products in homes and businesses. This information could help EPA guide the
direction of the WaterSense brand and program.

9.	While we offer no comments on the EPA's decision not to revise any specifications at
this time, we nonetheless believe that it is important that specifications move forward
and advance over time, based on adequate study and research. WaterSense product
specifications should keep up with changing times and technology.

The WaterSense program has been a tremendous success for EPA. Public and private utilities in
all 50 states tailor successful water conservation programs around consumer use of
WaterSense-labeled products. And because of the nexus between water and energy use, the
4.4 trillion of gallons of water saved by WaterSense since 2006 have resulted in 522.9 billion
kilowatt hours of energy that are not used to heat, pump and distribute water. These savings
have resulted in a financial benefit to consumers on an average of more than $380 annually and
$87 billion total in water, sewer, and energy bills since 2006.

2


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Thank you for doing your utmost to ensure this inexpensive, valuable, and effective program
that continues to deliver for the American people.

Sincerely,

The Alliance for Water

Efficiency

Chicago, IL

Alameda County Water

District

Fremont, CA

American Supply
Association
Itasca, IL

American Water
Camden, NJ

American Water Works
Association
Denver, CO

AMWUA
Phoenix, AZ

Amy Vickers & Associates
Amherst, MA

Bottom Line Utility
Solutions, Inc.

Laguna Hills, CA

C+C, Inc.

Seattle, WA

California Water Efficiency
Partnership
Sacramento, CA

City of Ashland
Ashland, OR

City of Bellingham
Bellingham, WA

City of Bend
Bend, OR

City of Big Bear Lake
Department of Water
Big Bear Lake, CA

City of Charlottesville
Charlottesville, VA

City of Durham
Durham, NC

City of Flagstaff
Flagstaff, AZ

City of Mesa
Mesa, AZ

City of Sacramento
Sacramento, CA

City of Westminster
Westminster, CO

Coachella Valley Water

District

Coachella, CA

EcoSystems, LLC
Miami, FL

HI Commission on Water
Resource Management
Honolulu, HI

IAPMO
Dayton, NJ

Las Vegas Valley Water

District

Las Vegas, NV

Mesa Water,

Costa Mesa, CA

Metropolitan North GA
Water Planning District
Atlanta, GA

Metropolitan Water
District of Southern CA
Los Angeles, CA

Monte Vista Water District
Montclair, CA

Municipal Water District of
Orange County
Fountain Valley, CA

National Wildlife
Federation
Reston, VA

O'Cain Consulting
Santa Monica, CA

Peter Williams Solutions,
LLC

Danville, CA

PHCC—National
Association
Falls Church, VA

3


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Rancho Water
Temecula, CA

Regional Water Authority
Citrus Heights, CA

Santa Rosa Water
Santa Rosa, CA

Sacramento Suburban
Water District
Sacramento, CA

San Francisco Public
Utilities Commission
San Francisco, CA

Scottsdale Water
Scottsdale, AZ

Sonoma-Marin Saving
Water Partnership
Santa Rosa, CA

Sonoma Water
Santa Rosa, CA

Soquel Creek Water

District

Soquel, CA

Southern Nevada Water

Authority

Las Vegas, NV

T&S Brass and Bronze
Works

Travelers Rest, SC
Tacoma Water
Tacoma, WA

Texas Water Foundation
Austin, TX

Turfgrass Water
Conservation Alliance
Albany, OR

Utah State University,
Center for Water Efficient
Landscaping
Logan, UT

United Association of
Plumbers and Pipefitters
of the U.S and Canada
Annapolis, MD

Upper San Gabriel Valley
Municipal Water District
Monrovia, CA

Utah Water Conservation
Forum

Salt Lake City, UT

Valley County Water
District

Baldwin Park, CA

Valley Water
San Jose, CA

Water - Use It Wisely
Mesa, AZ

Water Supply Citizens
Advisory Committee to
MWRA

Belchertown, MA

WaterDM
Boulder, CO

Waterless Co
Vista, CA

WaterNow Alliance
San Francisco, CA

Western Urban Water
Coalition
Washington, DC

4


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Detailed Comments

1. Should the EPA include customer satisfaction criteria in the WaterSense product
specifications and guidelines?

We believe that customer satisfaction criteria do not belong in WaterSense product
specifications themselves, but there are reasonable uses for customer satisfaction information
within WaterSense. Proper uses of customer satisfaction survey results would inform the EPA
about Americans' opinions of the WaterSense brand and their experience with WaterSense-
labeled products in homes and businesses. This information could help EPA guide the direction
of the WaterSense brand and program. However, it would not be reasonable or correct for EPA
to include customer satisfaction requirements within individual product specifications.

ENERGY STAR hired JD Power and Associates and others to conduct customer satisfaction
surveys about products that receive the ENERGY STAR label.1 All of these surveys were focused
on satisfaction with partnerships, utility programs, and the ENERGY STAR brand. These surveys
did not cover topics like the wattage of light bulbs, the duration of dishwasher cycles, or any
product-specific information. Recent JD Power research answered the question, "Does Energy
Star Partnership Increase Customer Satisfaction?"

Similarly, WaterSense could use customer satisfaction surveys conducted by independent
organizations to evaluate utility partnerships, brand recognition, and overall satisfaction with
WaterSense-labeled products. This information could help guide EPA to improve the
WaterSense program and could even provide insight and general direction for product
categories like toilets, urinals and smart irrigation controllers.

Customer satisfaction is a
comparatively vague concept that
cannot be measured in a laboratory in
the same way as flush volumes and
flow rates can. As shown in Figure 1,
customer satisfaction research
examines the nexus between
customer expectations, perceived
quality, and perceived value.

Customer satisfaction with a

Figure 1: Customer satisfaction research nexus. Source:
plumbing fixture depends greatly on the	https://asq.org/quality-resources/customer-satisfaction

https://www.energystar.gov/sites/default/files/asset/document/Schultz Energy%20Star%20Results JDPower 2R.
pdf

https://www.esource.com/svstem/files/files/corpcomm programs-brand.pdf

https://www4.eere.energv.gov/seeaction/svstem/files/documents/ratepaver efficiency customersatisfaction.pdf

Perceived
quality

Customer
complaints

Perceived
value

Customer
satisfaction

Customer
loyally

Customer
expectations,

5


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quality of manufacturing, the cost of the product, the customers' own expectations, the actual
installation of the fixture, the water pressure in the building, and the appearance of the fixture,
among other factors. These are all difficult to measure. Including customer satisfaction criteria
could introduce uncertainty and bias into what has until now been a fair and scientific process.

Since its inception in 2006, WaterSense has sought to base its product specifications on
measured values of performance that are tested in a laboratory and certified by an authorized
certification body. These measured values include the volume of water used to flush a toilet, or
the maximum flow rate of a showerhead or faucet aerator under specific pressure conditions.
These measured test values ensure that products that receive the WaterSense label are tested
and are thus capable of meeting established, measurable performance criteria under laboratory
conditions. This fundamental adherence to measured performance has provided a level playing
field for manufacturers who have produced WaterSense products since 2006. The playing field
is level because the measured requirement of each specification is understood by product
manufacturers.

Customer satisfaction research is best left to the marketplace and manufacturers themselves.
Product manufacturers conduct customer satisfaction research frequently and keep the results
to themselves so they can use it strategically to develop their products and brand to
competitive advantage. This is truly the proper use of and location for product-specific
customer satisfaction research, not with the EPA, but with product manufacturers.

The WaterSense approach of basing specifications on measured values of performance that are
tested and certified has had tremendous positive impact on the American economy. Americans
can choose from more than 34,000 available models of WaterSense-labeled products for
bathrooms, commercial kitchens and irrigation systems. The EPA has estimated that
WaterSense-labeled products have saved more than $87 billion on American families' water,
sewer, and energy bills. To date more than 2,000 manufacturers, retailers and distributors,
water and energy utilities, state and local government, non-profit and trade organizations,
irrigation training organizations, and home builders strengthen their businesses through
partnerships with WaterSense.

2. How should EPA design studies to inform future reviews that might incorporate customer
satisfaction considerations?

Measuring customer satisfaction is a complex task that requires statistical surveying and careful
research. It becomes particularly challenging when trying to understand customer satisfaction
with a product and to distinguish that from the brand and style and manufacturing of the
fixture, the installation of the fixture, the local water pressure, and other factors. The task of
measuring customer awareness of and satisfaction with the WaterSense brand as a whole
would be quite different than measuring customer satisfaction with specific WaterSense-
labeled plumbing fixtures such as toilets or showerheads.

6


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This is not the type of research that can or should be conducted by the EPA itself. To protect
WaterSense partners and the integrity of the WaterSense brand, the EPA should rely on the
services of professional independent researchers (like JD Power, Edmunds, or KBB) or who
specialize in this type of work.

Our recommendation is to limit the scope of customer satisfaction research to consideration of
the WaterSense brand itself and WaterSense partnerships, like the type of research ENERGY
STAR has conducted. This is much more likely to yield useful information to the EPA. If EPA
chooses to conduct customer satisfaction research into specific labeled product categories, it
must be designed and conducted by experts with knowledge of both customer satisfaction
survey methods and plumbing fixtures.

Superior products will gain market share and it is industry that knows best how to conduct
customer satisfaction research. Product category research has been conducted in the
marketplace by industry and product manufacturers and distributors who all want this
information to make popular products that customers want, to thus gain competitive
advantage and market share. Product-specific customer satisfaction research does not need to
be and should not be conducted with public funds. Industry may not wish to share the results of
the research they have privately conducted, but that is their prerogative. During the
WaterSense product specification and review process, information that industry deems
relevant can be introduced.

3. What information, data, surveys, and studies are available that to help assess customer
satisfaction with WaterSense-labeled products which could help inform future product
specification?

In 2002, four years before WaterSense was created, all toilets sold in the US were required to
comply with ASME Standard A112.19.2, which required testing with media comprised of plastic
"granules", nylon balls, sponges and kraft paper. In 2003, in response to water utilities'
concerns over the performance of toilets they rebated, engineers John Koeller and Bill Gauley
created Maximum Performance Testing (MaP Testing) and began bench-testing toilets using far
more realistic test media comprised of dense bean paste. MaP also began publishing testing
results on a regular basis so that water utilities could provide toilet fixture performance
information to their customers. Manufacturers voluntarily submitted their toilets for MaP
Testing so that they could be part of large rebate programs in California, Texas, Georgia, and
elsewhere.

By June 2006, when the WaterSense program was introduced, there were already about 500
different tank-type toilet models submitted for MaP Testing, the results of which were released
to the public. These toilets could remove an average of 420 grams each (see Figure 2 below).
As the WaterSense toilet specification for tank-type toilets was developed, many parties
recommended that MaP Testing (or similar testing using realistic test media) be incorporated
into the specification and, ultimately, the WaterSense tank-toilet minimum performance
specification was set at 350 grams of waste removal using the MaP approach.

7


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Figure 2: Fixture models tested and average grams of waste removed by tank-type toilets, 2003 - 2020

(Source: MaP Testing)

The WaterSense tank-type toilet specification was released in 2007, and since that time the
number of MaP-tested fixture models has gone from 500 to 3,390, and the average flushing
performance has improved from 500 grams of waste removed in a single flush to almost 900
grams. To be perfectly clear, 900 grams is nearly two (2) pounds of waste in a single flush,
which is over 7 times the median wet weight for daily fecal output by healthy individuals in high
income populations (128 grams) and 3.6 times the median wet weight for daily fecal output by
healthy individuals in low income populations (250 grams).2

The impact of MaP Testing in improving toilet performance has been so significant that it was
incorporated into the national product standard (ASME A112.19.2-2013/CSA B45.1-13) in 2013.
Figure 2 shows the progression of fixtures tested and the improvement in average flushing
performance since the advent of MaP Testing and WaterSense.

American consumers have expressed a high level of satisfaction with WaterSense-labeled
products that have been tested through this and other processes. Customers of the Home

2 The Characterization of Feces and Urine: A Review of the Literature to Inform Advanced Treatment Technology,
C. Rose, a A. Parker, a , * B. Jefferson, a and E. Cartmell a - 2015

https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4500995/

8


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Depot were so satisfied with WaterSense products that the company chose to sell WaterSense-
labeled products exclusively in all of their stores. At competitor Lowe's, the overwhelming
majority of eligible product offered for sale carry the WaterSense label. If there were a problem
with customer satisfaction, these retail giants would know it and would offer something
different. Home Depot and Lowe's both know that the products carrying the WaterSense label
perform better than the competition that is not subject to rigorous performance testing.

WaterSense has operated on a very modest budget since 2006, but nonetheless has become
remarkably successful and popular. WaterSense manufacturer partners have produced over
4,200 different WaterSense-labeled tank-type toilet models; 9,300 models of WaterSense-
labeled showerheads; and 18,000 WaterSense-labeled lavatory faucet and accessory models3.
American consumers have voiced their satisfaction with their purchases. Industry agrees, and
more than 2,000 manufacturers, retailers and distributors, water and energy utilities, state and
local government, non-profit and trade organizations, irrigation training organizations, and
home builders strengthen their businesses through partnerships with WaterSense.

Based on this success, the popularity of WaterSense is expected to grow. Research from
Plumbing Manufacturers International found that within the next 15 years, most bathroom sink
faucets and showerheads installed in the United States will be WaterSense-certified or meet
the requirements of the WaterSense program. Within the next 30 years, most residential tank-
type toilets will also be WaterSense-certified or meet the requirements of the WaterSense
program. Within the next 40 years, most flushometer-valve toilets and flushing urinals will be
WaterSense-certified or meet the requirements of the WaterSense program.4

While not addressing customer satisfaction or WaterSense products directly, the 1999 and 2016
Residential End Uses of Water Studies5 measured how people use water at home in their daily
lives. The studies reveal how frequently people use toilets, faucets, and clothes washers, and to
what extent those behaviors have changed over time. This information can be a strong
indicator of customer satisfaction. These paired residential end use studies offer the best
available measurements of key metrics such as the frequency of toilet flushing, the duration of
shower and faucet usage, and the flow rate of these fixtures. This information provides valuable
insight about water use patterns and indicates if people are using fixtures the same or more
frequently as the flow rates and flush volumes of the fixtures have changed.

The results for toilet flushing, showering, and faucet use show that over 15 years, fixtures
themselves have become more efficient, but the use of these fixtures has not changed. The

average volume of water used to flush a toilet has decreased, but the average number of

3	Federal Register. April 10, 2020. EPA-HQ-OW-2020-0026 - Request for Information on the WaterSense Program.
Vol. 85, No. 70.

4	IBID

5	DeOreo, W.B., P. Mayer, J. Kiefer, and B. Dziegielewski. 2016. Residential End Uses of Water, Version 2. Water
Research Foundation. Denver, CO.

Mayer, P., W. DeOreo, J. Kiefer, E. Opitz, B. Dziegielewski, and J.O. Nelson. 1999. Residential End Uses of Water.
Water Research Foundation, Denver, CO.

9


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flushes per person per day has stayed the same. The average number of minutes spent in the
shower has likewise stayed the same. The average faucet use per person per day has also
stayed the same. Subsequent analysis on shower patterns using the same Residential End Uses
of Water data sets found "on average, people do not compensate for lower flow rates by
increasing the duration of their shower and that lower flow rate showerheads do, on average,
result in a lower overall shower volume".6

WaterSense has also driven performance improvement for showerheads. ASME industry
standards for showerheads have been made more rigorous directly as a result of WaterSense
with the addition of spray force and spray coverage test requirements taken directly from the
WaterSense specifications.

Under section "V. Request for Information on Consumer Satisfaction" of the April 10 Federal
Register Notice it states the following (emphasis added):

"Understanding consumer satisfaction is important to the EPA as the Agency seeks to
ensure that our performance criteria review is in fact ensuring that labeled products are
meeting the same standards as products on the market before the WaterSense label was
adopted."

This statement is problematic for several reasons. First, the statement correctly states that
products that achieve the WaterSense label are meeting different standards than products that
do not receive the label. Both then and now, all plumbing products and fixtures must meet the
same set of basic national product standards established by ASME/CSA A112.19.2-2013/CSA
B45.1-13 for fixtures and ASME A112.18.1-2018/ CSA B125.1-18 for fittings. Since 2013,
however, the requirements contained within the WaterSense specifications for plumbing
products have been incorporated into the relevant ASME/CSA standards. As a result,
certification to the national product standard can also result in certification to the WaterSense
specification if the manufacturer so desires.

Appendix A shows the current standards that all tank-type toilets must meet in 2020 along with
a history of these specifications since 2003.

Second, the statement wrongly implies that customer satisfaction for plumbing fixtures was
higher before 2006 when the WaterSense label was adopted and that products met a different
standard back then. The tremendous success and popularity of WaterSense-labeled products
(described above) is due in large part because WaterSense specifications include measurable
performance requirements that result in products that work better for consumers than the
products they had before. Achieving the WaterSense label requires that products be tested to
a higher standard, and this statement wrongly implies that these don't meet the same

6 Gauley, B. and J. Koeller. 2017. How Showerhead Flow Rates Impact Shower Duration and Volume, www.map-
testing.com

10


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minimum basic standards as other fixtures. The confusion evident in this statement in the
Federal Register should be corrected.

4. Comments on EPA's recent review of the WaterSense program.

The April 10 Federal Register Notice also included a summary of the review of WaterSense
product performance criteria, conducted as required under the authorizing legislation under
the America's Water Infrastructure Act (AWIA) of 2018. Based on this review, the EPA made the
decision not to revise any specifications.

While we offer no comments on the EPA's decision not to revise any specifications at this time,
we nonetheless believe that it is important that specifications move forward and advance over
time, based on adequate study and research. WaterSense product specifications should keep
up with changing times and technology.

11


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Appendix A - History of Tank-Type Toilet Standards 2003 - 2013

ASME/CSA National Product Standard - Water Closets (toilets) - 2003 to today

0'

McP

Maximum Performance





Current Standard



2013 Standard



2008 Standard



2003 Standard



ASME A112.19.2-2018/CSA B45.1-
18

ASME A112.19.2-2013/CSA B45.1-
13

ASME All2.19.2-2008/CSA B45.1-
08

ASME A112.19.2-2003



Pro-
cedure

Requirements

Pro-
cedure

Requirements

Pro-
cedure

Requirements

Pro-
cedur

(3

Requirements

Water consumption

7.3

Maximum flush volumes:
Low consumption models: 1.6 gal
High-Efficiency models: 1.28 gal
Dual-flush models-full flush*: 1.6

7.4

Maximum flush volumes:
Low consumption models: 1.6 gal
High-Efficiency models: 1.28 gal

7.4

Maximum flush volumes:
Water-saving models - 3.5 gpf
Low-consumption models: 1.6 gal
High-Efficiency models: 1.28 gal

8.4

Two thresholds for maximum flush
vol.: Water-saving water closets - 3.5

gpf

Low-consumption water closets - 1.6

Granule and ball test

7.5

2500 granules in bowl - not more
than 125 granules visible after
flush. 100 Nylon balls (0.25 in.
diameter) in bowl - not more than 5
balls visible after flush

7.5

2500 granules in bowl - not more
than 125 granules visible after flush.
100 Nylon balls (0.25 in. diameter)
in bowl - not more than 5 balls
visible after flush

7.5

2500 granules in bowl - not more
than 125 granules visible after
flush. 100 Nylon balls (0.25 in.
diameter) in bowl - not more than 5
balls visible after flush

8.5

2500 granules in bowl - not more
than 125 granules visible after flush.
100 Nylon balls (0.25 in. diameter) in
bowl - not more than 5 balls visible
after flush

Surface wash test
(ink line test)

7.6

Ink line around interior
circumference of bowl 1 inch below
rim - after flushing, remaining line
= 2-inch maximum; no segment
more than 0.5 inch

7.6

Ink line around interior
circumference of bowl 1 inch below
rim - after flushing, remaining line =
2-inch maximum; no segment more
than 0.5 inch

7.6

Ink line around interior
circumference of bowl 1 inch below
rim - after flushing, remaining line
= 2-inch maximum; no segment
more than 0.5 inch

8.6

Ink line around interior circumference
of bowl 1 inch below rim - after
flushing, remaining line = 2-inch
maximum; no segment more than 0.5
inch

Mixed media test

TEST DELETED IN 2018 >>>>

7.7

20 sponges and 8 kraft paper balls
(15 lb. paper) in bowl. After
flushing, at least 22 sponges/paper
balls fully discharged

7.7

20 sponges and 8 kraft paper balls
(15 lb. paper) in bowl. After
flushing, at least 22 sponges/paper
balls fully discharged

8.7

20 sponges and 8 kraft paper balls (15
lb. paper) in bowl. After flushing, at
least 22 sponges/paper balls fully
discharged

Drainline transport

7.7

100 polypropylene balls (0.75-in.
diameter) in bowl. After flushing,
average distance traveled in plastic
drainline at least 40 ft.

7.8

100 polypropylene balls (0.75-in.
diameter) in bowl. After flushing,
average distance traveled in plastic
drainline at least 40 ft.

7.8

100 polypropylene balls (0.75-in.
diameter) in bowl. After flushing,
average distance traveled in plastic
drainline at least 40 ft.

8.8

100 polypropylene balls (0.75-in.
diameter) in bowl. After flushing,
average distance traveled in plastic
drainline at least 40 ft.

Waste extraction
test (MaP test
orocedure^

7.9

350 gram minimum waste extration

7.10

350 gram minimum waste extration









Consistent water
level test (non-pilot-
type fill valves only)

7.10

Maintain tank water level at ± 0.5
inches

7.11

Maintain tank water level at ± 0.5
inches









Fill valve shutoff
integrity test with
increased water
pressure (non-pilot-
type fill valves only)

7.11

Maintain tank water level at ± 0.5
inches at 20 to 80 psi

7.12

Maintain tank water level at ± 0.5
inches at 20 to 80 psi

<<<<< REQUIREMENTS ADDED IN 2013

Adjustability test for
tank-type gravity-
fed toilets

7.12

Single-flush maximum = 1.68 gal
Dual-flush maximum = 2.0 gal (full)
and 1.4 gal (reduced)

7.13

Single-flush maximum = 1.68 gal
Dual-flush maximum = 2.0 gal (full)
and 1.4 gal (reduced)









*-Maximum flush volume of 1.1 gal for the reduced flush is specificed in ASME A112.19.14-2013_R2018, section 3.2.2

12


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WaterSense

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Mary Ann Dickinson, President and Chief Executive Officer
Affiliation: Alliance for Water Efficiency (AWE) et al.

Comment Date: July 22, 2020
Document ID: EPA-HQ-OW-2020-0026-0110

Comment Text:

Alliance for Water Efficiency submits the following letter as a comment. Letter 2 of 3
Attachment

See pages 283 through 286.

282

August 2020


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July 22, 2020

i^>

Alliance

Water
Efficiency

Mr. Andrew Wheeler
Administrator

US Environmental Protection Agency
Washington, DC

RE: Comments on Docket ID No. EPA-HQ-OW-2020-0026
Request for Information on the WaterSense® Program

Dear Administrator Wheeler:

The Alliance for Water Efficiency (AWE) writes to express support for the
WaterSense® program, and for the integrity of WaterSense product specifications.
AWE is filing two letters to this Docket; this letter pertains specifically to the issue
of maintaining showerhead flow rates.

The WaterSense specification for showerheads has been designed to provide the
following: improved showerhead performance testing; increased water savings
from a lower fiow rate than the federal standard; and energy savings resulting
from the additional conserved hot water. Since the WaterSense showerhead
specification was adopted in 2010, labeled showerheads have provided
demonstrated water and energy savings, and will continue to do so into the future
due to a transformed market. WaterSense labeled showerheads use 2.0 gallons
per minute (gpm) or less, and meet the American Society of Mechanical Engineers
testing procedures (ASME A112.18.1/CSA B125.1). The development of the
WaterSense showerhead specification has also helped increase the rigor of ASME
testing procedures with the addition of spray force and spray coverage test
requirements.

33 N LaSalle Street
Suite 2275
Chicago, IL 60602

(773) 360-5100
(866) 730-A4WE
¦ (773)345-3636

allianceforwaterefficiency.org
home-water-works.org

The savings achieved by the WaterSense showerhead specification are significant,
and both water and energy use have been reduced. But AWE is concerned that
there might be a proposal to increase the specification flow rate from the current
2.0 gpm, or even increase the flow rate in the federal standard of 2.5 gpm. To
provide some perspective on the importance of the water and energy savings,
AWE has analyzed the future impact that might result if showerhead flow rates
were raised, using data describing the installed base of showerheads in 2011-2012
from the Residential End Uses of Water Study1 which has documented actual flow
rates in the field. Based on projections for new development and for existing home
showerhead replacements, AWE estimates that 2.5 gpm showerheads provide 11
billion gallons per year in water savings and 5 trillion Btu per year in energy
savings. Ultra-efficient showerheads (<1.6 gpm) provide 19 billion gallons per year

Residential End Uses of Water Study, 2016 Update. Water Research Foundation,


-------
2

in water savings and 9 trillion Btu per year in energy savings. These are significant savings; in ten
years the savings for 2.5 gpm showerheads at the federal standard alone accumulate to the
equivalent of supplying 1 million homes with water and 670,000 homes with energy.

Thus, AWE strongly supports maintaining the existing federal showerhead flow rate standard and
WaterSense showerhead specification at the current levels. The attached memo explains our
analysis.

Sincerely,

Mary Ann Dickinson
President and CEO


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3

Analysis of Water and Energy Savings from Showerhead Flow Rates

The Alliance for Water Efficiency (AWE) analyzed the water and energy savings coming from
existing showerhead flow rates and possible changes to them. The Federal standard specifies a
maximum flow rate of 2.5 gallons per minute (gpm). The WaterSense showerhead specification
specifies a maximum flow rate of 2.0 gpm. Our analysis used data describing the installed base
of showerheads in 2011-2012 from the Residential End Uses of Water Study,2 which has
documented actual flow rates in the field. Because ultra-efficient showerheads can go as low as

1.5	gpm or lower, the field data from the Residential End Use Study showed an average flow of

1.6	gpm or less for these showerheads. Thus, it is this number that AWE used in the analysis.

AWE estimates that showerheads are installed in slightly more than one million new homes and
replaced in approximately 9.7 million existing homes each year, or a total of 10.8 million homes.
These estimates are based on the following:

•	New homes: Slightly more than one million occupied housing units are added to the
United States housing stock annually.3

•	Existing homes: The annual replacement rate of showerheads has been estimated to
range from 5% to 10% (California Energy Commission. 2015). Currently, there are
approximately 122 million occupied housing units in the United States.4 Assuming an
average of 2 showerheads per housing unit, there are approximately 244 million installed
showerheads, of which between 12 and 24 million are replaced each year. This is
equivalent to showerhead replacement in 6 to 12 million homes each year. For this
analysis, we use the midpoint of the range, or 9.7 million homes.

Table 1 shows the national-level estimates of water and energy savings, assuming existing and
new homes installing showerheads were fitted with either efficient or ultra-efficient
showerheads. Water savings are 11 billion gallons for efficient showerheads and 19 billion gallons
for ultra-efficient showerheads. Energy savings are 5 trillion Btu for efficient showerheads and 9
trillion Btu for ultra-efficient showerheads. For a sense of magnitude of this savings, it is enough
water to serve between 100,000 and 171,000 homes and enough energy to serve between
67,000 and 115,000 homes.5

Table 2 shows the national-level estimates of cumulative water and energy savings assuming
existing and new homes installing showerheads were fitted with either efficient or ultra-efficient
showerheads.

2	Residential End Uses of Water Study, 2016 Update. Water Research Foundation.

3	Based on U.S. Census, American Community Survey, 2013-2018 1-year occupied housing unit estimates
(data.census.gov, Table DP04).

4	Ibid.

5	According to EPA and the U.S. Energy Information Administration, the typical home in the United States uses
approximately 110,000 gallons of water and 77.1 million Btu annually.


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4

Table 3 shows the number of homes that could be served by these savings. After 5 years, water
savings would be sufficient to serve between 500,000 and 855,000 homes and energy savings
would be sufficient to serve between 335,000 and 575,000 homes. After 10 years, water savings
would be sufficient to serve between 1,000,000 and 1,710,000 homes and energy savings would
be sufficient to serve between 670,000 and 1,150,000.

Table 1. National-Level Estimate of Annual Water and Energy Savings for Efficient and Ultra-
Efficient Showerheads

Showerhead Efficiency

Water Savings
(Billion Gallons)

Energy Savings
(Trillion Btu)

Efficient Showerhead Retrofit
(flow rate < 2.5 gpm)

11

5

Ultra-efficient Showerhead Retrofit
(flow rate < 1.6 gpm)

19

9

Table 2. National-Level Estimate of Cumulative Annual Water and Energy Savings for Efficient and
Ultra-Efficient Showerheads



Annual Water Savings
(Billion Gallons)

Annual Energy Savings
(Trillion Btu)

Showerhead

Efficient

Ultra-Efficient

Efficient

Ultra-Efficient











After 1 year

11

19

5

9

After 5 years

55

95

25

45

After 10 years

110

190

50

90

Table 3. National-Level Estimate of Savings in terms of Number of Homes



Number of homes that could

Number of homes that could



be served by water savings

be served by energy savings

Showerhead

Efficient

Ultra-Efficient

Efficient

Ultra-Efficient











After 1 year

100,000

171,000

67,000

115,000

After 5 years

500,000

855,000

335,000

575,000

After 10 years

1,000,000

1,710,000

670,000

1,150,000


-------
WaterSense

Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Mary Ann Dickinson, President and Chief Executive Officer
Affiliation: Alliance for Water Efficiency (AWE) et al.

Comment Date: July 22, 2020
Document ID: EPA-HQ-OW-2020-0026-0111

Comment Text:

Alliance for Water Efficiency submits the attached letter as a comment. 3 of 3
Attachment

See pages 288 through 293.

287

August 2020


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Results from 1999 and 2016 Residential End Uses of Water Studies

MEMO

April 29, 2020

From: Peter Mayer, P.E., Principal, WaterDM
To: Alliance for Water Efficiency

Summary of Conclusions

•	The April 10, 2020 Notice in the Federal Register requested information, data, surveys and
studies to help assess customer satisfaction with WaterSense labeled products which could
help inform future product specification.

•	While not addressing customer satisfaction or WaterSense products directly, the 1999 and
2016 Residential End Uses of Water Studies measured how people use water at home in
their daily lives. The studies reveal how frequently people use toilets and faucets and
clothes washers and to what extent those behaviors have changed over time. This
information can be an indicator of customer satisfaction.

•	The results for toilet flushing, showering, and faucet use show that over 15 years, fixtures
themselves have become more efficient, but the use of these fixtures has not changed.

o The average volume of water used to flush a toilet has decreased, but the average

number of flushes per person per day has stayed the same,
o The average number of minutes spent in the shower has stayed the same,
o The average faucet use per person per day has stayed the same.

Why a Residential End Use Study Memo?

The Alliance for Water Efficiency requested that WaterDM prepare a memo presenting key
results from the Water Research Foundation's paired residential end uses of water studies
(REUWS) published in 1999 and 2016, particularly as they relate to toilets, showers, and
faucets. This information is provided to improve understanding of usage patterns over time for
the purpose of responding to the Notice of Recent Specifications Review and Request for
Information on the WaterSense Program published on April 10, 2020 in the Federal Register.

What Are the Residential End Uses of Water Studies?

The Residential End Uses of Water Studies are a series of research studies sponsored by the
Water Research Foundation and a consortium of utilities. The 1999 Residential End Uses of
Water (Mayer P. and DeOreo W., et. al. 1999) provided detailed information on residential
water use patterns and efficiency levels from 1,187 single-family homes from random samples
selected across 14 water providers. The 2016 Residential End Uses of Water, Version 2 (DeOreo
W. and Mayer P. et. al. 2016) provided an updated and expanded assessment of water use from
762 single-family households from random samples selected across 9 water providers and
presents detailed information and data about how water use has changed during the 15-year
period. The WaterSense program was established in 2006 in the time between these two
research projects.

1 I P a g e


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Results from 1999 and 2016 Residential End Uses of Water Studies	/ WaterDM

t DEMAND MANAGEMENT

Do the Residential End Uses of Water Studies Address Customer
Satisfaction?

The Residential End Uses of Water Studies did not specifically survey participants about
"satisfaction" or "enjoyment" of fixtures like toilets, showerheads, and faucets. Rather the
study measured how people use water
at home in their daily lives. The studies
reveal how frequently people use
toilets and faucets and clothes washers
and to what extent those behaviors
have changed overtime.

These successive residential end use
studies offer the best available
measurements of key metrics such as
the frequency of toilet flushing, the
duration of shower and faucet usage, and the flow rate of these fixtures. This information
provides valuable insight about water use patterns, and indicates if people are using fixtures
the same or more frequently as the flow rates and flush volumes of the fixtures have changed.
This information can be a strong indicator of customer satisfaction.

Toilet Flushing

American households are equipped with thousands of different makes and models of toilets
that have been installed over many years. The results from the Residential End Uses of Water
studies (Table 1) show that toilet flushing became substantially more efficient between 1999
and 2016, but significantly, people flushed the toilet almost exactly the same amount. The
average toilet flush volume decreased from 3.65 gallons per flush in 1999 down to 2.6 gallons
per flush in 2016, but the number of flushes per person per day stayed the same. From a
flushing frequency perspective, Americans are just as satisfied with their toilets that used an
average of 2.6 gallons per flush as they were with their toilets that used an average of 3.65
gallons per flush.

Figure 1 presents the frequency distribution of toilet flush volumes from the two studies. High
volume toilets flushing at 4 gallons per flush or more were far more common in the 1999 data
set. Low volume toilets flushing below 2 gallons per flush were far more common in the 2016
data set. Flush volume has changed, but flushing behavior remained the same. If customers
were experiencing problems with lower volume toilets, it would be evident from these data,
but that is not the case. The results from these two major national studies show that toilet
flushing frequency has stayed the same, even as flush volumes have been reduced through
plumbing codes and standards and the voluntary WaterSense program.

THE RESULTS FROM THE LARGEST

NATIONAL STUDIES SHOW THAT TOILET
FLUSHING FREQUENCY HAS STAYED THE
SAME, EVEN AS FLUSH VOLUMES HAVE
BEEN REDUCED THROUGH PLUMBING
CODES AND STANDARDS AND THE
VOLUNTARY WATERSENSE PROGRAM.

2 | P a g e


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Results from 1999 and 2016 Residential End Uses of Water Studies	, Water DM

I OE.MANO MANAGEMENT

Table 1: Toilet summary from 1999 and 2016 REUWS1

1999 REUWS	2016 REUWS

Number of houses

1187

762

Average flushes/household/day

12.4

13

Average flushes per person per day

5.05

5.0

Average flush volume

3.65 ±0.06 gal

2.6 ±0.01 gal

Average daily use for toilet flushing

45.2 gphd

33.1 ±2 gphd

Median daily use for toilet flushing

43 gphd

29 gphd

% of Flushes <2.2 gal

16%

48%

Average per capita toilet use (gpcd)

18.5

14.3

14%
12%
10%

>.
o

§ 8%

?

LL



TO

4%
2%
0%

Figure 1: Frequency distribution of toilet flush volumes, 1999 and 2016 REUWS1

Showers

The second largest category of water use inside homes in these studies was for showering. On
average there were roughly two showers per day taken in the homes that had an average
duration of 8 minutes and used 16 gallons of water per shower. Results from the two studies
are shown in Table 2. These statistics show a consistent pattern of use for showering over the
years. People generally take a shower with a duration of 7.8 minutes that uses between 15 and





¦ REU1999 b REU2016





























































































































i/)ou->ou->OL/-)c>u-)OLnou->OLr>omoLnoinou">ou">ou->
(\iinsq(\iinsq(viu)Kq
-------
Results from 1999 and 2016 Residential End Uses of Water Studies	, WaterDM

I DEMAND MANAGEMENT

18 gallons (57 and 68 liters) of water. The data do suggest a small but perceptible decrease in
the daily use and per shower use between the two REUWS studies, but it is not significant.

As with toilet flushing, showering behavior patterns did not change much over 15 years.
Subsequent analysis on shower patterns using the same Residential End Uses of Water data
sets was performed in 2017 by Bill Gauley and John Koeller. That research found "on average,
people do not compensate for lower flow rates by increasing the duration of their shower and
that lower flow rate showerheads do, on average, result in a lower overall shower volume"
(Gauley and Koeller 2017).

The Gauley and Koeller report findings also shed light on the complexities associated with
showering and trying to measure customer satisfaction. "While some people take longer
showers and some take shorter showers, it seems that, in general, people tend to follow their
own unique routine for showering regardless of the flow rate of the showerhead. In fact, it is
possible that the few extra seconds spent showering at lower flow rates is primarily related to
washing and rinsing hair" (Gauley and Koeller 2017).

Table 2: Shower summary from 1999 and 2016 REUWS2

1999 REUWS	2016 REUWS

Number of houses

1187

762

Average showers/household/day

1.8

1.8

Average showers/person/day

0.66

0.69

Average shower volume

16.7 ±0.3 gal

15.8 ±0.5 gal

Average shower duration

7.8 ± 0.14 minutes

7.8 ± 0.02 minutes

Average flow rate for showers (gpm)

2.2 ± 0.04 gpm

2.1 ± 0 .04 gpm

Average per capita shower use

11.6 gpcd

11.2 gpcd

Faucets

Faucet use in the Residential End Uses of Water studies is comprised of a wide variety of water
use events, which basically do not fall into any other recognizable category within established
flow constraints and include kitchen, bathroom, hose bib, and utility sink faucets.

Faucet use is highly discretionary, so it is expected to see high numbers of these events and a
high degree of variability in the statistics. Table 3 shows faucet statistics from the 1999 and
2016 end use studies. Faucet use has remained similar over the roughly 15-year period
between studies, with the average per capita use for faucets only differing by 0.2 gpcd.

Similar to the findings with toilets and showers, there appear to be very few differences in
faucet use behavior between the two studies, even more notable because the data were

2 Source: Water Research Foundation, Residential End Uses of Water, V2 (2016)

4 | P a g e


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Results from 1999 and 2016 Residential End Uses of Water Studies	, WaterDM

I DEMAND MANAGEMENT

collected 15 years apart from samples of entirely different homes in different cities. The fact
that faucet use patterns did not change is clear indication that changing faucet fixture flow
rates including the WaterSense specification have had little overall impact on behavior or
faucet use.

Table 3: Faucet summary from the 1999 and 2016 REUWS3

1999 REUWS	2016 REUWS

Number of houses

1187

762

Average faucet uses/person/day

15

20

Average faucet use volume

0.7 gallons per use

0.5 gallons per use

Average faucet duration

30 seconds

30 seconds

Average per capita faucet use

10.9 gpcd

11.1 gpcd

Conclusions

•	The April 10, 2020 Notice in the Federal Register requested information, data, surveys and
studies to help assess customer satisfaction with WaterSense labeled products which could
help inform future product specification.

•	While not addressing customer satisfaction or WaterSense products directly, the 1999 and
2016 Residential End Uses of Water Studies measured how people use water at home in
their daily lives. The studies reveal how frequently people use toilets, showers, faucets and
clothes washers and to what extent those behaviors have changed over time.

•	These paired residential end use studies offer the best available measurements of key
metrics such as the frequency of toilet flushing, the duration of shower and faucet usage,
and the flow rate of these fixtures. This information provides valuable insight about water
use patterns and indicate if people are using fixtures the same or more frequently as the
flow rates and flush volumes of the fixtures have changed to become more efficient.

•	The results for toilet flushing, showering, and faucet use show that over 15 years, fixtures
themselves have become more efficient, but the use of these fixtures has not changed. The
average volume of water used to flush a toilet has decreased, but the average number of
flushes per person per day has stayed the same. The average number of minutes spent in
the shower has stayed the same. The average faucet use per person per day has stayed the
same.

•	If customers were satisfied with their fixtures in 1999, they appear to be equally satisfied
with their fixtures in 2016 and use them in pretty much the same way, even as the fixtures
themselves have become more efficient.

3 Source: Water Research Foundation, Residential End Uses of Water, V2 (2016)

5 | Page


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Results from 1999 and 2016 Residential End Uses of Water Studies	, WaterDM

I DEMAND MANAGEMENT

References

DeOreo, W.B., P. Mayer, J. Kiefer, and B. Dziegielewski. 2016. Residential End Uses of Water,
Version 2. Water Research Foundation. Denver, CO.

Gauley, B. and J. Koeller. 2017. How Showerhead Flow Rates Impact Shower Duration and
Volume. Prepared for the Alliance for Water Efficiency, www.map-testing.com

Mayer, P., W. DeOreo, J. Kiefer, E. Opitz, B. Dziegielewski, and J.O. Nelson. 1999. Residential
End Uses of Water. Water Research Foundation, Denver, CO.

6 | Page


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Summary of Comments on Notice of Recent Specifications Review
and Request for Information on WaterSense Program

Commenter: Mike Collignon, Executive Director
Affiliation: Green Building Coalition
Comment Date: July 22, 2020
Document ID: EPA-HQ-OW-2020-0026-0112

Comment Text:

The Green Builder® Coalition is a not-for-profit association dedicated to amplifying the
voice of green builders and professionals to drive advocacy and education for more
sustainable home building practices. We unite individual small builders, building
professionals and suppliers to drive policy-change and education for more resource-
efficient home building standards.

Since February 2014, The Coalition has been working on the development of the
residential industry's first performance-based water rating system. Known by the name
of WERS, our program has been in significant use for over 3 years. In that time, over
600 single-family properties have utilized the program. Data has been collected on a
wide range of residential properties, from production to custom. We are seeing
WaterSense products used in all types of single-family properties. It is important to note
that where the WERS Program is being used, there is not a code requirement for
WaterSense products, nor does the WERS Program require their usage. The
installations are voluntary. It's hard to imagine a large number of homeowners would
voluntarily request and regularly use these water-saving products if they weren't satisfied
with them.

There are other notable organizations, some of which are our partners, who have
already submitted information on the performance aspects of WaterSense products. We
concur with their findings, and have the data to back up their claims. But the other
element of customer satisfaction that might get overlooked is customer satisfaction of
the water utilities. If we don't continue to utilize, and increase the use of, WaterSense
products, we'll start to see water shortages in the American West. That will most
certainly lead to unhappy customers.

We've all seen reports of rolling brownouts in the West when it comes to electricity.
People can get by for a brief time without electricity. You can't have rolling "blue-outs".
People need water. The management of this essential resource is critical to all facets of
life, from public health to the economy. Once water leaves an area, all life leaves with it.

The WaterSense Program finally received Congressional authorization in 2018. That
was long overdue, but it also wasn't by accident. This is a vital program to help industry,
municipalities, utilities and the general public conserve one of the most precious
elements on our planet. We cannot take water for granted, and we cannot dial back on
conservation and efficiency efforts. The WaterSense Program must remain fully intact.

Mike Collignon
Executive Director
Green Builder® Coalition

4

EPA

WaterSense

294

August 2020


-------