EPA
Water Sense
Response to Public Comments Received on the
Draft of the WaterSense® Labeled Homes Program,
Version 2
February 2021
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WaterSense
Response to Comments on the Draft
WaterSense Labeled Homes Program, Version 2.0
Background
This document provides the U.S. Environmental Protection Agency's (EPA's) responses
to public comments received on the draft WaterSense Labeled Homes Program, Version
2, which includes: the WaterSense Draft Home Certification System, Version 2.0; the
WaterSense Draft Specification for Homes, Version 2.0; and the WaterSense Draft
Technical Evaluation Process for Approving Home Certification Methods. For the
purposes of this document, the comments are summarized and paraphrased. The
verbatim comments can be viewed in their entirety at www.epa.gov/watersense/homes-
specification-backqround.
Within this document, unless otherwise noted with the version number, it should be
assumed mention of the WaterSense Home Certification System and WaterSense
Specification for Homes refers to the Version 2.0 documents—draft or final, as specified.
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epa Response to Comments on the Draft
WaterSense WaterSense Labeled Homes Program, Version 2.0
Table of Contents
I. General Comments on WaterSense Labeled Homes Program Revision 1
1.1 General Support 1
1.2 Editorial Suggestions 1
1.3 Potential WaterSense Approved Certification Methods (WACMs) 1
1.4 Harmonization Wth ENERGY STAR® and Other Green Building Programs.2
1.5 Complications Resulting From Multiple HCOs and WACMs 3
1.6 Define "Typical Home" 5
1.7 Recommendations for Transition to Version 2 6
II. Comments on WaterSense Draft Home Certification System, Version 2.0 8
11.1 Define Relationship Between PCM and WACM 8
11.2 Organizational Requirements 9
11.3 Incorporate Additional Quality Assurance (QA) Guidelines 9
11.4 Modify Independent Oversight Requirements 10
11.5 Allowing Other Organizations to Authorize Program Elements 10
11.6 Verifier Recognition 12
11.7 Sampling Protocol Options 12
11.8 Public Lists of Verifiers and Certified Homes 13
11.9 Data Reporting Requirements 14
11.10 Certification Method Approval 14
11.11 Alternative Certification Method Development Processes 15
11.12 Potential for Outdated WACMs 17
III. Comments on the WaterSense Draft Home Specification, Version 2.0 18
111.1 30 Percent Water Efficiency Requirement 18
111.2 Inclusion of Irrigation Requirements 19
111.3 Leak Detection Devices 23
111.4 Providing Verifier Training for Leak Detection 24
111.5 Need for Structured Plumbing Criteria 24
111.6 Harmonization Wth State and Local Standards 26
111.7 Appendix A Not Sufficiently Detailed 26
111.8 Maintaining a Prescriptive Path 27
IV. Comments on WaterSense Draft Technical Evaluation Process for Approving
Home Certification Methods 27
IV. 1 Request to Evaluate the Water Demand Calculator 27
IV.2 Source of Data on Household Water Use 28
IV.3 Baseline Home Not Well-Defined in Technical Evaluation 29
IV.4 Landscape Area References 30
IV.5 Reference Home Physical Parameters 31
IV.6 Limitations for Multiple Showerheads 41
IV.7 Source of ET0 Data Outdated 42
IV.8 Method for Estimating Outdoor Water Use 43
IV.9 Emphasize Efficient Irrigation 44
IV.10 Allowing Xeriscaping in Non-Arid Regions 45
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IV. 11 Removing References to "Supplemental" Irrigation 46
V. Other Miscellaneous Comments 46
V.1 Fate of Other WaterSense Program Resources 46
V.2 Suggestions for the WaterSense Specification for Weather-Based Irrigation
Controllers 47
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WaterSense
Response to Comments on the Draft
WaterSense Labeled Homes Program, Version 2.0
I. General Comments on WaterSense Labeled Homes
Program Revision
1.1 General Support
Four commenters submitted comments of support for EPA's effort to revise
the WaterSense Labeled Homes Program.
Two commenters commended EPA for incorporating additional flexibility
within the WaterSense Homes Program.
Response: EPA thanks the commenters for their support.
1.2 Editorial Suggestions
One commenter indicated that the naming convention of the documents
associated with Version 2 of the WaterSense Labeled Homes Program was
confusing. The commenter said that the document names were too long and
similar, and recommended that EPA shorten the titles, include a summary
and purpose statement for each document, and add a preface to each
document referencing other related documents.
Response: EPA has decided to retain the document naming convention for
the homes program documents, as they are consistent with document
naming conventions in other areas of the WaterSense program. However,
EPA agrees that the intent of the documents could be made clearer. As such,
EPA has modified the introductions in the WaterSense Home Certification
System and the WaterSense Technical Evaluation Process for Approving
Home Certification Methods to articulate the documents' purpose and
relationship with other program documents. Program documents applicable to
the verification, certification, and labeling of homes for WaterSense are also
summarized in Table 1 of the WaterSense Home Certification System.
1.3 Potential WaterSense Approved Certification Methods (WACMs)
One commenter indicated that their organization supports the market-based
approach of the revised WaterSense Labeled Homes Program and flexibility
included in the technical requirements. The commenter indicated that the
Home Certification Organization (HCO) structure would be beneficial because
builders and developers could choose their preferred certifying body. The
HCO structure would also enable existing residential labeling programs to
participate in the certification and labeling of homes to WaterSense criteria.
The commenter suggested there is potential for the International Code
Council (ICC)/American Society of Heating, Refrigerating and Air-
Conditioning Engineers (ASHRAE)-700 National Green Building Standard
(NGBS) to be recognized as a WaterSense Approved Certification Method
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(WACM), providing builders and developers with the opportunity to pursue
both NGBS certification and the WaterSense label.
Two commenters indicated that EPA should consider approving the
International Association of Plumbing and Mechanical Officials' (lAPMO's)
Water Efficiency and Sanitation Standard (WE'Stand) as a WACM. The
commenters suggested that WE'Stand could qualify as a WACM because it
was developed by a technical committee composed of well-respected subject
matter experts under an American National Standards Institute (ANSI)
accredited consensus development method.
Response: EPA thanks the commenters for their support of the WaterSense
Labeled Homes Program, Version 2 structure. EPA will consider NGBS and
WE'Stand as potential WACMs, as appropriate, if they are submitted as part
of a prospective HCO's application.
1.4 Harmonization With ENERGY STAR® and Other Green Building
Programs
One commenter suggested that it would be advantageous to offer a labeling
program combining ENERGY STAR and WaterSense certifications. The
commenter stated that a combination label would provide the benefits of both
programs and streamline recordkeeping and reporting for builders. The
commenter acknowledged that although the combination label might not be
possible at this time, EPA could consider it in the future.
A second commenter recommended that WaterSense discard its proposed
certification scheme under Version 2 of the WaterSense Labeled Homes
Program and instead consider a certification structure that aligns with existing
voluntary third-party conformity assessment processes. In particular, the
commenter suggested that it would be useful to align the certification
structure of the ENERGY STAR and WaterSense programs. The commenter
observed that verifiers must use similar analytical processes to evaluate
similar technical characteristics when certifying a home to either label. A
combined label could increase the market value and adoption of ENERGY
STAR and WaterSense in residential construction, maximize their
attractiveness to builders, and allow verifiers to bundle the certification.
Response: Wth Version 2 of the WaterSense Labeled Homes Program, EPA
has made strides to align the certification and verification requirements for
homes with those stipulated by the ENERGY STAR Certified Homes
Program. The revision is intended to enable better coordination among the
programs and significantly reduce the additional burden required to
administer and achieve both labels. ENERGY STAR and WaterSense
recognize the benefits of aligning program requirements and will continue to
work closely to create additional program synergies.
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In general, the revised program structure allows HCOs to leverage and use
existing certification and verification processes and program requirements to
label homes for WaterSense. As such, HCOs and verifiers should be able to
offer the WaterSense label along with other water efficiency or green building
certifications.
1.5 Complications Resulting From Multiple HCOs and WACMs
a. One commenter said that the HCO structure was likely to increase market
uncertainty and instability. The commenter said that HCOs could join or leave
the program quickly, which would make it challenging for verifiers to
anticipate possible WACMs and counsel their clients accordingly.
Two commenters said that the revised program structure—and in particular,
the fact that multiple WACMs would be allowed—could increase
inconsistency across HCOs. One of the commenters suggested that it would
be more advantageous and add flexibility to instead create default water
budgets based on a home's occupancy, number of fixtures, presence of
leaks, and lot size. The other commenter indicated that the program structure
could foster mistrust among builders because the same home might not
qualify for the WaterSense label under all WACMs. Additionally, the
commenter said that builders would be likely to select the easiest and
cheapest WACM available for their area, reducing competition among HCOs.
Response: EPA does not anticipate a significant number of HCOs joining and
leaving the program quickly. Although HCOs may need to make modifications
to their organizational practices or certification criteria to be approved by EPA
to offer the WaterSense label, EPA expects to sign licensing agreements with
established water efficiency and green building programs. In addition, the
organizational requirements included in Section 4.1 (and Section 4.2, if
applicable) of the WaterSense Home Certification System are such that a
prospective HCO will need to put forward sufficient commitment and
resources to sustain and administer their certification program. Similarly,
Section 4.3 of the WaterSense Home Certification System requires that
certification methods be developed through an ANSI consensus-based
standards development process or equivalent or, for public agencies,
following the administrative and transparency requirements by a jurisdiction
having authority. It is, therefore, unlikely that an organization would develop
its Proposed Certification Method (PCM) without sufficient notice and input
from relevant stakeholders and a long-term commitment in mind.
WaterSense also acknowledges that homes with different features could
qualify for the WaterSense label depending on the WACM(s) available in
different locations. This flexibility is intentional, allowing EPA to approve
PCMs that can adapt to varying regional priorities based on different climates,
local code requirements, and building practices. However, regardless of the
particular features included, all homes will have to meet a minimum water
efficiency requirement (per the WaterSense Specification for Homes)
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compared to a home with characteristics typical of new construction. As
described in the WaterSense Technical Evaluation Process for Approving
Home Certification Methods, EPA assesses each PCM across a broad range
of home physical attributes to ensure that the program can effectively and
consistently differentiate homes that meet the water efficiency requirement.
EPA also evaluates the HCO's organizational structure, as outlined in the
WaterSense Home Certification System, to ensure they have the minimum
processes and infrastructure in place to protect and maintain the integrity of
the WaterSense label. HCOs will be able to compete for business based on
their programs; builders will know that all HCOs will offer programs that meet
the minimum water efficiency requirement and will be free to choose the most
appropriate HCO and WACM in their area that offers the program structure
and requirements that are most conducive to their needs; and consumers can
have confidence in the water savings associated with WaterSense labeled
homes.
b. Two commenters expressed concern that stakeholders would not be aware of
organizations applying to become HCOs. The commenters requested that
EPA develop a mechanism to share the names of prospective HCOs, so that
other organizations could be aware of applicants and contact the prospective
HCO as it is developing its PCM. The commenters said that external
organizations could benefit prospective HCOs by helping them design PCMs
that maximize water efficiency.
One of the commenters proposed a scenario in which requirements for
openness would not be satisfied, even if prospective HCOs used an ANSI-
approved process. Some stakeholders might not have relationships with a
prospective HCO and could therefore be denied the opportunity to participate
in the development of its PCM.
The commenter said that EPA should require that prospective HCOs notify
national organizations representing relevant stakeholders, such as the
Irrigation Association (IA) or Alliance for Water Efficiency (AWE). EPA could
provide prospective HCOs with a list of organizations and their contact
information so stakeholders could directly contact prospective HCOs and
become involved in the PCM development. The commenter said that this
solution would not create a substantial burden and would avoid concerns
about EPA directly disclosing information about a "deliberative process."
The other commenter suggested that EPA publish an online list of
prospective HCOs and their contact information so stakeholders could
contact them as they develop their PCMs.
Response: EPA understands and appreciates that stakeholders desire to
engage with prospective HCOs and promote water efficiency. EPA has
established requirements to ensure that a PCM is developed in an open and
transparent process with a balance of stakeholder interests (see Section 4.3
of the WaterSense Home Certification System) and will ensure these
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requirements are met as part of its review of the HCO's application. Further,
prospective HCOs will apply to EPA after the development of their PCMs.
Therefore, EPA notifying stakeholders of an HCO's application would not
necessarily allow for additional stakeholder engagement in the development
of the PCM. To avoid sharing information about a deliberative process, EPA
intends to leave publicity surrounding an HCO's application to the discretion
of the HCO. Once an HCO (and its respective WACM) are approved,
stakeholders will be able to engage with the HCO on future revisions to its
certification method.
EPA also recognizes that there are numerous stakeholder organizations that
might be interested in engaging with prospective HCOs, however, EPA is not
in a position to provide a comprehensive list or determine which of these
organizations would be appropriate to serve as a conduit to ensure that
balance in the development of PCMs is achieved.
1.6 Define "Typical Home"
Four commenters stated that the draft specification and other program
documents referenced terms such as "typical home" and "typical new
construction" without sufficiently defining them. The commenters said that it
would be particularly important to define these terms since they are used as a
basis of comparison for the 30 percent water efficiency requirement.
One of the commenters suggested that a "typical home" should be defined as
a home built to the Energy Policy Act (EPAct) of 1992 requirements. This
commenter added that EPA should define all parameters of a typical home,
including landscape and irrigation requirements by climate. Another
commenter said that there are a number of codes that potentially could be
adopted throughout the United States, and that EPA should specify the
applicable codes and standards.
Response: In response to these comments, EPA incorporated a new
description of "characteristics typical of new construction" in the WaterSense
Technical Evaluation Process for Approving Home Certification Methods.
Subsequently, EPA updated references to the term "typical home" in the final
specification, certification system and WaterSense Technical Evaluation
Process for Approving Home Certification Methods to instead refer to "a
home with characteristics typical of new construction." This term is meant to
describe characteristics of a home with features that meet national standards
and common design and landscape practices. EPA has also removed
reference to "national codes" in its definition, since no plumbing or building
codes are referenced in the WaterSense Technical Evaluation Process for
Approving Home Certification Methods. For plumbing products, such as
toilets and showerheads, "typical" efficiency is defined by EPAct 1992.
Efficiency requirements related to hot water distribution, landscaping and
irrigation design are not as easily defined on a national scale. Therefore, in
these instances, EPA used the best available data to determine what could
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be considered "typical." All assumptions, subsequent water use calculations,
and citations are provided in the WaterSense Technical Evaluation Process
for Approving Home Certification Methods.
EPA has also included definitions for "reference home," "baseline
configuration," and "water-efficient configuration" to better define and
differentiate these terms and explain how EPA will use the WaterSense
Technical Evaluation Process for Approving Home Certification Methods to
approve PCMs that consistently differentiate homes that meet WaterSense's
water efficiency requirement from homes that do not. EPA acknowledges that
a clear understanding of "characteristics typical of new construction" is both
challenging and fundamental to developing a PCM.
1.7 Recommendations for Transition to Version 2
a. One commenter inquired about homes that could not meet the proposed
construction/inspection schedule in advance of the transition to Version 2 of
the WaterSense Labeled Homes Program. In the WaterSense Draft
Specification for Homes Supporting Statement, EPA suggested that homes
permitted within six months of the publication date of the WaterSense
Specification for Homes, Version 2.0, could still be certified to the
WaterSense Specification for New Homes, Version 1.2, as long as the final
inspection was completed within 12 months (one year) of the publication
date. The commenter agreed with EPA's suggested grace period for homes
to be permitted (i.e., six months), but suggested that builders should not have
a deadline to construct the home and complete the final home inspection.
Response: EPA agrees that it is necessary to incorporate a transition period
to ensure that stakeholders can successfully prepare for Version 2 of the
WaterSense Labeled Homes Program. Furthermore, EPA realizes that this
will be particularly critical for builders who have been planning to construct
and certify homes to meet the WaterSense Specification for New Homes,
Version 1.2. However, because EPA depends on third-party stakeholders
(i.e., the Residential Energy Services Network [RESNET] and licensed
certification providers) to operate Version 1.2 of the WaterSense Labeled
Homes Program, it must negotiate and establish a reasonable transition
period to ensure certification and verification services are still available for
builders. It is therefore not practical to provide builders with no deadline to
construct a home and complete an inspection for Version 1.2 of the program.
EPA is seeking a balance between supporting Version 1.2 of the program
and moving towards Version 2 while still ensuring a period of transition that
gives participating builders time to adjust.
Concurrent with the release of materials related to Version 2 of the
WaterSense Labeled Homes Program, EPA published a document to
summarize the transition to Version 2 that includes the latest proposed
schedule. See the WaterSense Labeled Homes Program Transition to
Version 2 for more details.
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b. One commenter acknowledged EPA's proposed implementation schedule
and said that EPA should consider immediately allowing nationally
recognized certifiers to operate as WaterSense HCOs. As these existing
national certification organizations prepare for Version 2 of the WaterSense
Labeled Homes Program, this would place them on equal footing with
organizations currently involved in the certification of WaterSense labeled
homes under Version 1.2 of the program.
Response: EPA recognizes that the home certification marketplace is diverse
and lacks consistency that would lend itself to uniformly recognizing all
existing certification organizations. Wth Version 2 of the WaterSense
Labeled Homes Program, EPA intends to accommodate HCOs that use
different approaches and structures to achieve the same end goal of
certifying and labeling homes that are more water-efficient than a baseline
home with characteristics typical of new construction. However, EPA has
established a minimum set of organizational requirements, outlined in Section
4.1 of the WaterSense Home Certification System that ensure competency
and that certification is conducted in a fair and consistent manner. These
minimum requirements are intended to be protective of the WaterSense
brand. EPA will evaluate any organization against these minimum
requirements prior to HCO approval.
EPA retains the right to provisionally approve HCOs that do not fully meet or
have not yet documented adherence to EPA's organizational and certification
method development requirements (as set forth in Sections 4.1, 4.2 [if
applicable], and 4.3 of the WaterSense Home Certification System). For any
requirement for which an HCO is provisionally approved, EPA will work with
the HCO to develop a plan that outlines the conditions and timeline for full
compliance with the requirements. These terms will be detailed in the HCO's
licensing agreement with EPA. While EPA intends to issue provisional
approval to help accommodate HCOs into the program sooner, this process
also permits EPA to establish clear milestones that HCOs will be required to
meet to be fully approved. Prospective HCOs would only be eligible for
provisional approval if 1) their PCM, when evaluated in accordance with the
WaterSense Technical Evaluation Process for Approving Home Certification
Methods, can differentiate homes that meet the water efficiency requirement
of the WaterSense Specification for Homes; and 2) they meet core
organizational and certification method development requirements. The
specific requirements that may be considered for provisional approval are
identified in EPA's Application for Home Certification Organization (HCO) and
Proposed Certification Method (PCM) Approval.
c. One commenter predicted that there would be a delay in enrollment as
prospective HCOs apply for approval and as verifiers assess whether they
want to inspect homes to earn the WaterSense label. The commenter
indicated that this delay would likely limit the organization's ability to evaluate
multifamily buildings for WaterSense certification and labeling.
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Response: Some delays are inherent to major program updates. The
availability of certification options for multifamily buildings is dependent on
prospective HCOs applying and being approved using a PCM that
accommodates multifamily buildings or units.
To facilitate continued participation in the WaterSense Labeled Homes
Program by EPA's various stakeholders, including existing builders, raters,
and providers, and enable a smoother transition to Version 2, EPA published
a revised WaterSense Home Certification System (Version 1.3) in May 2020.
The revision helped bridge the gap between Version 1.2 and Version 2.0 of
the certification system and established the necessary certification
infrastructure to operate Version 2 of the WaterSense Labeled Homes
Program. EPA subsequently approved an HCO—RESNET—in accordance
with Version 1.3 of the certification system and instituted a pilot program to
certify and label homes following the draft Version 2 program requirements
and specification criteria. RESNET's approval included a review of its PCM—
HERSh2o—by EPA to ensure its ability to differentiate homes that meet
WaterSense's water efficiency requirement. The HCO has subsequently
certified approximately 200 homes in Southern Nevada as part of this pilot,
and already has the infrastructure in place to implement its program on a
national scale for single-family homes.
From the implementation of the pilot, EPA identified and made minor
clarifications to the WaterSense Home Certification System, Version 2.0. As
discussed in the WaterSense Labeled Homes Program Transition to Version
2, EPA has extended full approval and licensure under Version 2 to HCOs
that participated in the pilot program. This includes approval of their
associated WACMs. Therefore, builder partners can immediately begin
applying for the WaterSense label in accordance with Version 2 of the
WaterSense Labeled Homes Program. Further, homes and multifamily units
previously planning to earn the label using the WaterSense Specification for
New Homes, Version 1.2 will be able to continue to do so during EPA's
transition to Version 2 of the program. See the WaterSense Labeled Homes
Program Transition to Version 2 for more details.
II. Comments on WaterSense Draft Home Certification
System, Version 2.0
11.1 Define Relationship Between PCM and WACM
a. One commenter said that EPA introduced the concept of the PCM and the
process of review and approval without providing sufficient context. The
commenter suggested that, when it first references the PCM, the WaterSense
Home Certification System should provide more context about the definition
of a PCM and its relationship to the WACM.
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Response: EPA agrees with this comment and has updated the WaterSense
Home Certification System to explain the relationship between a PCM and
WACM.
11.2 Organizational Requirements
A commenter indicated that their organization was supportive of the
organizational requirements and requirements for the certification method
development process as outlined in the certification system.
Response: EPA thanks the commenter for their support.
11.3 Incorporate Additional Quality Assurance (QA) Guidelines
One commenter observed that Version 2 of the WaterSense Labeled Homes
Program reduces the number of mandatory requirements, recognizes that
outdoor water use depends on regional climate, and allows for a variety of
WACMs. The commenter encouraged EPA to maintain high quality
assurance requirements for HCOs to ensure consistency and rigor among
providers (i.e., designees).
In particular, the commenter suggested that EPA provide more direction to
HCOs regarding quality assurance requirements. The commenter
encouraged EPA to develop a procedure for conflict resolution, guidelines for
disciplining verifiers, and a mechanism for individuals to submit complaints
about HCOs directly to EPA.
Response: EPA recognizes the importance of quality assurance in
maintaining the integrity of WaterSense labeled homes. EPA will evaluate
each HCO that applies for approval to ensure their quality assurance
protocols meet the intent of the WaterSense requirements and are rigorous
enough to maintain the integrity of the WaterSense label.
HCOs are responsible for handling verifier complaints and discipline, and
prospective HCOs are required to demonstrate that they have procedures in
place as part of the approval process. EPA also recognizes its role in
providing HCO oversight. In Section 7.0 of the WaterSense Home
Certification System, EPA established its right to audit operations and records
of an HCO and to conduct periodic in-home inspections.
Based on the commenter's suggestions, EPA has added language to the
WaterSense Home Certification System to elaborate on and strengthen
EPA's role in providing oversight of HCOs. The new language includes
information about submitting complaints about an HCO to EPA. See Section
7.0 of the WaterSense Home Certification System for more details.
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11.4 Modify Independent Oversight Requirements
One commenter said that the proposed composition of the independent
oversight committee, included within Section 4.1.1 of the WaterSense Draft
Home Certification System, was too prescriptive and represented a potential
constraint for prospective HCOs. The commenter was also concerned about
the fact that the requirement would force HCOs to share client business
information with external parties.
The commenter explained that an internal oversight approach would also
meet EPA's goal of ensuring fair and impartial oversight, while offering
quicker responses and controlling access to information. The commenter said
that an internal oversight committee could meet EPA's goals if its members
did not have a direct vested interest in the outcome of certification decisions.
The commenter provided an example of their organization's internal oversight
program, which is modeled on quality assurance requirements for certification
programs accredited to International Organization for Standardization (ISO)
17065. In this oversight committee, team members can promptly meet to
discuss and evaluate appeal requests. Discussions about specific projects or
partner companies are kept confidential, but the oversight committee
publishes decisions that pertain to a broader set of stakeholders. This
process offers transparency and provides information on certification
decisions to those working on active projects.
Response: EPA agrees that an internal oversight committee could include
checks and balances that could be just as rigorous as, or more rigorous than,
an oversight committee with external members. Therefore, EPA has
amended its oversight requirements within Section 4.1.1 of the WaterSense
Home Certification System to focus on the intent of fair and impartial
oversight, rather than the specific makeup of the oversight body. Specifically,
EPA amended the language to require HCOs to demonstrate that the
personnel responsible for oversight of their program are not involved in the
routine program operations or certification decisions. These changes
maintain the intent behind EPA's initial requirements presented in the
WaterSense Draft Home Certification System, but add flexibility for
prospective HCOs in conducting oversight.
11.5 Allowing Other Organizations to Authorize Program Elements
One commenter submitted a suggestion that EPA allow other external
organizations to authorize elements of Version 2 of the WaterSense Labeled
Homes Program. The commenter suggested that the following entities could
approve the elements of the program in lieu of EPA, as follows:
• Organizational structure (Section 4.1 of the home certification system):
An EPA-recognized, United States-based International Laboratory
Accreditation Cooperation (I LAC) signatory for product certification
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could evaluate an HCO's organizational structure and processes
proposed to be used for the verification, certification, and labeling of
homes for WaterSense.
• Verifier Training (Section 4.1.3): An EPA-recognized curriculum and
training agency accredited by a United States-based accreditation body
could train and authorize verifiers.
• PCM Evaluation (Section 4.4): An EPA-recognized, United States-
based I LAC signatory for product certification could evaluate the
technical efficacy of an HCO's PCM in accordance with the WaterSense
Technical Evaluation Process for Approving Home Certification
Methods.
• Overall Approval (Section 5.0): An EPA-recognized, United States-
based I LAC signatory for product certification could evaluate an HCO's
organizational structure and PCM prior to licensing the HCO to certify
and label homes.
By way of justification, the commenter indicated that EPA currently approves
private accreditation bodies to accredit WaterSense product certifiers. The
commenter said that EPA has therefore recognized that those organizations
meet a level of rigor and that it is efficient to leverage private companies for
accreditation. If organizations were required to be ILAC signatories, they
would have been peer-reviewed in accordance with the requirements of
ISO/I EC 17011: Conformity assessment - Requirements for accreditation
bodies accrediting conformity assessment bodies, published by ISO.
Similarly, the commenter suggested that EPA could utilize existing
accreditation programs for training and curriculum development.
Response: EPA does not believe it is appropriate to allow other organizations
to authorize elements of the program at this time. While there is an
established protocol for managing and overseeing the certification process for
products and multiple organizations available to carry out the certification
process, a similar infrastructure and level of experience does not currently
exist in the homes sector. It is possible that in the future, when EPA has had
more experience with Version 2 of the WaterSense Labeled Homes Program
and the industry develops additional capacity for home certification, there
may be a way to transition some roles to other organizations.
Wth respect to verifier training, the majority of verifier training will be
HCO/WACM-specific, and therefore the HCO will be responsible for training
and authorizing verifiers, not EPA. EPA will provide some minimum content
that will be incorporated into the HCO's training to explain the WaterSense
Labeled Homes Program, responsibilities of the verifier for WaterSense, and
verification of the features specified on the Mandatory Checklist. However,
each HCO's training will be specific to its WACM and certification
requirements. Through this process, EPA intends to recognize the existing
infrastructure of certification programs. HCOs, at their own discretion, can
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11.6
11.7
choose to utilize outside agencies or organizations (i.e., designees) to
conduct verifier training and authorization.
Verifier Recognition
One commenter said their company was very interested in its staff becoming
verifiers, but that it would prefer a national verifier credential. Their company
does not intend to apply to be an HCO and would therefore not be qualified to
formally authorize verifiers.
Response: Verifier training and authorization will be tied to each HCO and its
WACM. Because prospective HCOs and their WACMs are expected to vary
in their approach to the verification and certification of WaterSense labeled
homes, EPA cannot establish verifier training that would apply to all possible
HCOs and their WACMs. However, all verifiers interested in verifying homes
in accordance with the WaterSense Specification for Homes are required to
complete a WaterSense program-specific training that is intended to provide
an introduction to WaterSense and the WaterSense Labeled Homes Program
and establish verification requirements related to the Mandatory Checklist.
The HCOs are required to provide reciprocity for verifiers who have
completed the WaterSense program-specific training under another HCO.
EPA recognizes the important role the verifiers play in marketing the program
and ensuring homes meet the criteria of the WaterSense Specification for
Homes; therefore, EPA is promoting verifiers through other elements of
Version 2 of the WaterSense Labeled Homes Program. For instance,
approved verifiers will be listed on the WaterSense website and will be
provided a verifier mark that can be displayed on websites and promotional
materials to advertise verification services for the WaterSense Labeled
Homes Program.
Sampling Protocol Options
One commenter said that their company is anticipating growth in the
WaterSense labeled multifamily homes market as a result of changes to the
structure under Version 2 of the WaterSense Labeled Homes Program,
particularly changes to hot water delivery criteria. Because of this, the
commenter encouraged EPA to establish a national sampling protocol. The
lack of a national sampling protocol could introduce substantial uncertainty to
their company's national pricing strategy and limit its ability to promote
WaterSense to new clients.
Response: WaterSense aimed to increase flexibility and limit prescriptive
requirements in Version 2 of the WaterSense Labeled Homes Program. This
will enable existing water efficiency or green building certification programs to
offer the WaterSense label without undue additional burden. As such, the
WaterSense Home Certification System allows HCOs the option of
establishing a sampling protocol and enables it to set the requirements to suit
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their needs. Verifiers, in turn, can choose to work with one or more HCO(s)
that align with their business practices to verify homes to earn the
WaterSense label.
b. One commenter observed that, in the WaterSense Draft Home Certification
System, Version 2.0, EPA has expanded on the sampling protocol included in
Section 7.2.2 of the WaterSense New Home Certification System, Version
1.2. The commenter said that their organization supports the continued option
for builders to use a sampling protocol if applicable. The commenter said that
this was an example of flexibility that would encourage builder participation by
offering cost-effective certification pathways.
Response: EPA acknowledges this comment in support of the proposed
approach to authorizing a sampling protocol.
II.8 Public Lists of Verifiers and Certified Homes
One commenter said that HCO requirements related to recordkeeping and
reporting should be stronger to provide increased transparency and potential
market transformation. The commenter recommended that EPA require
HCOs to maintain public registries of authorized verifiers and certified homes.
The commenter went on to say that a verifier registry would help advertise
verifiers' services, supporting the growth of Version 2 of the WaterSense
Labeled Homes Program. It would also allow builders and developers to
confirm verifiers' credentials.
Further, the commenter suggested that by maintaining a public listing of
certified homes, real estate professionals and appraisers could ensure that
homes with water-efficient features are valued and marketed appropriately.
The commenter said that consumer market demand for WaterSense labeled
homes could be bolstered by access to information on green home features
and certifications.
Response: As indicated in Section 4.1.6 of the WaterSense Home
Certification System, EPA requires that HCOs maintain a list of authorized
verifiers and report the information at least quarterly for EPA to make public
on the WaterSense website, as appropriate. However, individual HCOs are
responsible for deciding whether to establish and maintain their own public
listing of authorized verifiers specific to their programs. EPA recognizes that it
might not be appropriate for HCOs to publicize their lists of authorized
verifiers. For example, a public agency or utility could use internal staff to
conduct home verifications and might not want to publicize employee
information. Should there ever be a question about the qualifications of a
specific verifier, the WaterSense Helpline is available to offer clarification and
coordinate with the relevant HCO(s).
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Due to respect for homeowners' privacy, EPA does not intend to collect
information on addresses for individually labeled homes. However, EPA does
require that the HCOs maintain documentation, which includes the address or
lot number of all certified homes. HCOs may, at their own discretion, choose
to make this information publicly available.
11.9 Data Reporting Requirements
One commenter encouraged EPA to specify the information that HCOs are
required to report to WaterSense. The commenter suggested that HCOs
should report, at a minimum, the following for each home that receives the
WaterSense label: date of certification, the applicable version of the
WaterSense Specification for Homes, software version (if applicable to the
WACM), builder partner company name and physical address, energy rating
index, and verifier name, company name, and contact information. The
commenter said baseline data requirements would help standardize the
information collected across HCOs, increase the visibility of the WaterSense
Labeled Homes Program, and enable EPA to readily compare homes that
receive the WaterSense label. The requirements could also facilitate
consistent data sharing with external organizations such as the Multiple
Listings Services (MLS).
Response: EPA has established quarterly reporting requirements for HCOs;
however, EPA is only collecting general information in the quarterly report
sufficient to understand the number and general locations of certified homes.
EPA requires the HCOs to maintain the specific documentation for each
certified home. As described in Section 4.1.4 of the WaterSense Home
Certification System, this includes: the builder partner contact information;
address or lot number of the home; documentation of verification results;
name and contact information for the verifier; and the home verification date.
As a result of this comment, EPA is also including a requirement to track the
WACM version under which a home is certified.
EPA cannot at this time provide more specific reporting requirements
because it recognizes that the different HCOs might not rate, score, or
assess a home's compliance with its WACM requirements in the same way.
However, through the recordkeeping requirements, EPA can access
additional information on individual certified homes if it becomes relevant or
necessary in the future.
11.10 Certification Method Approval
One commenter suggested that EPA add language to the program
documents to allow well-established green building programs to apply to
become HCOs even if they do not meet all of EPA's requirements. The
commenter said that it would be unfortunate for an existing certification
program to be excluded if its certification method development process was
established before Version 2 of the WaterSense Labeled Homes Program,
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and therefore did not include a formal comment period and/or established
appeals process.
The commenter suggested that these programs could be approved as
WACMs through a grandfathering process. Eligibility could be based on the
duration of the green building program's operation, the number of buildings
that had been certified under the program, or a letter of recommendation from
a local jurisdiction or water utility. The commenter suggested that if a green
building program was potentially acceptable, it could be granted provisional
approval, with the condition that it hold public comments and revise its
program within a stated period of time.
Response: EPA recognizes that prospective HCOs may have established
home certification programs that were developed prior to the publication of
Version 2 of the WaterSense Labeled Homes Program, and thus may not
fully comply with program requirements outlined in the WaterSense Home
Certification System at the time of its release. As discussed in Section 1.7 of
this document, EPA may provisionally approve HCOs on a case-by-case
basis where they have undergone a fairly rigorous development process but
might not fully meet EPA's organizational and certification method
development requirements (as set forth in Sections 4.1, 4.2 [if applicable],
and 4.3 of the WaterSense Home Certification System). As a condition for
approval, EPA will establish a plan and timeline for full compliance.
EPA maintains that public input has a significant influence on the ultimate
requirements included in a PCM; therefore, all PCMs should be developed
through a process that engages a balance of perspectives and has gone
through open and public discourse. For PCMs not fully meeting the
certification method development requirements, EPA will closely assess the
level to which the PCM has undergone public discourse prior to extending
approval.
11.11 Alternative Certification Method Development Processes
a. One commenter suggested that EPA expand alternatives to certification
method development processes beyond those approved through ANSI. The
commenter suggested that the first option for approved certification method
development processes be updated to, "the technical requirements in the
PCM requirements are included in an ANSI approved standard that was
developed and approved through an ANSI consensus-based standard
development process or equivalent development process" (proposed new
text underlined). The commenter said that Office of Management and Budget
(OMB) Circular A-119 governs the federal government's recognition and use
of consensus-based standards. Through OMB Circular A-119, the
government recognizes consensus-based standards other than those
approved through ANSI, so EPA should accept those standards as options
for the certification method development process.
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Response: EPA concurs that OMB Circular A-119 recognizes consensus-
based standards other than those developed through an ANSI process. As
suggested by the commenter, EPA has updated the requirements in Section
4.3 of the WaterSense Home Certification System to permit an equivalent
consensus-based standard development process.
EPA has also outlined acceptable alternatives to using an ANSI standard
development process in Section 4.3 of the WaterSense Home Certification
System. These criteria for an equivalent development process are based on
the ANSI Essential Requirements but have been slightly modified to apply to
WaterSense.
b. Two commenters said that only PCMs developed in accordance with ANSI
approved standards should be eligible for approval. The commenters said
that WaterSense needs to comply with OMB Circular A-119, which requires
federal agencies to utilize voluntary consensus standards developed by
voluntary consensus standards bodies through meaningful "involvement from
a broad range of parties with no single interest dominating the decision-
making." The commenters observed that ANSI approved standards meet the
OMB Circular A-119 requirements. One of the commenters said that
standards should not be considered if they have not been developed through
a consensus-based process or if one category of stakeholder made the final
decision on technical provisions in the published standard.
Response: EPA respectfully disagrees with these comments. The OMB
Circular A-119 does not identify ANSI approved standards as the only
acceptable form of voluntary consensus-based standard. As such, EPA has
provided two alternative pathways for PCM development that are intended to
provide the same level of rigor as an ANSI standards development process
and thus meet the intent of the OMB Circular A-119. The alternative
certification method development requirements closely follow the ANSI
Essential Requirements or an equivalent consensus-based standard
development process, and thus have all the elements meant to ensure the
requirements were developed with input from a broad range of parties with no
single interest dominating the decision-making. By virtue, this collective set of
requirements prevents EPA from approving a certification method developed
by a single category of stakeholders and enables EPA to recognize a broader
set of PCMs (e.g., voluntary specifications) that have met the requirements
for openness and transparency but that have not necessarily gone through an
ANSI standard development process.
c. One commenter wrote to express support for Section 4.3 of the WaterSense
Draft Home Certification System. The commenter said that prospective HCOs
might not have used the ANSI standard development process and might not
be public agencies. The commenter appreciated that EPA provided a
pathway for prospective HCOs to use other certification method development
processes.
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Response: EPA has noted this comment of support for the alternative
development requirements option for the certification method development
process.
d. One commenter stated that HCOs should be required to develop a
transparent methodology to estimate outdoor water use so builders and
irrigation installers can understand the calculations.
Response: Section 4.3 of the WaterSense Home Certification System
includes requirements for the certification method development process that
will help ensure that the HCO's method was developed through an open and
transparent process. This process will allow industry stakeholders, such as
builders, manufacturers, irrigation professionals, and other interested parties,
to understand the HCO's methodology(ies) for estimating outdoor water use
and promoting water efficiency.
11.12 Potential for Outdated WACMs
One commenter indicated that Section 4.0 of the WaterSense Draft Technical
Evaluation Process for Approving Certification Methods [and, by reference,
Section 4.4 of the WaterSense Draft Home Certification System] indicated
that EPA will recognize a WACM for five years. The commenter said this
could be problematic if the WACM depends on plumbing codes that could be
updated more regularly. For example, the UPC is revised every three years
and is not connected to other codes' revision cycles. As a result, baseline
conditions could potentially change more often than every five years,
resulting in a WACM that does not meet the 30 percent water efficiency
criteria. The commenter suggested that EPA require WACMs to be
reevaluated if the codes they reference are updated.
Response: Five years should be considered the maximum timeframe for
review. As described in Section 4.4 of the WaterSense Home Certification
System, HCOs are required to notify EPA if the requirements of the HCO's
WACM are revised prior to the five-year review period. Based on the
notification, EPA will make a decision if the WACM needs to undergo a new
technical evaluation to confirm that its ability to differentiate homes that meet
WaterSense's water efficiency requirement will be maintained.
Assumptions for determining baseline water use are included in the
WaterSense Technical Evaluation Process for Approving Certification
Methods. EPA intends to revisit these assumptions periodically to ensure
current national standards and available data used in its technical evaluation
reflect actual baseline conditions and are still appropriate for determining
whether the PCM can differentiate homes that are 30 percent more water-
efficient. If no changes have been made to the WACM at the end of the five
years, and EPA has updated or revised the WaterSense Technical Evaluation
Process for Approving Home Certification Methods, EPA reserves the right to
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re-evaluate an HCO's WACM to ensure that it can continue to differentiate
homes that meet the efficiency requirement.
III. Comments on the WaterSense Draft Home
Specification, Version 2.0
111.1 30 Percent Water Efficiency Requirement
a. One commenter observed that Section 1.0 of the WaterSense Draft
Specification for Homes, Version 2.0 indicates that the specification "is not
intended to contravene state and local codes and requirements." The
commenter noted that California has more stringent minimum code
requirements than other states, making it more challenging for homes in
California to satisfy an additional 30 percent water efficiency requirement.
The commenter suggested that this could result in fewer homes receiving the
WaterSense label in California.
Response: Given the objectives of the WaterSense program and its various
stakeholders, the program does not believe that a variable baseline for
homes based on state-level codes and standards is necessary, and that the
approach discussed in the WaterSense Technical Evaluation Process for
Approving Certification Methods is both reasonable and appropriate for a
national water efficiency label.
Rather, EPA intends for the WaterSense label to be awarded to homes that
are 30 percent more water-efficient than a home with characteristics typical of
new construction. Wthin its technical evaluation, EPA establishes baseline
water use based on national standards and common design and landscape
practices. Water-efficient homes built in accordance with PCM requirements
are compared to the baseline under a variety of home configurations to
evaluate whether the program requirements can consistently differentiate
homes that are 30 percent more water-efficient. Therefore, the baseline water
use for homes built in California is not impacted by the state's decision to
adopt more stringent building or efficiency codes.
The WaterSense Labeled Homes Program is a national program intended to
recognize homes that demonstrate water efficiency across the country.
However, the program structure has the flexibility to approve HCOs and their
respective PCMs that operate on a regional scale that take into account
regional water efficiency goals and standards. For example, an HCO could
operate in California and could adopt a certification method that requires
homes to achieve water efficiency greater than 30 percent. This PCM would
still be eligible for approval under the WaterSense Labeled Homes Program.
The program structure also provides flexibility to incorporate WaterSense,
even in states such as California that have adopted stricter state efficiency
codes and appliance standards. For example, municipalities and utilities
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might wish to promote the WaterSense label through rebates or other
incentives but mandate a higher efficiency than that required by the
WaterSense Specification for Homes. This could be done by requiring homes
to achieve a higher certification threshold or rating under a WACM.
b. One commenter said that there is no way to evaluate whether homes meet
the 30 percent water efficiency requirement relative to typical new
construction at this time. Since there are no PCMs or WACMs currently
available, the commenter said it was difficult to evaluate whether 30 percent
would be an appropriate value for a water-efficient home.
The commenter compared the requirements of the WaterSense Draft Home
Specification, Version 2.0 to other national water efficiency standards: the
LEED® Water Reduction Calculator, the RESNET HERSh2o® draft guidelines,
the WaterSense Water Budget Tool, and the Water Efficiency Rating System
(WERS). The commenter identified differences when they compared each
method to the WaterSense Draft Specification for Homes, Version 2.0.
Response: EPA established the 30 percent water efficiency requirement as a
metric for evaluating and approving certification methods and ensuring a
minimum level of water savings associated with homes that achieve the
WaterSense label. The 30 percent water efficiency requirement was arrived
at through an iterative process where EPA evaluated the water efficiency
achieved by existing green building programs, water-using products, and best
practices in home and landscape design.
EPA recognizes that there are multiple ways in which a home can achieve
the WaterSense water efficiency requirement. The Version 2 program
structure provides the flexibility to recognize the diverse structures and
requirements of existing home certification programs and seeks to leverage
those programs to increase the offerings of WaterSense labeled homes in the
market. As part of the approval process, EPA will evaluate each PCM to
determine whether certified homes can achieve at least a 30 percent
improvement in water efficiency relative to a home with characteristics typical
of new construction under a variety of potential scenarios and configurations.
The evaluation process and assumptions are described in the WaterSense
Technical Evaluation Process for Approving Home Certification Methods.
III.2 Inclusion of Irrigation Requirements
a. One commenter acknowledged that outdoor water use is influenced by
climate, irrigated area, irrigation technology, and landscape features, and
supported the elimination of mandatory outdoor water use reduction
measures to increase flexibility for home builders.
Response: EPA thanks the commenter for their comment.
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b. One commenter expressed appreciation for the WaterSense program, saying
that they hoped to see more irrigation products and technologies labeled in
the future. The commenter said that, following the release of the WaterSense
Single-Family New Home Specification, Version 1.0, their organization had
contributed comments suggesting that EPA establish locally driven and
outcome-based performance criteria in partnership with qualified
stakeholders. The commenter said that the revised WaterSense Labeled
Homes Program comes closer to achieving the goal of locally driven
decisions.
The commenter said that the increased flexibility built into the WaterSense
Specification for Homes, Version 2.0 would help prospective HCOs develop a
PCM specific to their local climate and market. The commenter expected that
the WaterSense Labeled Homes Program would ultimately benefit from
providing multiple options for home builders.
The commenter said that the WaterSense Labeled Homes Program should
both conserve water and be simple for HCOs and builder partners to
implement. The commenter noted that the latter was a challenge under
Version 1 of the WaterSense New Home Specification.
The commenter said that stakeholders should not be deterred from
participating in the program due to outdoor criteria. At the same time,
WaterSense should not discourage the installation of an irrigation system. It
would be preferable for WaterSense to promote efficient irrigation systems
that save water compared to typical systems in the same area.
The commenter identified three goals for the revised WaterSense Labeled
Homes Program:
1. Promote the importance of water conservation in new home
construction.
2. Result in homes that save water relative to typical new homes.
3. Encourage the use of existing WaterSense labeled products and
certifications.
The commenter acknowledged that the concept of "right plant, right place"
can help save water in residential landscapes. However, the commenter said
that no aspect of the WaterSense Labeled Homes Program should
discourage home builders or residents from installing an irrigation system.
To that end, the commenter said that WaterSense should require the use of
WaterSense labeled irrigation products for homes to be eligible to receive the
WaterSense label, as the WaterSense Labeled Homes Program is
WaterSense's best vehicle to promote the sale and use of WaterSense
labeled irrigation products and technologies. The commenter suggested that
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taking advantage of this opportunity would be in the best interest of the
irrigation industry and WaterSense as a whole. Similarly, the commenter said
that EPA should require that irrigation systems in WaterSense labeled homes
be designed, installed, and/or audited by irrigation professionals certified
through a WaterSense labeled program.
Another commenter said that household water use is often greater outdoors
than indoors. Consequently, the commenter said, the WaterSense
Specification for Homes, Version 2.0 should require qualified landscape
contractors to install outdoor landscaping.
However, the commenter acknowledged that landscaping is frequently added
after the home has been sold—and therefore after the home has been
inspected for certification to the WaterSense specification. As such, the
commenter proposed that the WaterSense Specification for Homes include
guidelines on efficient and sustainable landscaping that could be installed
after the home has received the WaterSense label.
Response: EPA emphasizes that, in keeping with the goals of Version 2 of
the WaterSense Labeled Homes Program, it intended to add flexibility for
homes to earn the WaterSense label by minimizing mandatory requirements
and stipulating a water efficiency threshold. The Mandatory Checklist is
composed of elements that are universally applicable to all homes. Not all
homes have irrigation systems, and homes are not required to have irrigation
systems to be eligible for the WaterSense label (in either Version 1 or Version
2 of the WaterSense Labeled Homes Program).
Further, different types of homes in different climates might not realize the
same water efficiency benefit from installing WaterSense labeled irrigation
products. For example, a home with a small landscape in a cool climate is
unlikely to observe the same water and cost savings benefit as a home with a
large landscape in a hotter climate. By not requiring the installation of
WaterSense labeled irrigation products in homes pursuing the WaterSense
label, EPA is providing flexibility to HCOs and builders to prioritize and pursue
other water efficiency measures that could generate a greater reduction in
water use and water costs.
However, EPA agrees that many regions throughout the country could benefit
from targeting outdoor water use, and in fact, in many locations, it is very
unlikely homes would be able to achieve the requisite 30 percent water
efficiency criteria without implementing outdoor water efficiency measures.
Therefore, EPA is promoting WaterSense labeled irrigation products,
irrigation professionals certified by a WaterSense labeled program, and other
water-efficient irrigation products, technologies, and design strategies by
recognizing their contribution toward water use reductions in the WaterSense
Technical Evaluation Process for Approving Home Certification Methods. If a
PCM includes certain outdoor requirements, EPA provides credit toward the
30 percent efficiency requirement only if the PCM requirements follow the
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specifications included in the WaterSense Technical Evaluation Process for
Approving Home Certification Methods. For example, EPA provides credit for
WaterSense labeled weather-based irrigation controllers and spray sprinkler
bodies but does not provide credit for non-WaterSense labeled "smart"
irrigation controllers or pressure-regulating spray sprinkler bodies, since
those product categories are not well-defined and have not necessarily been
third-party certified for performance and efficiency.
EPA anticipates that prospective PCMs will incentivize or require these
program features as a means of achieving the 30 percent water efficiency
requirement necessary for PCM approval, particularly if they operate in
regions where irrigation is common. EPA maintains that it would be nearly
impossible for national PCMs or PCMs that operate in warmer regions to
receive WaterSense approval without adequately addressing outdoor water
use.
EPA also agrees with the commenters that it is challenging to establish
outdoor water use criteria and guidance when landscaping is incomplete or
nonexistent at the time of sale. Similar to many other green building
certifications, the WaterSense label is an as-built certification. Therefore, EPA
cannot directly control what is done to a home or landscape after the home is
completed and sold. EPA maintains many technical resources, including
Water-Smart Landscapes Start With WaterSense and Saving Water With
Microirrigation: A Homeowner Guide, to minimize outdoor water use through
landscape practices and irrigation design. WaterSense intends to promote
these resources to builder partners to share with home buyers.
c. One commenter indicated that allowing the PCM to only address indoor water
use and leaks would weaken the WaterSense brand and would detract from
the significant water savings currently associated with the WaterSense brand.
The commenter said that, to be eligible to receive the WaterSense label,
homes should be required to be notably more water-efficient than typical
homes and should be required to address outdoor water use. It is not
uncommon for typical new homes to include WaterSense labeled plumbing
fixtures. The commenter encouraged EPA to require that homes demonstrate
additional water savings beyond the minimum requirements.
Response: EPA is clarifying that the WaterSense Specification for Homes
requires efficiency measures beyond those achieved by completing the
Mandatory Checklist, which requires installation of WaterSense labeled
toilets, lavatory faucets, and showerheads, and for the home to be verified to
be free of leaks. In keeping with the goals of Version 2 of the WaterSense
Labeled Homes Program, EPA intends to add flexibility for homes to earn the
WaterSense label by minimizing mandatory requirements and instead
stipulating a water efficiency threshold that a home can pursue through any
number of water efficiency features, including outdoor features.
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In all regions of the country, PCMs will need to incorporate water efficiency
features beyond the minimum requirements included in the Mandatory
Checklist. Within the WaterSense Technical Evaluation Process for
Approving Home Certification Methods, EPA indicates what features or
practices of a PCM will be credited with water savings. The features included
in the technical evaluation are those for which EPA has identified studies,
research or other data that suggest quantifiable water savings can be
achieved from implementation of that feature. The credited features include
WaterSense labeled irrigation products, irrigation professionals certified by a
WaterSense labeled program, and other water-efficient irrigation products,
technologies, and design strategies that can be used by a PCM to promote
outdoor water efficiency.
EPA is confident that homes that earn the WaterSense label under Version 2
of the WaterSense Labeled Homes Program will demonstrate water efficiency
beyond homes with characteristics typical of new construction and maintain
public confidence in the water savings associated with the WaterSense label.
III.3 Leak Detection Devices
The following four commenters suggested that EPA should consider including
leak detection devices as part of Version 2 of the WaterSense Labeled
Homes Program.
One commenter wrote to inform EPA of their new product that detects leaks
from toilets. The device connects with the toilet water supply line and sends
electronic notifications if leaks are detected.
Another commenter recommended that EPA require leak detection devices
that are in contact with water and send an alert if leaks are detected
anywhere in a home's plumbing. The commenter said that such technology is
effective because homeowners can track their water usage in real time.
A third commenter asked whether their company's product would be eligible
for inclusion in Version 2 of the WaterSense Labeled Homes Program. The
commenter's company manufactures an electric valve installed immediately
after the main water valve. The valve remains closed unless movement is
detected in the home. The system also has a leak detection function that
closes the valve if a leak is detected while the home is occupied.
A fourth commenter suggested that EPA consider new leak detection devices
that can predict freezes and leaks, provide alerts, and remotely shut off the
water supply.
Response: EPA agrees that household leaks are a serious problem that can
result in significant water loss and recognizes that various types of leak
detection systems can be used to prevent or minimize water losses from
leaks. Under the WaterSense Technical Evaluation Process for Approving
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Home Certification Methods, EPA applies credit toward the 30 percent water
efficiency requirement for PCMs that require or credit for installation of leak
detection systems in homes. See Section 4.3.2.9 of the WaterSense
Technical Evaluation Process for Approving Home Certification Methods for
more information.
At this time, EPA does not have a separate product specification to label or
differentiate among leak detection devices; however, it plans to track these
products as the market expands and new technologies are introduced. EPA
is aware of a number of ongoing research efforts intended to evaluate the
water savings potential of these devices. EPA will also remain informed of
ongoing efforts to develop standards for leak detection devices.
111.4 Providing Verifier Training for Leak Detection
One commenter said that it is beneficial to have a short Mandatory Checklist;
however, they indicated that it would be difficult to verify some of the
requirements pertaining to leaks. Regarding the required pressure-loss test,
the commenter suggested that HCOs should be given a specific,
standardized test method. Regarding the requirement to verify that the hot
water delivery system is free of visible leaks, the comment suggested this
would be difficult to verify, and that HCOs would need to accept a statement
of attestation that the hot water system is free of leaks, or provide a checklist
for the plumber to complete.
Response: EPA agrees that it is important to clearly convey the expectations
for evaluating leaks as described in the Mandatory Checklist. Regarding the
pressure-loss test, EPA has incorporated details on this evaluation in the
WaterSense program-specific training, which will be provided to approved
HCOs for dissemination to verifiers interested in offering verification services
related to the WaterSense Labeled Homes Program. The training educates
verifiers on: protocols related to conducting the pressure-loss test; verifying
visible leaks are not present in any water-using system, fixture, or appliance;
and ensuring that toilets, lavatory faucets, and showerheads are WaterSense
labeled. EPA also agrees that verifying that the hot water delivery system, in
particular, is vague as written in the WaterSense Draft Specification for
Homes, Version 2.0. EPA has determined that the pressure-loss test serves
to evaluate any internal leaks within the hot water distribution system;
therefore, the requirement is redundant. As such, EPA has removed the
requirement to visually verify the hot water distribution system is free of leaks
from the Mandatory Checklist and has instead clarified that the point of
connection to the hot water heater should be verified and free of visible leaks.
111.5 Need for Structured Plumbing Criteria
One commenter said that the revised specification should include
requirements related to structured plumbing systems, such as those included
in Section 3.3 of the WaterSense Specification for New Homes, Version 1.2,
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Response to Comments on the Draft
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WaterSense
which identifies the maximum volume of water that may be stored between
the hot water source and any hot water-using fixture and specifies the
maximum volume of water that can be collected from the hot water-using
fixture before hot water is delivered.
The commenter said that structural waste—defined as long runs of pipe to
frequently utilized fixtures—could lead to behavioral waste through delays in
use over a building's lifetime. The commenter included results from a life
cycle assessment (LCA) conducted by their organization. The LCA indicated
that, by incorporating a well-planned piping layout, a large home could use
less water and have a smaller environmental impact than a medium-sized
home. The commenter quoted a section of text from the LCA report
describing that water use efficiency was influenced by pipe distance. This is
because hot water in the pipes cools as it travels to a fixture and because
there is a larger volume of water in the pipe that must be purged before hot
water reaches the fixture.
Another commenter summarized EPA's proposed handling of water savings
associated with hot water delivery, as presented in the WaterSense Draft
Technical Evaluation Process for Approving Home Certification Methods and
compared the calculations for water use and savings associated with hot
water delivery to different versions of the International Energy Conservation
Code (IECC) and the 2018 Uniform Plumbing Code (UPC). The commenter
noted differences between each of these methods.
Response: As stated previously, EPA sought to minimize mandatory
requirements to add flexibility for homes to earn the WaterSense label while
still demonstrating a requisite level of water efficiency. EPA agrees that
structured plumbing and hot water distribution design can influence water use
in homes; however, EPA does not agree that it should retain a prescriptive
requirement related to efficient hot water delivery.
The revised specification is focused on allowing builders flexibility in plumbing
design and installation to achieve water efficiency. As such, the WaterSense
Technical Evaluation Process for Approving Home Certification Methods
provides credit to PCMs that incorporate requirements for water-efficient
structured plumbing systems (i.e., recirculating hot water distribution
systems) or establish maximum volumes of water that can be stored in hot
water piping before it reaches a fixture. See Section 4.3.2.8 of the
WaterSense Technical Evaluation Process for Approving Home Certification
Methods for more information. Many existing home certification programs that
address water efficiency already include requirements on these topics.
EPA also intends to maintain resources related to efficient hot water delivery
on the WaterSense website. For example, EPA intends to update its Guide
for Efficient Hot Water Delivery Systems so that builders, prospective HCOs
involved with certification method development, and other stakeholders can
access information on efficient design practices related to hot water delivery.
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111.6 Harmonization With State and Local Standards
One commenter said that PCMs should require adherence to local
ordinances and applicable state standards, such as irrigator licensing
requirements. The commenter expressed concern that if such language was
not included, homes that receive the WaterSense label might be out of
compliance with local and state standards.
The commenter provided a few examples from Texas to illustrate their
concern. The San Antonio plumbing code requires water-efficient plumbing
fixtures, and the state of Texas has specific requirements for irrigation
systems and for licensing irrigation professionals. The commenter suggested
that a home built in Texas might not meet these requirements if it was
constructed in accordance with a WACM developed outside the state.
Response: EPA does not intend for the WaterSense Specification for Homes
to exempt homes from following local codes, standards, or regulations. All
homes will need to go through normal permitting requirements and therefore
will need to meet local and state code requirements, regardless of a home's
pursuit of WaterSense certification.
However, there is potential for local standards and codes to conflict with the
Mandatory Checklist included in the WaterSense Specification for Homes. An
HCO, in consultation with EPA, will consider and respond to such conflicts on
a case-by-case basis and provide exceptions where appropriate.
111.7 Appendix A Not Sufficiently Detailed
One commenter said that Appendix A to the WaterSense Draft Specification
for Homes, Version 2.0, was too brief. The commenter recommended
providing summary information about the mandatory program elements and
including a brief description of the process of implementing a WACM. The
commenter indicated that these details would be preferable to simply
referencing the content of the WaterSense Home Certification System.
Response: This document structure is consistent with specifications and
certification systems in other areas of the WaterSense program. EPA did not
include specific details on the certification system requirements or structure in
Appendix A of the specification in order to provide flexibility for conducting
document or program updates and to avoid providing duplicate information in
multiple places which could result in inconsistencies in the future. EPA has
provided information in the WaterSense Home Certification System that
summarizes the structure and indicates how the various program documents
relate.
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WaterSense
III.8 Maintaining a Prescriptive Path
One commenter observed that the WaterSense Draft Specification for
Homes, Version 2.0 does not include a prescriptive compliance checklist, in
contrast to Version 1.2 of the specification. The commenter said that water
rating systems are still relatively new in the United States, and that HCOs are
still in the process of learning to administer them. The commenter suggested
that EPA may want to retain a prescriptive checklist as an additional pathway
to achieve certification. The commenter noted that the checklist could be
particularly helpful to address regional differences, such as landscaping, and
that it would provide a simpler option to homebuilders who would prefer not to
work with an HCO.
Response: During its stakeholder outreach and in its Notice of Intent (NOI),
EPA specifically asked whether stakeholders were supportive of maintaining
a prescriptive path to certify a home to the WaterSense label. EPA did not
receive many comments or much support on the issue. The prescriptive
compliance checklist in Version 1.2 of the specification has helped promote
specific water efficiency features and practices, but it has also presented
some barriers for homes to be eligible to receive the WaterSense label.
Prescriptive checklist options maintained by other programs, such as the
ENERGY STAR Certified Homes Program, have not been widely utilized.
Further, EPA does not have the capacity to administer certification or
verification services related to a prescriptive program structure (which has
also proven difficult for programs such as ENERGY STAR that chose to
maintain dual paths). Instead, by offering flexibility in the design of PCMs,
EPA allows HCOs to choose whether to adopt a prescriptive path to
certification on their own.
IV. Comments on WaterSense Draft Technical
Evaluation Process for Approving Home
Certification Methods
IV.1 Request to Evaluate the Water Demand Calculator
The following two commenters requested that WaterSense consider using
lAPMO's Water Demand Calculator as part of the process of evaluating
PCMs.
One commenter explained that IAPMO, the American Society of Plumbing
Engineers, the Water Quality Research Federation, and the University of
Cincinnati had developed a statistical method for determining water pipe
sizing to reduce pipe diameters and adapt to lower water demand from water-
efficient plumbing features. The method has been incorporated into lAPMO's
WE'Stand and the Uniform Plumbing Code. The Water Demand Calculator is
a free tool that can be downloaded from lAPMO's website and used to
calculate pipe sizing with the new method.
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The commenter said that the method applies to single-family and multifamily
buildings. IAPMO is in the process of calculating volumetric efficiencies
associated with using the Water Demand Calculator in homes of different
sizes. The commenter suggested that EPA should factor the efficiencies
provided by use of the Water Demand Calculator into the WaterSense
Technical Evaluation Process for Approving Home Certification Methods.
A second commenter also highlighted the Water Demand Calculator as an
important part of WE'Stand. The commenter explained that the Water
Demand Calculator uses a method that reduces domestic water pipe size
relative to the method used in baseline plumbing codes.
Response: EPA commends IAPMO for establishing the Water Demand
Calculator, a tool intended to reduce water pipe diameters by accounting for
expected water use from water-efficient plumbing fixtures. EPA agrees with
the principle that reduced and appropriately sized piping results in reduced
water waste. Accordingly, EPA will evaluate this resource to determine
whether it should be incorporated into the WaterSense Technical Evaluation
Process for Approving Home Certification Methods as a means of assessing
PCM compliance with the water efficiency criteria when data on potential
water savings become available.
IV.2 Source of Data on Household Water Use
One commenter inquired about the source of the water use data incorporated
in the WaterSense Technical Evaluation Process for Approving Home
Certification Methods. The commenter said they have built more than 100
homes that exclusively use collected rainwater. The commenter said their
company has thousands of homes with meters for indoor water use,
irrigation, and swimming pools, if applicable. The commenter said that over
14 years of collecting data from metering, they had not found water use
numbers comparable to those used by EPA.
The commenter said that they could identify the amount of water used in a
home based on certain characteristics of the home, such as age and gender
of occupants, installation of WaterSense labeled products, and structured
plumbing. They critiqued the use of data based on assumed occupancy,
indicating that this estimation of water use is not accurate.
The commenter recommended that EPA work with builders to install internet-
capable meters to homes before the water is connected. The commenter
suggested some organizations that might want to participate in such a
program and share data.
Response: WaterSense encourages stakeholders to share any data on water
consumption patterns in households and the influence of different factors on
water use and user behavior.
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Response to Comments on the Draft
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WaterSense
As presented in the WaterSense Technical Evaluation Process for Approving
Home Certification Methods, EPA relied on the best available data with a
national scope to identify household water use and savings estimates
associated with certain features. Since the WaterSense label is a national
designation, it is necessary to use data that represent water use across the
United States. Unfortunately, there are limited data available that assess
household water usage patterns. The Residential End Uses of Water, Version
2 is considered the best resource for this type of data in the industry, and its
process for establishing occupancy is detailed in the report.
IV.3 Baseline Home Not Weil-Defined in Technical Evaluation
One commenter said that it appeared that a prospective HCO would establish
its own baseline conditions in its PCM. The commenter suggested that EPA
should define a single set of baseline conditions and a verification process to
encourage consistency and establish a more competitive environment for
The commenter said that EPA should also clearly define applicable national
codes, standards, and common landscape practices in the revised
WaterSense Labeled Homes Program documents. The commenter quoted
Section 1.0 of the WaterSense Draft Technical Evaluation Process for
Approving Home Certification Methods, which requires "homes that earn the
WaterSense label to be at least 30 percent more water-efficient than a
comparable home of typical new construction using national codes, standards
and common landscape practices." The commenter said that there are a
number of potentially applicable codes, including the International Plumbing
Code (IPC) and Uniform Plumbing Code (UPC), that are not universally
adopted and implemented in the United States. This could result in
inconsistencies and confusion if PCMs based on differing standards are
approved by EPA.
Another commenter said that EPA should set the parameters of the baseline
home and not permit HCOs to establish their own baselines that would be
compared to the 30 percent benchmark.
Response: As stated in Section 1.6 of this document, EPA has incorporated
clearer definitions and discussions regarding the "baseline configuration" and
"reference home" into the WaterSense Technical Evaluation Process for
Approving Home Certification Methods. In addition, EPA previously used the
phrase "national codes, standards, and common landscape practices" to
reference the water efficiency requirements for plumbing fixtures, fittings, and
appliances defined in EPAct and subsequent efficiency legislation. However,
based on comments received, EPA has removed the reference to national
codes and revised its terminology to refer "national standards and common
design and landscape practices."
HCOs.
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WaterSense
EPA is clarifying that the baseline configuration of each reference home does
not vary based on local codes and ordinances. Rather, the baseline
configuration has a strict definition that is applied uniformly nationwide. EPA's
assumptions and calculations for the baseline and water-efficient
configuration of each reference home are included in Section 4.0 of the
WaterSense Technical Evaluation Process for Approving Home Certification
Methods. In the approval of the PCM, EPA estimates the water use for each
reference home's baseline configuration compared to the water use from the
water-efficient configuration to determine if the PCM is capable of
differentiating homes that meet EPA's water efficiency requirement.
IV.4 Landscape Area References
One commenter observed that EPA cited the RESNET Draft Standard PDS-
01, BSR/RESNET/ICC 1101-201X, Water Rating Index, for the proposed
landscape area equations presented in the WaterSense Draft Technical
Evaluation Process for Approving Home Certification Methods. The
commenter said that this draft standard is not the most recent version and
does not cite the Residential End Uses of Water, Version 2; provide
background on the development of the equations; nor rationalize the
selection of 7,000 square feet as the breakpoint between equations.
The commenter observed that a subscription is needed to access the
Residential End Uses of Water, Version 2 data and report. Without a
subscription, it is not possible to review the field data and verify the best fit
equation. The commenter said that they are not opposed to EPA referencing
specific standards, but that any standards referenced should be available for
free public access.
Response: EPA reviewed multiple existing standards related to home water
efficiency and certification to identify potential methods to evaluate and
calculate landscape area and determined that the BSR/RESNET/ICC 1101-
201X Draft Standard for the Calculation and Labeling of the Water Use
Performance of One- and Two-Family Dwellings Using the Water Rating
Index (which has since been finalized and published as ANSI/RESNET/ICC
850-2020 Standard Calculation and Labeling of the Water Use Performance
of One- and Two-Family Dwellings Using the Water Rating Index) was most
suitable because it provided an estimate that was national in scope. See
Section IV.5b of this document for more information on the rationale behind
7,000 square feet lot size breakpoint.
EPA referenced the most recent version of the BSR/RESNET/ICC 1101 draft
standard that was available when the draft WaterSense Labeled Homes
Program, Version 2 documents were published. There were no changes to
the equations for proposed landscape area between the draft standard that
was referenced and the final ANSI approved version. EPA has updated its
reference to the final standard—ANSI/RESNET/ICC 850-2020 Standard
Calculation and Labeling of the Water Use Performance of One- and Two-
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WaterSense
Family Dwellings Using the Water Rating Index—within the WaterSense
Technical Evaluation Process for Approving Home Certification Methods.
EPA seeks to use the best available data to inform its decisions and inputs.
Frequently this means purchasing data, reports, codes, and standards, such
as the Residential End Uses of Water, Version 2.
IV.5 Reference Home Physical Parameters
a. One commenter said that the square footage of the lot and home for the
reference home does not reflect average square footage for homes in Texas
or the United States. The commenter also recommended that the reference
home's outdoor water use be estimated by region, using summer rainfall and
freeze data as breakpoints. Finally, the commenter suggested that the
reference home should be developed using results from the Residential End
Uses of Water, Version 2, especially because most homes do not irrigate as
much as predicted by typical water budget calculators. As a result, the
"typical home" could have an artificially high irrigation budget, and
homeowners could mistakenly conclude that their outdoor water use is low.
Response: EPA does not intend for the reference homes to represent
average conditions in U.S. homes. Rather, the reference homes are a tool
that EPA will use to ensure that PCMs can accurately differentiate homes that
meet the WaterSense criteria across a broad range of physical home
attributes (e.g., lot size, number of bedrooms, number of bathrooms). EPA
has added the definitions of "reference home/reference building" and
"baseline configuration" to the WaterSense Technical Evaluation Process for
Approving Home Certification Methods to clarify this concept.
The WaterSense Technical Evaluation Process for Approving Home
Certification Methods already incorporates the suggestions provided by the
commenter to estimate outdoor water use based on region and climate, and
uses the irrigation habits reported in the Residential End Uses of Water,
Version 2. Section 4.4 of that document describes how EPA considers
regional climate differences in estimating outdoor water use for the baseline
and water-efficient configurations of each reference home. Section 4.4.1
explains how EPA uses the findings from the Residential End Uses of Water,
Version 2 to establish baseline outdoor water use for each reference home.
Specifically, EPA applies a factor of 58 percent to the baseline theoretical
irrigation requirements to account for the fact that homeowners do not
typically irrigate landscapes to their full water plant demand.
b. One commenter wrote to clarify the reasoning behind the 7,000 square foot
threshold for lot size. The commenter referenced the U.S. Census Bureau's
Survey of Construction (SOC), noting that it uses a median lot size of 8,560
square feet based on nationwide data available in 2017. The commenter
included a figure from the U.S. Census Bureau illustrating median lot size in
new single-family homes (Figure 1). The commenter observed that the SOC's
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Response to Comments on the Draft
WaterSense Labeled Homes Program, Version 2.0
median lot size is 18 percent larger than the 7,000 square foot lot size
threshold used in equations presented in the WaterSense Draft Technical
Evaluation Process for Approving Home Certification Methods, possibly
leading EPA to underestimate landscape size and outdoor water use in the
baseline home. The WaterSense Technical Evaluation Process for Approving
Home Certification Methods would therefore not properly calculate water
savings when determining the water savings associated with a candidate
home.
Median Lot Size: New Single-family Detached
Homes Sold
eet
10,500
8,000
1992 1995 1997 1999 2001 2003 2005 2007 2009 2011 2013 2015 2017
Source: US Census Bureau
Figure 1. Median lot size of new single-family detached homes by year (as provided
by the commenter).
The commenter also indicated that there have consistently been significant
regional differences in lot sizes. The landscape area calculations included in
the WaterSense Draft Technical Evaluation Process for Approving Home
Certification Methods do not account for these regional differences, and
HCOs are not required to address them in their PCMs. The commenter said
that this would ultimately affect EPA's assessment of candidate homes. For
example, in 2017, the median lot size of homes in the West Coast, Hawaii
and Alaska was 6,534 square feet—7 percent smaller than EPA's breakpoint.
In contrast, the median lot size of homes in New England was 17,424 square
feet—50 percent larger than the breakpoint. The commenter included a figure
from the 2017 SOC, with estimates compiled by the National Association of
Home Builders, illustrating median lot size of new single-family homes where
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WaterSense Labeled Homes Program, Version 2.0
construction began in 2017 (Figure 2). The commenter recommended that
EPA reevaluate the methodology used to calculate landscape area and
consider using median lot sizes representative of the corresponding region
when evaluating PCMs.
Median Lot Size
New Single-Family Detached Spec Homes Started in 2017
Figure 2. Median lot size of new single-family detached homes started in 2017 (as
provided by the commenter).
Response: EPA consulted with RESNET, the relevant standard development
organization, on the reasoning behind the equation used to generate
landscape area based on lot size. RESNET indicated that 7,000 square feet
is the approximate breakpoint at which two equations intersect on a best fit
regression model. Data from the Residential End Uses of Water, Version 2
indicates homes with lot sizes less than 7,000 square feet have landscape
areas that correlate to Equation 1 in the WaterSense Technical Evaluation
Process for Approving Home Certification Methods, whereas homes with lot
sizes greater than 7,000 square feet have landscape areas that correlate to
Equation 2. The breakpoint of 7,000 square feet dictates which of these
equations to use when determining landscape area and is not meant to
represent the median or average lot size of new homes. In other words, for a
home with a lot size of 7,000 square feet, either equation could be used to
generate landscape area from lot size, and each would calculate
approximately the same results.
MIDDLE ATLANTIC
0.3 acres
IEW ENGLAND
« 0.4 acres
Source: 2017 Survey of Construction, NAHB Estimates
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WaterSense Labeled Homes Program, Version 2.0
The WaterSense Technical Evaluation Process for Approving Home
Certification Methods is designed to assess whether a PCM properly
accounts for outdoor water use across a range of lot sizes, landscape areas,
and climates. As a result, it evaluates outdoor water use in smaller lot sizes
more typical of the Pacific region, as well as larger lot sizes such as those
found in New England. EPA's evaluation of the PCM will not be influenced by
the median lot size in the prospective HCO's region.
c. One commenter stated that they identified a discrepancy in reference home
footprint size based on quarterly analyses of data from the Census Quarterly
Stats and Completions by Purpose and Design. The commenter included a
table from this report showing the average and median single-family new
home size in the first quarter of 2019 and in 2017-2018 (Table 1).
Single-Family New
Home Size
1st Quarter, 20191
2017-2018
Average (sq. ft)
2,584
2,574
Median (sq. ft)
2,355
2,368
Table 1. Sizes of single-family new homes.
The commenter said that EPA's large footprint reference home is
approximately equivalent to the average new home in the United States.
Since mid-2011, the median and average square footages of new homes
have been larger than 2,300 and 2,500 square feet, respectively. The
commenter observed that using 2,500 as the large footprint reference home
might not represent a least efficient home among larger new homes. It may
be more accurate to create an "average reference home" with a footprint of
2,500 square feet and a "large footprint reference home" with a larger
footprint based on existing data. If EPA designed the reference homes to
align with the dimensions of new homes, it could more accurately quantify
potential water savings in homes seeking the WaterSense label.
Further, the commenter suggested that EPA's small footprint single-family
reference home does not represent typical new small homes in the United
States. EPA's small footprint single-family reference home is a two-bedroom,
one-bathroom home. To illustrate their point, the commenter included a graph
showing the share of new single-family homes by number of bedrooms from
2005 to 2015 (Figure 3). The commenter observed that only 10 to 12 percent
of new single-family homes built between 2005 and 2015 had two or fewer
bedrooms. In contrast, 45 to 50 percent of homes had three bedrooms, and
30 to 35 percent had four bedrooms.
1 http://eveonhousina.org/2019/05/new-sinale-familv-home-size-first-auarter-2019-data/
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Water Sense WaterSense Labeled Homes Program, Version 2.0
Share of New Single-Family Homes Started by Number of Bedrooms, 2005 to 2015
60%
E 50%
3 bedrooms
40%
30%
20%
10%
4 bedrooms
2 bedrooms or less
5 bedrooms or more
0%
2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015
Figure 3. Share of new single-family homes started by number of bedrooms, 2005 to
2015 (as provided by the commenter).
The commenter provided additional statistics from the National Association of
Home Builders' Eye on Housing website. Since 2000, less than 10 percent of
new single-family home starts had one bathroom. Among new single-family
homes where construction started in 2017, 4 percent had one bathroom, 60
percent had two full bathrooms, and 27 percent had three full bathrooms. The
commenter said that the small footprint reference home should be updated to
reflect the number of bathrooms and bedrooms in typical new construction to
more accurately quantify water savings in homes seeking WaterSense
certification.
The commenter included a figure illustrating the percentage of new single-
family homes started by number of full bathrooms between 2007 and 2017
(Figure 4).
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WaterSense Labeled Homes Program, Version 2.0
Figure 1: Share of New Single-Family Home Started
by Number of Full Bathrooms
80%
0%
200? 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017
1 bathroom or less -®-2 bathrooms -*-3 bathrooms -•-4 bathrooms or more
Figure 4. Share of new single-family homes started by number of full bathrooms (as
provided by the commenter).
The commenter also included a figure illustrating the percentage of new
single-family homes started by number of half bathrooms between 2007 and
2017 (Figure 5).
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Figure 5. Share of new single-family homes started by number of half bathrooms (as
provided by the commenter).
The commenter explained that, based on the three figures provided, the
number of bathrooms and bedrooms in EPA's large footprint home were an
accurate representation of trends in larger new home construction. Four-
bedroom homes comprised 30 to 35 percent of homes constructed since
2005. Among homes constructed since 2007, 60 to 70 percent have two
bathrooms, and nearly half of those homes also have one half bathroom.
Response: Based on water use data EPA considered during development of
Version 2 of the WaterSense Labeled Homes Program, a home's occupancy,
design choices (e.g., plumbing fixture efficiencies), and landscape area have
a more substantial influence on predicted water use than square footage and
number of bathrooms. EPA has included values for square footage and
number of bathrooms to provide context, but these values do not directly
influence the technical evaluation's prediction of the water use for the
baseline and water-efficient configurations of each reference home.
EPA reiterates that the reference homes are meant to evaluate the PCM's
ability to differentiate homes that meet the water efficiency requirement
across a broad, but realistic, range of potential physical home attributes. The
reference homes' attributes are not, therefore, intended to reflect average or
median conditions for homes.
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WaterSense
However, in response to the information supplied by the commenter, EPA
reevaluated and has expanded the range of attributes used for the single-
family reference home characteristics evaluated. Within the Table 4-1 of the
WaterSense Technical Evaluation Process for Approving Home Certification
Methods, the large footprint reference homes now include five bedrooms and
four bathrooms (representing the upper ends of the data range supplied by
the commenter), whereas the small footprint reference homes include two
bedrooms and one-and-a-half bathrooms. The assumed number of fixtures
and appliances has also been updated accordingly. EPA made these updates
to ensure its technical evaluation appropriately considers a range of homes
that could realistically pursue certification through a PCM.
Lastly, EPA has made a clarification to square footage of the large footprint
reference home. This reference home has a footprint of 2,500 square feet,
but has a total area of approximately 5,000 square feet, since the home is
intended to be two stories. The 5,000-square-foot threshold is more in line
with the upper end of the range of single-family home square footage as
indicated by the commenter.
d. One commenter referenced Table 3-2 in the WaterSense Draft Technical
Evaluation Process for Approving Home Certification Methods, which
identified WaterSense's small multifamily reference building as having 20
units and WaterSense's large multifamily reference building as having 300
units. The commenter included a figure from the U.S. Census Bureau's
Characteristics of New Housing website that depicted the percent distribution
of ranges of units in new multifamily buildings constructed between 2010 and
2017 (Figure 6). The commenter requested that EPA explain its decision to
define a larger multifamily reference home as having 300 units, since the data
from the U.S. Census Bureau grouped together all multifamily buildings with
50 or more units.
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Units per New Multifamily Building 2010-2017
60
i
.i
J
..I
TJ
.J
J
2010 2011 2012 2013 2014 2015 2016 2017
¦ 2 units 3 to 4 units ¦ 5 to 9 units B10 to 19 units
¦ 20 to 29 units ¦ 30 to 49 units ¦ 50 units or more
Figure 6. Units per new multifamily building, 2010 to 2017 (as provided by the
commenter).
The commenter also observed that EPA's small multifamily reference building
assumes units with one bedroom and one bathroom, whereas the large
multifamily reference building assumes units with two bedrooms and two
bathrooms. The commenter analyzed data from the U.S. Census Bureau and
identified that a different unit distribution would better represent multifamily
buildings currently being constructed. The commenter requested that EPA
review and explain the chosen distribution of units for small and large
multifamily reference buildings.
The commenter presented additional data from the U.S. Census Bureau. In
2017, 41 percent of multifamily units had two bedrooms, and 41 percent had
one bedroom. The distribution of units with one and two bedrooms has been
approximately equal since 2013. Further, in 2017, 45 percent of units with two
or more bedrooms had two bathrooms, whereas 51 percent had one
bathroom. The commenter observed that this marked a shift compared to
pre-2013, when units with two bathrooms were twice as common as units
with one bathroom.
The commenter included two figures that showed the percent distribution of
the number of bedrooms and the number of bathrooms in new multifamily
units for each year between 2010 and 2017 (Figures 7 and 8).
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(e.g., number of units, number of bedrooms, number of bathrooms) possible
in new construction. They are not meant to represent average conditions. By
using an evaluation methodology that assesses a broad range of physical
attributes, EPA can ensure that any WACM will result in a home with water
savings of at least 30 percent compared to a home with characteristics typical
of new construction, regardless of the home's attributes.
EPA reviewed multiple sources of data including data from ENERGY STAR
Portfolio Manager, which includes building information for thousands of
multifamily buildings throughout the country and determined that 300 units
was reasonably representative of a larger multifamily building.
Regarding the commenter's point about the distribution of bedrooms and
bathrooms in multifamily units, the U.S. Census Bureau data confirm that it is
reasonable for EPA to use one to two bathrooms in the multifamily reference
buildings, although as stated previously, the number of bathrooms do not
influence EPA's estimates of water use in the reference buildings under the
baseline and water-efficient configurations. In response to the data supplied
by the commenter, EPA modified the average number of bedrooms per unit in
the large reference buildings to two and a half bedrooms to represent the
upper range of bedrooms anticipated in multifamily buildings. EPA updated
Table 4-2 of the WaterSense Technical Evaluation Process for Approving
Home Certification Methods accordingly.
e. Based on the data presented above, the commenter encouraged EPA to
reconsider the mandatory 30 percent improvement in water efficiency relative
to baseline homes, stating that it could be too stringent.
Response: The 30 percent benchmark is appropriate and achievable using
common, proven water efficiency practices. For example, EPA found that
homes built to the requirements of the WaterSense New Home Specification,
Version 1.2, achieve approximately 30 percent water efficiency when
evaluated using the WaterSense Technical Evaluation Process for Approving
Home Certification Methods.
Further, WaterSense labeled products are more common in the marketplace
now than when the WaterSense Labeled Homes Program was first
introduced in 2008. Since more homes can be expected to have WaterSense
labeled products as part of typical new construction, baseline residential
water efficiency could be greater. By requiring a 30 percent increase in water
efficiency, EPA is striving to promote residential water savings in addition to
that achieved by installing WaterSense labeled products.
IV.6 Limitations for Multiple Showerheads
One commenter indicated that they were concerned about bathroom designs
with multiple showerheads and that the WaterSense Technical Evaluation
Process for Approving Home Certification Methods should be designed to
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discourage multiple showerheads. The commenter recommended that
WaterSense labeled homes should be required to have only one showerhead
per minimum shower area to discourage home builders from adding extra
showerheads to a shower as an upgrade.
Response: EPA agrees that multiple showerheads in a shower compartment
can be a detriment to water efficiency in homes. In the WaterSense Technical
Evaluation Process for Approving Home Certification Methods, EPA
penalizes PCMs that do not stipulate requirements addressing multiple
showerheads by assigning a flow rate equivalent to two WaterSense labeled
showerheads (i.e., 4.0 gallons per minute [gpm] total) within a shower
compartment within the water-efficient home configurations. See Section
4.3.2.2 of the WaterSense Technical Evaluation Process for Approving Home
Certification Methods for more details.
EPA also incorporated reference to a recent (at the time of publication of this
document) Memorandum of Understanding (MOU) between Plumbing
Manufacturers International (PMI) and the Alliance for Water Efficiency
(AWE), which requires the total combined flow rate from all shower outlet
devices controlled by one shower valve to not exceed 2.0 gpm. Where a
second shower valve is installed in a shower compartment designed for two
persons in residences, shower valves shall be installed not less than 96
inches apart, as measured horizontally. This MOU serves as an important
industry agreement to limit the installation of multiple spray showers. EPA will
refer to this MOU when determining whether a PCM has appropriate
measures to limit multiple spray showers. However, because this MOU is
recent, EPA will not plan to apply a penalty to PCMs for which stakeholder
engagement has occurred prior to release of the WaterSense Technical
Evaluation Process for Approving Home Certification Methods and that have
otherwise controlled for multiple spray showers.
To allow maximum flexibility in PCMs, EPA chose not to prescribe the way in
which prospective HCOs should restrict multiple showerheads. However, it
would be challenging for a PCM to be approved without a provision against
multiple showerheads in a shower stall.
IV.7 Source of ET0 Data Outdated
One commenter observed that EPA was proposing to use reference
evapotranspiration (ET0) data from 1990 to calculate water use by outdoor
irrigation. The commenter said that it was unclear why EPA had chosen to
use this data, and that doing so excluded several droughts that had occurred
in California, including the most significant drought in the state's history,
which lasted from 2012 to 2016. The commenter suggested that excluding
these drought periods would likely impact the ET0 values used to calculate
the irrigation requirements.
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Response: As explained in Section 4.4 of the WaterSense Technical
Evaluation Process for Approving Home Certification Methods, EPA used ET0
data from the World Water and Climate Atlas, a project of the International
Water Management Institute. EPA processed data from 1961 to 1990 to
determine monthly ET0 and rainfall for each zip code in the United States.
The ET0 data from the World Water and Climate Atlas satisfy two
considerations for EPA's use of external data:
• The data are representative of the entire United States, since they were
processed for each zip code. WaterSense is a national program and
seeks to use data that represent conditions across the country.
• The data are from a reliable source, which helps to ensure their
accuracy. The International Water Management Institute is a non-profit
scientific research organization and is part of the Consultative Group on
International Agricultural Research.
When considering climate data such as ET0, it is also necessary to consider
data across a long time period, since climate can vary significantly year-to-
year. EPA is not aware of other available ET0 data that meet each of these
criteria. EPA also stresses the need for consistency in its data inputs across
spatial, geographic, and temporal resolutions. The technical evaluation would
be less consistent if data substitutions were made only for certain parts of the
country.
IV.8 Method for Estimating Outdoor Water Use
One commenter provided a series of comments on the methodology in the
WaterSense Draft Technical Evaluation Process for Approving Home
Certification Methods for estimating outdoor water use. The commenter
indicated that the percent of effective rainfall used to calculate modified net
evapotranspiration (ModNetET0) should be closer to 50 percent of total
rainfall, rather than 25 percent. The calculation is more likely to result in
excessive irrigation if it assumes that 75 percent of rainfall is ineffective.
The commenter also indicated that the efficiency allowance should be
minimized. It assumes that homeowners "water to the dry spot," which is
unlikely. The commenter argued that irrigation systems should instead be
improved to avoid the dry spot.
The commenter indicated that EPA should address the percentage of
landscape that could be irrigated with an automatic system and the average
flow rate of that system. EPA's goal should be to irrigate less land with a
lower flow rate.
Lastly, the commenter said that EPA's evaluation of outdoor water use should
include a metric of plant type and diversity, and that the home should
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demonstrate that the irrigation system has been designed for a particular
plant community.
Response: EPA agrees that residents should assume that more than 25
percent of rainfall is utilized by the landscape, particularly when designing a
resilient landscape intended to minimize the need for significant irrigation.
However, EPA has retained this assumption within the WaterSense Technical
Evaluation Process for Approving Home Certification Methods to be
conservative in establishing baseline water use in its technical evaluation of
PCMs. This assumption is consistent with the WaterSense Water Budget
Tool (developed to support Version 1 of the WaterSense Labeled Homes
Program).2
Regarding the commenter's concern about the prescribed "efficiency
allowance," EPA assumes this is in reference to the actual irrigation factor of
0.58, discussed in Section 4.4.1 of the WaterSense Technical Evaluation
Process for Approving Home Certification Methods. While the applied value
of this input has the same impact as an efficiency allowance in a traditional
water budgeting approach, the purpose of this value is simply to match the
predicted water use with quantities observed in the field (since most
homeowners do not water to full replacement ET). EPA has chosen to use
the efficiency inputs included in the Residential End Uses of Water, Version 2
because it represents the most up-to-date information available on irrigation
efficiencies.
Lastly, EPA has already accounted for the commenter's suggestion to
address the percentage of irrigated landscape and landscape plant selection.
The WaterSense Technical Evaluation Process for Approving Home
Certification Methods considers the percentage of landscape irrigated with
different technologies (or not irrigated at all) and the percentage of landscape
area containing certain plant types. See Section 4.4.2 of the WaterSense
Technical Evaluation Process for Approving Home Certification Methods for
more information.
IV.9 Emphasize Efficient Irrigation
One commenter said that efficient irrigation technologies and management
can result in significant water savings. The commenter said the WaterSense
Labeled Homes Program should place more emphasis on the benefits of
efficient irrigation, in addition to addressing the plants included in a
landscape.
Response: EPA agrees that both landscape design and irrigation efficiency
can contribute to outdoor water savings. The WaterSense Technical
Evaluation Process for Approving Home Certification Methods provides credit
2 EPA, 2014. WaterSense Water Budget Approach, Version 1.02. July 24, 2014.
www.epa.aov/sites/production/files/2017-01/documents/ws-homes-water-budaet-approach.pdf
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for both approaches, giving home builders the flexibility to select the options
that are most appropriate for their region and customers.
IV.10 Allowing Xeriscaping in Non-Arid Regions
One commenter noted that Table 3-3 of the WaterSense Draft Technical
Evaluation Process for Approving Home Certification Methods presented
several types of landscape that were used to calculate plants' water
requirements. Xeriscaping is one of those landscape types; however, EPA is
limiting the use of xeriscape landscape to arid and semi-arid climates. The
commenter suggested that although it was originally developed for arid and
semi-arid climates, xeriscaping has been adapted for regions with more
precipitation.
The commenter said that limiting the use of xeriscaping to homes in arid and
semi-arid climates restricts builders in other areas of the country from
installing xeriscaping. The option in the WaterSense Draft Technical
Evaluation Process for Approving Home Certification Methods for "non-turf
plants with microirrigation" does not compensate for this restriction, even
though this option offers a species coefficient that is more than double that of
xeriscaping. The commenter recommended that EPA expand the options for
using xeriscaping in all climates by creating subcategories of species
coefficients.
Response: EPA has chosen to retain the current approach to xeriscaping and
low-water-using plants. As explained in the footnotes to Table 4-3 in the
WaterSense Technical Evaluation Process for Approving Home Certification
Methods, EPA has chosen a species coefficient of 0.3 for xeriscaping that
applies only to landscapes in warm, arid climates. EPA has chosen to add a
category for non-turf plants in other regions that are watered with
microirrigation and has assigned a species coefficient of 0.65 and an
irrigation efficiency of 90 percent to these types of landscapes.
EPA considered the climate of the landscape when establishing species
coefficients for each category. As stated in Section 4.1.1.7 of the American
Society of Agricultural and Biological Engineers (ASABE) Standard S623.1
Determining Landscape Plant Water Demands, desert plant species are
defined as "plants that can survive a very dry (<10 inches of annual
precipitation) environment" and are assigned a plant factor of 0.3.3 It is EPA's
understanding that the ASABE S623.1 Standard Development Committee
made a conscious decision to limit the application of desert plants due to
concerns these plants would not (either due to biological reasons or user-
3 Although ASABE S623.1 uses plant factors instead of species coefficients, the two terms are related. Plant
factors reflect the amount of water plants need for acceptable appearance, whereas species coefficients
account for optimal growth.
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behavior) require or receive as small of a percentage of irrigation efficiency
as plants in wetter climates.
As the commenter observed, "xeriscaping" in practice is not limited to warm,
arid regions, nor does it by definition require desert plants. Low-water-use
plants can be used in warm, wet states such as Florida. However, it is
unlikely that plants with a species coefficient as low as 0.3 are commonly
used, as these types of desert plants are not suitable for wetter climates.
The species coefficient of 0.65 for non-turf plants used in the WaterSense
Technical Evaluation Process for Approving Home Certification Methods for
other regions was adopted from Table 2.1 of the Residential End Uses of
Water, Version 2. The use of a species coefficient of 0.65 for non-turf plants
is also supported by ASABE S623.1. As explained in Section 4.2.3 of ASABE
S623.1, non-turf plants in arid regions typically exhibit acceptable appearance
and provide intended landscape function at about 50 percent of ET0 (resulting
in a plant factor of 0.5), while those in wet regions require more water to fulfill
the functional and aesthetic purposes of landscaping, with a plant factor of
about 0.7. Lastly, although the species coefficient of 0.65 may appear high, it
accounts for optimal growth (as opposed to aesthetics as indicated by plant
factor), and the overall combined factor would also be tempered by a 90
percent irrigation efficiency, assuming microirrigation is used. The result is
that proper requirements for efficient plant and irrigation selection in a PCM
would still receive favorable credit toward the water efficiency requirement in
the technical evaluation, even in warm, wet climates.
IV.11 Removing References to "Supplemental" Irrigation
One commenter said that EPA should remove references to "supplemental
irrigation" when discussing irrigation.
Response: EPA agrees and has changed the phrase "supplemental irrigation"
to "irrigation" throughout the WaterSense Technical Evaluation Process for
Approving Home Certification Methods.
V. Other Miscellaneous Comments
V.1 Fate of Other WaterSense Program Resources
One commenter observed that the documents supporting Version 2 of the
WaterSense Labeled Homes Program do not address the status of the
WaterSense Water Budget Tool or the WaterSense label for irrigation
professional certification programs. Some green building standards cite these
program elements. The commenter encouraged EPA to work with relevant
green building organizations to resolve any issues related to the potential
elimination of these program elements.
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Response: EPA intends to retain the Water Budget Tool, although it will not
be directly included or referenced in Version 2 of the WaterSense Labeled
Homes Program. Other existing green building programs can continue
referencing this resource, at least in the short term, but should evaluate
alternative references related to landscape and irrigation design to
incorporate it into their certification programs in the future.
EPA is also retaining the WaterSense label for irrigation professional
certification programs. While EPA is not requiring homes pursuing the
WaterSense label to utilize an irrigation professional certified through a
WaterSense labeled program, it does provide water savings credit to PCMs
that require or encourage use of these professionals as described in the
WaterSense Technical Evaluation Process for Approving Home Certification
Methods. In doing so, EPA is encouraging green building programs to
continue to reference the professionals certified through a WaterSense
labeled irrigation professional certification program.
V.2 Suggestions for the WaterSense Specification for Weather-Based
Irrigation Controllers
Two commenters provided comments relating to WaterSense labeled
irrigation controllers.
One commenter said that WaterSense labeled irrigation controllers should
comply with the U.S. Department of Energy's Level VI external power adapter
requirement. The commenter said that although the requirement went into
effect in February 2016, many WaterSense labeled irrigation controllers are
using a Level IV power adapter.
A second commenter wrote that the current testing protocol in the
WaterSense Specification for Weather-Based Irrigation Controllers is
adequate, but that revisions should make the specification more stringent.
The commenter provided a series of suggestions for improvement for any
future specification revision:
• The specification should require 90 percent irrigation adequacy, and the
word "adequacy" should be defined.
• WaterSense labeled irrigation controllers should retain all supplemental
capability requirements.
• WaterSense labeled weather-based irrigation controllers (WBICs)
should have a maximum limit of 80 percent ET0 for cool season grasses
and 60 percent ET0 for warm season grasses. The commenter clarified
that 100 to 125 percent ET0 should not be permitted.
• The Residential End Uses of Water, Version 2 indicated that deficit
irrigation habits are standard practice among homeowners. However,
WBICs are incompatible with deficit irrigation because they increase
household water use. Manufacturers of WaterSense labeled WBICs
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should be encouraged to facilitate deficit irrigation in residential
landscapes.
• The current assumptions for effective rainfall, efficiency allowance, and
some coefficients used to program weather-based irrigation controllers
ultimately result in higher water usage than homeowners expect. It
should be easier to change these default values based on regional
differences.
• Weather-based irrigation controllers should be further classified by their
ability to manage local conditions. The commenterwas involved with a
pilot study of an app-based, weather-based irrigation controller. They
found that one manufacturer could establish defaults to allow the
irrigation controller to match the needs of their regional market. For
example, the irrigation controller could default to warm season turf
grass, instead of cool season turf grass. The commenter found that,
without this customization, 30 percent of this brand's WBICs retained
cool season turf grass settings, potentially resulting in up to 30 percent
excessive irrigation.
Response: EPA appreciates these comments; however, they are beyond the
scope of revisions to the WaterSense Labeled Homes Program. Instead, EPA
considered these comments as part of its review of the WaterSense
Specification for Weather-Based Irrigation Controllers to determine whether a
revision should be completed. More information on EPA's specification review
process can be found at www.epa.gov/watersense/product-specification-
review. EPA encourages these commenters to engage in the specification
revision process if EPA updates the WaterSense Specification for Weather-
Based Irrigation Controllers in the future.
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