Analysis of H.R. 859, a Bill to
Amend the Energy Policy and Conservation Act
to Eliminate Certain Regulation of Plumbing Supplies
Summary of Bill
H.R. 859 was introduced by Rep. Joseph Knollenberg, R-MI, on February 27, 1997. It would repeal the water use standards and labeling requirements for water closets, showerheads, faucets, and urinals contained in the Energy Policy and Conservation Act (EP Act) of 1992. EP Act's standards for efficient water use apply to the manufacture of plumbing fixtures and fixture fittings and have been in effect since January 1, 1994.1
Need for the Bill
According to Rep. Knollenberg, the bill is needed for the following reasons.
The conserving effects of regulated showerheads and toilets are significantly offset by longer shower times and double-flushing.
Lower water flows have caused adults and children to be scalded by showers
Increased incidence of respiratory illness from shower aerosols is possible due to reduced pressure and flow as reported in a University of Cincinnati study.
The public is dissatisfied with fixture performance as evidenced by newspaper articles and complaints to plumbing companies.
Analysis
The need for the bill, as stated above, is not substantiated by a sizeable body of information including laboratory studies, field studies, and customer surveys. This information indicates that: 1) plumbing fixtures meeting EP Act standards save 35% or more of indoor residential water use, which by the year 2020 could reduce the national water demand by nearly 10 billion gallons per day; 2) no evidence exists that real or suspected health problems from showers are more prevalent from low-flow showerheads than from non-conserving types; and 3) customer satisfaction with toilets and showerheads meeting EP Act standards is high.
Ultra Low Flush (ULF) Toilet Performance
Water savings from residential ULF toilets (1.6 gallons or less per flush) have been well documented. Monitoring of residential water use in a number of cities, including Tampa, Phoenix, Austin, and Oakland, has shown water savings from ULF toilets to range from 23% to 46%, despite an increase in average flushing frequency in some homes.2-5 Empirical studies of seven years of data from 23,000 households in Los Angeles and Santa Monica estimated mean savings of 28 gallons per day (gpd) per ULF toilet in single family homes and 44 gpd per toilet in multi-family residences.6 The Metropolitan Water District of Southern California reports that over one million ULF toilets have been retrofitted in its service territory since 1991 with a cumulative water savings over the life of the toilets of approximately 238 billion gallons.7
The problem of inadequate bowl clearance necessitating multiple flushing has been recognized for both ULF and higher flush volume toilets. A 1986 field study of very similar subdivisions in Phoenix measured a much lower incidence of multiple flushing in the homes using ULF toilets than those using 3.5 gallons per flush (gpf) toilets.3 The ULF toilets in the test subdivision used 0.8 gpf, 50% less than the EP Act standard of 1.6 gpf. In a study of Columbia (MD) homes, Stevens Institute of Technology found that double-flushing occurred 1.6% of the time with 3.5 gpf toilets and 2.3% of the time with 1.0 gpf toilets.8 Another study in Boulder showed that the number of flushes per person per day in the homes with 1.6 gpf toilets was only 6.3% more than in the homes with higher volume toilets.9
In two surveys of over 16,000 Los Angeles ULF toilet customers, a majority of the respondents indicated they double flushed with the same or lower frequency than with their replaced model, while about a third indicated they double-flushed more frequently.10,11 In a New York City survey, about three-fourths of 3,250 homeowners said they double-flushed their ULF toilets the same or less often than their old toilets, while about half of 55,450 apartment residents reported double-flushing more often.12 Water use studies in Los Angeles and New York City, however, have demonstrated that despite an increase in the frequency of multiple flushing in some residences, overall water savings were significant.6,13
Surveys, field tests, and laboratory tests have shown significant differences among the various brands and models of ULF toilets with respect to their frequency of multiple flushing.3,10-12,14 Most perform well, some even better than higher flush volume toilets, but others clearly have problems with bowl clearance. The industry has steadily made improvements in the technology and market forces should improve overall performance with time.
Showerhead Performance
The water-saving effects of low-flow showerheads are also well documented. Empirical studies in Los Angeles and Santa Monica estimated average savings per low flow showerhead to be 5.5 gpd in single-family homes and 5.2 gpd in apartments.6 A pilot program in St. Paul (MN) measured savings from low flow showerhead installations in apartments and single-family homes which averaged 20.5 gallons per household per day.15 In another study, shower water use was reduced over 34% with low flow showerheads.2 Although 29% of homeowners felt that the one brand of showerhead retrofitted in the study did not give an adequate shower, average shower time decreased slightly. Some communities, however, have reported increased shower time with low flow showerheads.16 This is thought to be due to spray characteristics and temperature effects associated with some showerhead models, but no national data are available.
Shower Scalding
Scalding can occur from non-conserving or low-flow showerheads. Some laboratory studies indicate that some low-flow showerheads, particularly in combination with certain valving, may have a greater propensity for sudden temperature increases from pressure changes (e.g. from toilet flushing).17 The risk of scalding can be greatly reduced through the use of anti-scald devices which compensate for changes in pressure and temperature. The Uniform Plumbing Code now requires anti-scald valves in all permitted construction. Some water utilities recommend that homeowners set water heaters at approximately 120° F.13
Respiratory Illness
According to the Centers for Disease Control, there is no evidence linking any class or brand of showerhead with increased health risk.18 The USEPA/University of Cincinnati study cited by the bill sponsor tested only three showerheads, two of which were low-flow models.19 The researchers looked at the production of inhalable droplets from the showerheads, principally with an interest in the transmission of volatile organic compounds to humans. Shower flow rate and water pressure were not measured. One of the low-flow showerheads produced significant increases in inhalable droplets, while the other did not, implying that droplet production was not a function of the rated flowrate of the showerhead. According to the principal investigator, the study did not establish a relationship between droplet level and increase in respiratory illness or relate the increase in respirable droplets with pressure or flowrate.20 Considerably more research with many different makes and models of showerheads would be needed to draw any conclusions about the relationship of inhalable droplet production (and implied health risk) to type of showerhead.
Customer Acceptance of ULF Toilets
Surveys of thousands of ULF toilet customers indicate customer satisfaction to be quite high. Surveys of nearly 19,000 customers in Southern California indicated a very positive average rating of 7.8 out of 10, with no appreciable difference between apartment dwellers and homeowners.10,11,21 New York City surveyed over 10,000 apartment residents, homeowners, building owners/managers, and plumbers.12 Homeowners, on average, were satisfied with their ULF toilets. Ratings indicated that apartment residents and owner/managers were only slightly less happy with their ULF toilets than their old ones. The highest ratings for ULF toilets came from plumbers.
In each survey, ratings of ULF toilets by make/model varied significantly. The L.A. surveys concluded that the ULF toilets which require the least frequent double-flushing tend to receive the highest purchaser satisfaction ratings. As market forces improve ULF toilets over time, overall customer satisfaction will increase. Interestingly, the New York survey (the most recent survey cited) indicated positive average ratings by homeowners and plumbers for all but one model of ULF toilet.
Customer Acceptance of Low-flow showerheads
Retrofit programs using showerheads meeting EP Act standards have been conducted in Phoenix, San Jose, Seattle, Boston, Tampa, and Austin without performance complaints.22 Consumers Union rated 29 different models of low-flow showerheads in 1995.23 All but one of the showerheads rated "good" or better. Sixteen rated "very good" or "excellent." The evaluation concluded that, "...chosen carefully, a new [water efficient] toilet or showerhead can work at least as effectively as your present one -- and use less water in the process."
Potential Impact of the Bill
One significant impact of the bill would be on manufacturers of plumbing products. They have retooled their factories to produce products which meet the EP Act standards. Repeal of the standards would no doubt cause a reversion to 1992 conditions where 16 States and many municipalities had low flow fixture standards or regulations. Manufacturers would be forced again to produce products meeting various state, regional, and local standards.
The major effect by far would be on resource conservation. Estimates of water savings resulting from EP Act standards indicate that by the year 2020 savings from residential fixtures alone will reduce the nation's water demand to a level equivalent to that in 1990.22 From 1994 to 2010, the cumulative energy savings from water-efficient fistures are expected to be approximately 2.7 quads, or about 3% of the nation's current annual energy use.24 The environmental and economic benefits of those savings in terms of preventing air and water pollution and protecting aquatic ecosystems are enormous.
The bill would have the effect of increasing the national investment needed for drinking water and wastewater infrastructure improvements and expansion. As was stated, normal replacement and new installation of water-efficient fixtures will dramatically reduce water demand and wastewater flow over the long term. But accelerated installation of water -efficient plumbing fixtures through incentive programs has become a very cost-effective way for some municipalities to substantially reduce water demand and wastewater flows, thus deferring, reducing, or avoiding capital costs of needed water supply and wastewater facilities. The potential for savings is greatest when the demand on a system is close to its capacity.
The magnitude of infrastructure savings achievable through incentive programs for plumbing fixture replacement is impressive. For example, New York City recently invested $393 milion in a ULF toilet rebate program that they estimate has reduced water demand and wastewater flow by 90.6 mgd, 7% of the city's total water consumption.25 The rebate program accomplished a net present value savings of $605 million from a twenty-year deferral of water supply and wastewater treatment expansion projects. Santa Monica completed a ULF toilet replacement program achieving permanent reductions in water usage and wastewater flows of over 1.9 mgd., representing a 15% reduction in average total water demand and a 20% reduction of average total wastewater flow.26 The cost of the rebate program ws $5.4 million. The program will have a net savings of $6 million in the year 2002 due to avoided costs of water imports and wastewater treatment. This savings takes into account lost revenues from water and sewer charges. The Metropolitan Water District of Southern California, its member agencies, and the U.S. Bureau of Reclamation have invested approximately $120 million in toilet retrofit programs since 1990 with cost-effectiveness based primarily on avoided water supply costs.27
It is doubtful that EPA's most recent needs surveys reflect to any great extent the effect that water-efficient fixtures will have on long-term needs. The current 20-year need for drinking water infrastructure is conservatively estimated at $138.4 billion (Jan, '95 dollars).28 The 1996, 20-year clean water infrastructure needs totatled $139.5 billion (Jan, '96 dollars).29 Clearly, billions of dollars of infrastructure costs could be saved or deferred nationwide through the use of water-efficient plumbing fixtures.
REFERENCES
1.Energy Policy and Conservation Act of 1992. Public Law 102-486, October 24, 1992. 102nd Congress. Washington, D.C.
2. Konen, T.P. and D.L. Anderson (1993). The Impact of Water Conserving Plumbing Fixtures on Residential Water Use Characteristics. A report prepared for the City of Tampa Water Department.
3. Anderson, D.L. and R.L. Seigrist. Performance of Ultra-Low Volume Flush Toilets in Phoenix, Arizona. Jour. AWWA 81:3:52 (March, 1989)
4. Cobos, R. (1991). Ultra Low Flow Toilet Demonstration Project Evaluation. A report by the City of Austin Environmental and Conservation Services, Austin, Tex.
5. East Bay Municipal Utilities District Water Conservation Study -- Report No. R219. Stevens Institute of Technology, Hoboken, N.J. (1991).
6. Chestnutt, T.W. and A. Bamezia, C. McSpadden (1992). The Conserving Effect of Ultra Low Flush Toilet Rebate Programs. A report to the Metropolitan Water District of Southern California, Los Angeles, Calif.
7. Personal communication, B. Nadon, Metropolitan Water District of Southern California (April, 1997).
8. Konen, T.P. Field Measured Performance of the Eljer Ultra One/G Water Closet. Stevens Institute of Technology, Hoboken, N.J. (1987).
9. DeOreo, W.B. and P. Lander Evaluating Conservation Retrofit Savings with Precise End-Use Data, presented at the AWWA Annual Conference, Toronto, (June, 1996). top
We apologize that the missing references are unavailable.
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