LAS VEGAS — Two commercial building water efficiency initiatives were announced during the WaterSmart Innovations conference here in October. Plumbing engineers John Koeller, Koeller & Co., and Bill Gauley, Veritec Consulting, who created the Maximum Performance Test for 1.6-gpf and 1.28-gpf toilets, announced that they would develop a testing protocol for commercial toilets. And the Environmental Protection Agency's WaterSense program announced that it wants to expand the program into the commercial/institutional sector.
“It is our opinion that commercial toilets (e.g., flushometer or flush valve toilets) are potentially subjected to a more aggressive environment than residential toilets in the field. Demands for satisfactory flush performance are greater, abuse occurs, and custodial care is generally inferior to residential applications,” Koeller and Gauley said in announcing the program. “Therefore, commercial toilets should have to prove a higher level of flush performance than residential toilets for certification, i.e., the certification requirements should be different for residential and commercial toilet fixtures with the commercial requirements being more rigorous.
“What's more, recent product testing by Veritec Inc. has clearly demonstrated that, contrary to the common perception, all flushometer-operated toilet fixtures do not necessarily out-perform all gravity-operated toilet fixtures,” Koeller and Gauley said. “In fact, a number of gravity-operated fixtures demonstrate flush performance superior to today's flushometer valve/bowl fixture combinations. This is due, in part, to the very aggressive and commendable development of superior gravity-fed and pressure-assist toilet fixtures by the plumbing industry in the last 10-plus years. We believe that once a commercial toilet MaP testing protocol has been established, any toilet model that meets these more rigorous requirements should be allowed to label itself as an ‘industrial’ or ‘commercial’ grade toilet model, regardless of whether it is operated with a flushometer valve, a pressure-assist flushometer tank, or gravity.”
The two engineers said they are seeking feedback from toilet fixture manufacturers, governmental agencies, water providers, and testing facilities, such as the International Association of Plumbing & Mechanical Officials, CSA International, and Intertek. Based on that input, they will develop a commercial toilet MaP testing protocol.
“It is our intention and hope that this testing protocol, once finalized, will be accepted by the various parties and incorporated into the appropriate fixture certification requirements, voluntary labeling programs, and water efficiency incentive programs,” they said.
EPA's WaterSense program issued a 55-page whitepaper that said, given the complicated and multi-faceted nature of the commercial/institutional market, it has no idea what it wants to do.
Koeller called the document a “brain-dump” largely authored by prominent Texas plumbing engineer Bill Hoffman, H.W. Hoffman LLC, who sits on IAPMO's Green Technical Committee. Hoffman is also currently a trustee for and vice chair of the American Water Works Association, Water Conservation Division, and a member of the U.S. Green Building Council's Water Efficiency Technical Advisory Group for LEED.
Hoffman told CONTRACTOR that he didn't actually write the whitepaper, but he assisted EPA in its creation.
EPA noted that it is difficult to get a coherent definition of the sector from market to market or from one water utility to another. The amount of actual water used in the sector is also uncertain.
“While some information is available regarding water use and end uses within CI facilities, data on potential water savings in the sector is scarce, especially on a national scale,” the whitepaper notes. Later the document states, “Although the potential savings have been defined in some areas of the country, benchmarks for facility water use are even more difficult to determine. … Additional data and information is needed to create viable benchmarks for CI facilities on a national scale. The development of such metrics is not only difficult due to a lack of data, but it is further complicated by differences in the structure and categorization of facilities that affect the normalization factors (e.g., gallons per square feet, gallons per employee per day) that could be used to compare water use between differently sized facilities.”
WaterSense program administrators asked dozens of questions, including the following:
Are you aware of any reliable data that is not cited in this paper and could add substantially to our understanding of water use in the CI sector?
If EPA were to set a water use percent reduction target for the CI sector as a whole or for specific subsectors, what should EPA use as the water use baseline and what percent reduction should be targeted?
What program structure do you think EPA should adopt and why?
Is it important to have WaterSense labeled CI sector facilities?
If a certification and labeling scheme is preferred, should EPA have a single-tiered or multi-tiered program? Should certification be third-party or self declaration? Should a specification include percentage reduction requirements, best management practices (BMP) implementation requirements, or both?
If EPA offered technical assistance, what should it be and in what form should it be offered?
If a subsector-specific approach is chosen, should EPA's efforts focus on the largest overall users of water, or on the largest individual accounts?
Should EPA offer an awards program?
Additional information on the program can be found at http://www.epa.gov/watersense.