PMI says CEC’s California emergency drought regs are imprudent, urges use of WaterSense products

April 10, 2015
PMI said that the compliance deadline of January 2016 is unrealistic. PMI has expressed concerns that the 1.2 maximum GPM flow rate for residential lavatory faucets may introduce the risk of waterborne pathogens. PMI has recommended a 1.5 maximum GPM flow rate for residential lavatory faucets.
ROLLING MEADOWS, ILL. — Plumbing Manufacturers International (PMI) said that it agrees with California Governor Jerry Brown’s April 1 drought emergency executive order, but that it is concerned that the California Energy Commission’s emergency regulations call for products with maximum flow rates far below approved WaterSense levels and, in the case of 1.2-GPM residential lavatory faucets, products that do not widely exist.

The California Energy Commission has gone beyond WaterSense standards, mandating that new urinal installations use no more than a pint per flush and faucets max out at 1.2-GPM. The new requirements will take effect next year.

PMI said that the compliance deadline of January 2016 is unrealistic in view of the time required for product development, testing and certification, and meeting the deadline will be difficult, if not impossible.

In addition, consistent with the analysis submitted by acknowledged scientists, PMI has expressed concerns that the 1.2 maximum GPM flow rate for residential lavatory faucets may introduce the risk of waterborne pathogens growing in plumbing systems. Distribution challenges must also be considered.

In its announcement, the CEC claimed that its initiative would save 100 billion gallons of water a year. However, a prominent California plumbing engineer told CONTRACTOR that the CEC is claiming credit for future savings from water conservation measures that were already in place.

In working with the CEC on this issue for some time, PMI advocates the use of current WaterSense-labeled, water-efficient plumbing products meeting Environmental Protection Agency criteria. Using these products can save up to 360 million gallons of water per day in California, according to a PMI estimate.

PMI has therefore recommended a 1.5 maximum GPM flow rate for residential lavatory faucets. PMI advocates for flow rates to be established with an eye toward health, safety and product performance. Replacing, or retrofitting, old plumbing fixtures with WaterSense products will deliver immediate savings now. As noted, the executive order sets flow rate levels to be effective in the future, delaying the impact of water savings.

“The future is now,” said Barbara C. Higgens, CEO and executive director of PMI. “There is no need to postpone savings. Retrofit to WaterSense today.” Higgens will be a part of a panel presentation on “The Future of Water” at an April 13 Water Week event in Washington, D.C.

In anticipation of the need for better water efficiency, PMI has been engaged with the CEC during the two-year regulatory process preceding the governor’s order. As a result, PMI is very familiar with the emergency regulations and supports the ones addressing toilets, kitchen faucets and public lavatory faucets.

PMI will continue to work with and provide input to the CEC, the Department of Water Resources and the State Water Resources Control Board as they work to fulfill Governor Jerry Brown’s executive order to develop a statewide rebate program providing monetary incentives for the purchase of these products, which include toilets, faucets and showerheads bearing the WaterSense label of endorsement.

In an April 7 news announcement, Higgens stated: “In California, the future is now — a time when steps to sustain an ever-precious resource must be taken. As good stewards of the environment, PMI wants the public to know that using water-efficient plumbing products is an immediate action that can be taken to save water. Flow rates must be set carefully within health and safety parameters to avoid unintended consequences. PMI advocates levels specified by the EPA WaterSense program, which takes performance criteria into account in addition to promoting the efficient use of water. There have been tremendous advancements in the technology and efficacy of plumbing products. Just as you wouldn’t use a 25-year-old cell phone, it doesn’t make sense to use 25-year-old plumbing technology.”

PMI has a history of active engagement and support for California legislative and regulatory efforts to accomplish increased water efficiencies:

  • PMI was instrumental in the creation and promulgation of the provisions within AB 715 (Laird, Chapter 499, Statutes of 2007) to reduce water consumption of high-efficiency toilets (HET) to 1.28-gpf and high efficiency urinals (HEU) to 0.5-gpf. This law set levels of sales for high-efficiency water closets and urinals starting in 2010 and went into full effect for all sales of these products on January 1, 2014. All HETs and HEUs sold in California are required to meet these levels.

  • PMI also supported the promulgation of SB 407 (Padilla, Chapter 587, Statutes of 2009), which will require the replacement of plumbing fixtures installed prior to 1994 when new fixtures are installed during new construction or remodeling projects. The older fixtures must be replaced with water-conserving fixtures in single-family residences by 2017 and in commercial and multi-family properties by 2019.

  • PMI also worked closely with the California Department of Housing and Community Development (HCD) and the Building Standards Commission (BSC) to establish water efficiency levels for the 2013 CALGreen section of the California Building Code, which went into effect on January 1, 2014.

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