Comment #1Amendment: WER CommentsPage Number: 1, Draft-WER-Index-Standard-2-3-17.PDFParagraph / Figure / Table / Note: 1.0 Calculating Water Efficiency Rating Index.Comment Intent: ObjectionComment Type: TechnicalComment: Great work in the Water Efficiency Rating Index! One comment, the WER Index does not seem to take into account rainwater or graywater (i.e. onsite generation/reuse). I would argue these should be treated similarly to renewables in the HERS Index. The HERS Index accounts for onsite generation via the PEfrac. I think a similar adjustment would good for the WER Index. Response: Reject Reason: Need more specific comments on how this can be done. Can be considered in a future version.
Great work in the Water Efficiency Rating Index! One comment, the WER Index does not seem to take into account rainwater or graywater (i.e. onsite generation/reuse). I would argue these should be treated similarly to renewables in the HERS Index. The HERS Index accounts for onsite generation via the PEfrac. I think a similar adjustment would good for the WER Index.
Reject
Reason: Need more specific comments on how this can be done. Can be considered in a future version.
Comment #2Amendment: WER CommentsComment Intent: Not an ObjectionComment Type: GeneralComment: My concern/comment is regarding Section 3 referring to the presence or absence of automatic outdoor irrigation systems. Since The WER is being created to be a similar process as the HERS Rating system the approach neexds to be as simple as possible so WER Ratings can be consistent. In that case I agreen with Mr. Osrann's assesement that further studies need to be done. Automatic irrigation systems are common in the northeast (Metropoliton NYC- surrounding areas NJ & CT). Property sizes vary greatly. Taking into account the property size relative to the house size/footprint needs to be thought through. Further this gets complicated with mutlifamily buildings such as town homes and condominiums. Many of which may have a master meter for irrigation with water costs being paid for by a pro-rated share of common interest ownership by the unit owners. How would irrigation water (automatic or not) be aportioned to individual units? Furhter studies need to be done to get a better understanding of the actual percentage of irrigation systems and non-automatic systems. Proposed Change: I don't believe the reference home should include automatic irigation systems. The refernce home should not include any irrigation system, but rather a token "outdoor use" for general garden watering and for car washing. Response: Reject Reason: Misunderstanding about how the model works. Presence or absence of irrigation varies greatly not just with geography, but also by income level/price point, age of the home, etc. The model already takes into account the size of the landscape relative to lot and home as the commentator suggests is critical.
My concern/comment is regarding Section 3 referring to the presence or absence of automatic outdoor irrigation systems. Since The WER is being created to be a similar process as the HERS Rating system the approach neexds to be as simple as possible so WER Ratings can be consistent. In that case I agreen with Mr. Osrann's assesement that further studies need to be done. Automatic irrigation systems are common in the northeast (Metropoliton NYC- surrounding areas NJ & CT). Property sizes vary greatly. Taking into account the property size relative to the house size/footprint needs to be thought through.
Further this gets complicated with mutlifamily buildings such as town homes and condominiums. Many of which may have a master meter for irrigation with water costs being paid for by a pro-rated share of common interest ownership by the unit owners. How would irrigation water (automatic or not) be aportioned to individual units?
Furhter studies need to be done to get a better understanding of the actual percentage of irrigation systems and non-automatic systems.
I don't believe the reference home should include automatic irigation systems. The refernce home should not include any irrigation system, but rather a token "outdoor use" for general garden watering and for car washing.
Reason: Misunderstanding about how the model works. Presence or absence of irrigation varies greatly not just with geography, but also by income level/price point, age of the home, etc. The model already takes into account the size of the landscape relative to lot and home as the commentator suggests is critical.
Comment #3Amendment: WER CommentsParagraph / Figure / Table / Note: 3.0Comment Intent: ObjectionComment Type: TechnicalComment: Many homes will not have an irrigation system, but will have 1 or 2 outdoor faucets with manual on/off valves that connect to garden hoses or above ground sprinkler systems. There should be another equation for this more common configuration in reference homes. The usage will likely vary by climate zones (more use in warmer climates due to longer planting, car washing, and sprinkler use). Also, outdoor faucets have been required in new homes: https://www.nachi.org/forum/f22/many-hose-bibbs-new-home-28281/ R306.5. Exterior Hose Bibs. One- and two-family dwellings shall have not less than two exterior hose bibs, sill cocks or outside hydrants with one being located on the side or rear of the structure. (Effective January 1, 2007) Below is another study about water usage: http://www.cbia.org/uploads/5/1/2/6/51268865/2010_-_chf_water_use_study.pdf Proposed Change: In homes without automatic irrigation but with outdoor faucet fixtures, the reference home outdoor GPD shall be calculated as follows using Equation 3: Equation 3: RefOutgpd = [OutFixtTot * (Cdd / 1000) *CarTot] / 365 Where RefOutgpd = Reference Outdoor water use in gallons per day OutFixtTot = number of outdoor water faucets in reference home (2) Cdd = Annual Cooling Degree-Days CarTot = Reference number of cars associated with reference home Response: Reject Reason: Unsure how the commenter got from the source data to the equation. Reasonable use of outdoor water accounting for all of these uses is already embedded within the reference home outdoor water use. Irrigation systems are additional to these uses.
Many homes will not have an irrigation system, but will have 1 or 2 outdoor faucets with manual on/off valves that connect to garden hoses or above ground sprinkler systems.
There should be another equation for this more common configuration in reference homes. The usage will likely vary by climate zones (more use in warmer climates due to longer planting, car washing, and sprinkler use).
Also, outdoor faucets have been required in new homes:
https://www.nachi.org/forum/f22/many-hose-bibbs-new-home-28281/
R306.5. Exterior Hose Bibs. One- and two-family dwellings shall have not less than two exterior hose bibs, sill cocks or outside hydrants with one being located on the side or rear of the structure. (Effective January 1, 2007)
Below is another study about water usage:
http://www.cbia.org/uploads/5/1/2/6/51268865/2010_-_chf_water_use_study.pdf
In homes without automatic irrigation but with outdoor faucet fixtures, the reference home outdoor GPD shall be calculated as follows using Equation 3:
Equation 3:
RefOutgpd = [OutFixtTot * (Cdd / 1000) *CarTot] / 365
Where
RefOutgpd = Reference Outdoor water use in gallons per day
OutFixtTot = number of outdoor water faucets in reference home (2)
Cdd = Annual Cooling Degree-Days
CarTot = Reference number of cars associated with reference home
Reason: Unsure how the commenter got from the source data to the equation. Reasonable use of outdoor water accounting for all of these uses is already embedded within the reference home outdoor water use. Irrigation systems are additional to these uses.
Comment #4Amendment: WER CommentsParagraph / Figure / Table / Note: 2.6Comment Intent: ObjectionComment Type: TechnicalComment: It is technically impossible for someone to perform 5% of a flush. The reference flushes per day should be a whole number. Proposed Change: refFPO = the reference flushes per person per day = 5.05 5 Response: Reject Reason: Based on statistical average. The value used to determine total daily water consumption as a function of gallons per flush does not have to be an exact even number of flushes. The number of occupants used to determine toilet water use is also not a whole number. What is important to water savings is the gallons per flush for the rated home.
It is technically impossible for someone to perform 5% of a flush. The reference flushes per day should be a whole number.
refFPO = the reference flushes per person per day = 5.05 5
Reason: Based on statistical average. The value used to determine total daily water consumption as a function of gallons per flush does not have to be an exact even number of flushes. The number of occupants used to determine toilet water use is also not a whole number. What is important to water savings is the gallons per flush for the rated home.
Comment #5Amendment: WER CommentsParagraph / Figure / Table / Note: 4.2 and 4.3Comment Intent: ObjectionComment Type: TechnicalComment: Based on Table 3 of the attached report, kitchen and lavatory faucets used 23.3% of indoor water use in 1990 homes and 25.8% of indoor water use in new homes in 2009. Using linear interpolation, a value of 25% would be appropriate for a 2006 home (or 25.4% to be more exact). Also, the ratio kitchen to bathroom faucet use is different. See : http://www.cbia.org/uploads/5/1/2/6/51268865/2010_-_chf_water_use_study.pdf Proposed Change: faucetpc = Percent of indoor fixture water use consumed by indoor faucets = 46% 25% Kitch = the percentage of indoor faucet use that is attributed to kitchen faucets = 69% 84% Lav = - the percentage of indoor faucet use that is attributed to lavatory faucets = 31% 16% Response: Reject Reason: Study cited uses flawed method. The progression of water use percentages is not linear. EPAct legislation caused sudden shifts. The report mentioned estimates total end uses based on rate flow volumes and average usage durations. In recent years this methodology has been debunked.
Based on Table 3 of the attached report, kitchen and lavatory faucets used 23.3% of indoor water use in 1990 homes and 25.8% of indoor water use in new homes in 2009. Using linear interpolation, a value of 25% would be appropriate for a 2006 home (or 25.4% to be more exact).
Also, the ratio kitchen to bathroom faucet use is different.
See :
faucetpc = Percent of indoor fixture water use consumed by indoor faucets = 46% 25%
Kitch = the percentage of indoor faucet use that is attributed to kitchen faucets = 69% 84%
Lav = - the percentage of indoor faucet use that is attributed to lavatory faucets = 31% 16%
Reason: Study cited uses flawed method. The progression of water use percentages is not linear. EPAct legislation caused sudden shifts. The report mentioned estimates total end uses based on rate flow volumes and average usage durations. In recent years this methodology has been debunked.
Comment #6Amendment: WER CommentsParagraph / Figure / Table / Note: 4.3Comment Intent: ObjectionComment Type: TechnicalComment: This proposed change corrects the equation for lavatory faucet gallons per day. Proposed Change: LavFgpd = FixtureTot * faucetpc * KitchFeff LavFeff * Lav Response: Accept Reason: Proposed change corrects the equation.
This proposed change corrects the equation for lavatory faucet gallons per day.
LavFgpd = FixtureTot * faucetpc * KitchFeff LavFeff * Lav
Accept
Reason: Proposed change corrects the equation.
Comment #7Amendment: WER CommentsParagraph / Figure / Table / Note: 4.3Comment Intent: ObjectionComment Type: TechnicalComment: This proposed change corrects the equation for lavatory faucet gallons per day. Proposed Change: LavFgpd = FixtureTot * faucetpc * KitchFeff LavFeff * Lav Response: Accept Reason: Proposed change corrects the equation.
Comment #8Amendment: WER CommentsParagraph / Figure / Table / Note: 2.0Comment Intent: ObjectionComment Type: TechnicalComment: According to the Energy Information Administration's 2009 Residential Energy Consumption Survey, 110.1 million US homes had space heating systems in 2009. Of those homes, 6.9 million homes had a natural gas fired hot water or steam boiler, and 3.9 million homes had a fuel oil fired hot water or steam boiler. Other homes use propane or electric boilers. Based on this data, at least 10% of US homes have a hydronic heating system that will use water for space heating purposes. This proposal accounts for their water use. For forced air heating systems, the reference value will be 0.0 gpd. Proposed Change: refingpd = refFgpd+ ....+ totLeaks + refSHgpd Where: refFgpd = ..... refSHgpd = daily space heating system water use for the reference home Response: Reject Reason: No research on the water loss. Overall water use is insignificant compared to entire home. Commenter should provide data to base this on and committee will consider. Vast majority of hydronic heating systems in new residential construction are closed loops with very minimal water usage.
According to the Energy Information Administration's 2009 Residential Energy Consumption Survey, 110.1 million US homes had space heating systems in 2009. Of those homes, 6.9 million homes had a natural gas fired hot water or steam boiler, and 3.9 million homes had a fuel oil fired hot water or steam boiler. Other homes use propane or electric boilers.
Based on this data, at least 10% of US homes have a hydronic heating system that will use water for space heating purposes.
This proposal accounts for their water use. For forced air heating systems, the reference value will be 0.0 gpd.
refingpd = refFgpd+ ....+ totLeaks + refSHgpd
Where: refFgpd = .....
refSHgpd = daily space heating system water use for the reference home
Reason: No research on the water loss. Overall water use is insignificant compared to entire home. Commenter should provide data to base this on and committee will consider. Vast majority of hydronic heating systems in new residential construction are closed loops with very minimal water usage.
Comment #9Amendment: WER CommentsParagraph / Figure / Table / Note: 2.8 and 2.0Comment Intent: ObjectionComment Type: TechnicalComment: The current equation overstates water losses due to leaks. According to the equation, a 3 bedroom house will have 17.79 leaks (equal to 17.79 gallons per day). That would be equal to 6,493 gallon of water lost per year, or about 11% of total indoor consumption for a 2009 California home (see http://www.cbia.org/uploads/5/1/2/6/51268865/2010_-_chf_water_use_study.pdf Table 3). Whether it is one leak or 17 leaks, at least some or all of them would be visible to homeowners and they would be fixed. Also, it does not make sense that a 4 bedroom 2-bath house would have two times more leaks (or two times the volume of leaks) as a 2 bedroom, 2 bath house with the same piping layout. Since this is focused on water, it is much more likely that the leaks would be a function of the number of bathrooms, not the number of bedrooms in a house. Proposed Change: totLeaksgpd = 5.93 * Nbr 1 * Nbathr Where: Nbr Nbathr = the number of bedrooms bathrooms in the rated home Response: Reject Reason: No data to suggest bedrooms are a better surrogate than bathrooms. Agree that the name “Leaks” should be changed to more accurately reflect the source of consumption. This is an accommodation for the unknown. As more data becomes available, changes will be considered.
The current equation overstates water losses due to leaks. According to the equation, a 3 bedroom house will have 17.79 leaks (equal to 17.79 gallons per day). That would be equal to 6,493 gallon of water lost per year, or about 11% of total indoor consumption for a 2009 California home (see http://www.cbia.org/uploads/5/1/2/6/51268865/2010_-_chf_water_use_study.pdf Table 3).
Whether it is one leak or 17 leaks, at least some or all of them would be visible to homeowners and they would be fixed. Also, it does not make sense that a 4 bedroom 2-bath house would have two times more leaks (or two times the volume of leaks) as a 2 bedroom, 2 bath house with the same piping layout.
Since this is focused on water, it is much more likely that the leaks would be a function of the number of bathrooms, not the number of bedrooms in a house.
totLeaksgpd = 5.93 * Nbr 1 * Nbathr
Where:
Nbr Nbathr = the number of bedrooms bathrooms in the rated home
Reason: No data to suggest bedrooms are a better surrogate than bathrooms. Agree that the name “Leaks” should be changed to more accurately reflect the source of consumption. This is an accommodation for the unknown. As more data becomes available, changes will be considered.
Comment #10Amendment: WER CommentsParagraph / Figure / Table / Note: 4.9Comment Intent: ObjectionComment Type: TechnicalComment: Under the current equation, the rated home has the same "leak" equation as the reference home, so it gets no credit for reducing or eliminating water leaks. This creates a significant penalty, especially for larger homes with more bedrooms. The revised equation allows credit for good design and installation practice in a rated home. Proposed Change: Leaksgpd = TotLeaksbr * Nb Where: TotLeaks_br = the average value (in gpd) of leaks per bedroom = 5.93 gpd Nbr = the number of bedrooms in the rated home Leaks gpd = Measured leaks in kitchens and bathrooms over one hour * 24 Response: Reject Reason: **See #9, above. This number doesn’t just reflect leaks. “Leaks” will be renamed to “Other” to more accurately reflect the actual consumption.
Under the current equation, the rated home has the same "leak" equation as the reference home, so it gets no credit for reducing or eliminating water leaks.
This creates a significant penalty, especially for larger homes with more bedrooms.
The revised equation allows credit for good design and installation practice in a rated home.
Leaksgpd = TotLeaksbr * Nb
TotLeaks_br = the average value (in gpd) of leaks per bedroom = 5.93 gpd
Nbr = the number of bedrooms in the rated home
Leaks gpd = Measured leaks in kitchens and bathrooms over one hour * 24
Reason: **See #9, above. This number doesn’t just reflect leaks. “Leaks” will be renamed to “Other” to more accurately reflect the actual consumption.
Comment #11Amendment: WER CommentsParagraph / Figure / Table / Note: 4.0 and 5.0Comment Intent: ObjectionComment Type: TechnicalComment: If a rated home has a water recovery system (air conditioning and/or heating system from the indoor condensates, or rainwater recovery from the outdoors), then the equations should have another variable with minus signs showing lower water usage. Below are web site links with more information: http://www.allianceforwaterefficiency.org/Condensate_Water_Introduction.aspx http://www.arcsa.org/ http://www.ecy.wa.gov/programs/wr/hq/rwh.html Proposed Change: 4.0 Indoorgpd = Showergpd + .... + Leaksgpd - RecWgpd Where: ... RecWgpd = average daily recovered water for indoor water functions in gallons per day 5.0 If the rated home..... * netET] - RecOWgpd Where: RecOWgpd = average daily recovered outdoor water for outdoor water functions in gallons per day Response: Reject Reason: Collecting the water does not improve efficiency unless the water is used to supplant potable sources. The credit should occur where the alternate water is used, not just collected. The technical subcommittees did not feel addressing alternative water sources was a priority at this time. And there was not a reliable way to estimate the usage of evaporative cooling systems. Such a calculation would be necessary for estimating the amount of available condensate.
If a rated home has a water recovery system (air conditioning and/or heating system from the indoor condensates, or rainwater recovery from the outdoors), then the equations should have another variable with minus signs showing lower water usage.
Below are web site links with more information:
http://www.allianceforwaterefficiency.org/Condensate_Water_Introduction.aspx
http://www.arcsa.org/
http://www.ecy.wa.gov/programs/wr/hq/rwh.html
4.0
Indoorgpd = Showergpd + .... + Leaksgpd - RecWgpd
Where: ...
RecWgpd = average daily recovered water for indoor water functions in gallons per day
5.0
If the rated home..... * netET] - RecOWgpd
RecOWgpd = average daily recovered outdoor water for outdoor water functions in gallons per day
Reason: Collecting the water does not improve efficiency unless the water is used to supplant potable sources. The credit should occur where the alternate water is used, not just collected. The technical subcommittees did not feel addressing alternative water sources was a priority at this time. And there was not a reliable way to estimate the usage of evaporative cooling systems. Such a calculation would be necessary for estimating the amount of available condensate.
Comment #12Amendment: WER CommentsParagraph / Figure / Table / Note: 4.0 and 5.0Comment Intent: ObjectionComment Type: TechnicalComment: If a rated home has a water recovery system (air conditioning and/or heating system from the indoor condensates, or rainwater recovery from the outdoors), then the equations should have another variable with minus signs showing lower water usage. Below are web site links with more information: http://www.allianceforwaterefficiency.org/Condensate_Water_Introduction.aspx http://www.arcsa.org/ http://www.ecy.wa.gov/programs/wr/hq/rwh.html Proposed Change: 4.0 Indoorgpd = Showergpd + .... + Leaksgpd - RecWgpd Where: ... RecWgpd = average daily recovered water for indoor water functions in gallons per day 5.0 If the rated home..... * netET] - RecOWgpd Where: RecOWgpd = average daily recovered outdoor water for outdoor water functions in gallons per day Response: Reject Reason: Collecting the water does not improve efficiency unless the water is used to supplant potable sources. The credit should occur where the alternate water is used, not just collected. The technical subcommittees did not feel addressing alternative water sources was a priority at this time. And there was not a reliable way to estimate the usage of evaporative cooling systems. Such a calculation would be necessary for estimating the amount of available condensate.
Comment #13Amendment: WER CommentsComment Intent: Not an ObjectionComment Type: TechnicalComment: Steve: looks good! 1. Can the rated home have zero irrigated area? For example, all plants are native or adapted and can live on annual natural precipitation and no irrigation system is installed. Response: Reject Reason: No proposed language submitted. Yes, a home can have zero irrigated area.
Steve: looks good! 1. Can the rated home have zero irrigated area? For example, all plants are native or adapted and can live on annual natural precipitation and no irrigation system is installed.
Reason: No proposed language submitted. Yes, a home can have zero irrigated area.
Comment #14Amendment: WER CommentsComment Intent: Not an ObjectionComment Type: TechnicalComment: It’s great to see actual WER documents and its fantastic also to read the details of the guidelines and standards. My hats off to all those who have gotten us to this point. After reading through the documents I really would like to address one feature: dualflush toilets. Working out in the field I see dual-flush toilets more and more. They are becoming standard features for some builders, and more and more prevalent in existing homes as well. Our 1970 home had all three toilets replaced last year with WaterSense dual-flush toilets. As written in the standard it shows a reference for 5.05 flushes per day at 1.6 gallons per flush. And this is a great foundation. However I think it is worthy of an “area in need of future improvement and/or discussion”. Perhaps there could be a selection for the reference home to have a standard toilet and a dual-flush? For example perhaps a dual flush toilet would use 4 flushes per day on the low flush mode and 1 mode per day at the high flush mode — per person. Just something perhaps for us all to discuss. I won’t be able to make it the conference this year but will teleconference in for the meeting on the 28th. Thanks so much, it's a privilege for me to be part of this steering committee. Response: Accept in Principle Reason: Comment accepted in principle, but we’re using a 2:1 instead of 4:1 ratio.
It’s great to see actual WER documents and its fantastic also to read the details of the guidelines and standards. My hats off to all those who have gotten us to this point. After reading through the documents I really would like to address one feature: dualflush toilets. Working out in the field I see dual-flush toilets more and more. They are becoming standard features for some builders, and more and more prevalent in existing homes as well. Our 1970 home had all three toilets replaced last year with WaterSense dual-flush toilets. As written in the standard it shows a reference for 5.05 flushes per day at 1.6 gallons per flush. And this is a great foundation. However I think it is worthy of an “area in need of future improvement and/or discussion”. Perhaps there could be a selection for the reference home to have a standard toilet and a dual-flush? For example perhaps a dual flush toilet would use 4 flushes per day on the low flush mode and 1 mode per day at the high flush mode — per person. Just something perhaps for us all to discuss. I won’t be able to make it the conference this year but will teleconference in for the meeting on the 28th. Thanks so much, it's a privilege for me to be part of this steering committee.
Accept in Principle
Reason: Comment accepted in principle, but we’re using a 2:1 instead of 4:1 ratio.
Comment #15Amendment: WER CommentsComment Intent: ObjectionComment Type: TechnicalComment: 1. Section 1.0 – I’m surprised to see that the index is proposed for use with multi-family dwellings. I don’t recall any discussion of this feature, and have always viewed the context of this initial index as pertaining to single-family homes (including townhomes). REUWS 2, from which the outdoor water use relationships in the index were established, was a survey of single-family homes. In multi-family properties, parking lots and possibly other common area features will influence the proportion of the parcel given to landscape requiring supplemental irrigation, in ways that are not present in single-family homes. While it is highly desirable to move toward an index that can be applied to multi-family properties, I don’t believe this first edition is ready to perform that function. 2. Section 3.0 – Outdoor Reference GPD. The presence or absence of an automatic irrigation system is a major unresolved issue. While mentioned as such in the cover memo, it is under the heading of “Future Improvement.” I believe strongly that further refinement is necessary and should be made before the initial version of the WER Index is finalized. Allowing any rated home with an automatic irrigation system to invoke a reference home similarly equipped in the extensive portions of the country where automatic systems have not been common ensures a great distortion in WER Index scores in such areas. The memo notes a consensus of support for this treatment, but also some dissent. I call attention here to a bit of new information that became public after most of the outdoor committee work was completed. On November 17, the WaterSense Program released a draft proposal for pressure regulating irrigation sprinkler bodies. In the notice, EPA revealed information it has held since the 2005 DOE RECS survey that has not been made public regarding the installed base of automatic sprinkler systems. The Draft Specification for Spray Sprinkler Bodies Supporting Statement states that based on 2005 RECS data, “An estimated 13.5 million in-ground irrigation systems are currently installed in residential landscapes across the United States.” It is not clear whether the 13.5 million is a restatement of the 2005 count or whether a lower number from 2005 was projected to the present day to reach 13.5 million. At most, a count of 13.5 million sprinkler systems in 2005 would represent less than 18% of the 76 million occupied single-family homes in 2005. Given the prevalence of automatic irrigation systems in California, the Southwest, Texas, and Florida (where an automatic system in the reference home would be appropriate), the number of such systems in the remainder of the country must necessarily be vanishingly small –well under 10%. Allowing any home anywhere in the country with an automatic irrigation system to be compared with a reference home with an automatic system will be a benefit that will not easily be withdrawn in a future revision to the WER Index, and I would have very serious reservations about NRDC endorsing such a scoring system. I urge that this issue be given more attention and a revised approach formulated before adoption later this year that can be credibly applied to the eastern portions of the country. 3. Section 4.3 – Lavatory Faucets (rated home). Although lavatory faucets are thought to use less than half of the water of kitchen faucets, opportunities to save more than 5% from standard (2.2 gpm) units are widely available. Rather than providing a single point of credit for an efficient lavatory faucet regardless of the actual flow rate, it would be preferable to calculate lavatory faucet efficiency using the same method as is proposed for kitchen faucets and showerheads, i.e., a fraction that fully captures the reduction in rated flow from a standard faucet. 4. Section 4.5 -- Clothes washers (rated home). Two issues need attention here. First, although the formula for calculating clothes washer gpd calls for the use of the specific water factor of the washer, the Excel worksheet has fixed drop-down values (the lowest of which is 7.0), rather than allowing the machine-specific water factor to be entered. Values lower than 7.0 are widely available today, so the spreadsheet should be revised to accommodate a specific WF entry. Secondly, a default value of 2.874 cu ft for washer capacity is very likely too low for today’s new machines. There has been upward creep in clothes washer capacity for several years, and while entering the actual capacity value is certainly preferable, a default value, should it be used, should be more realistic. Thank you for your consideration of these comments. Response: Reject Reason: Part 4: standard does not limit water factor that can be entered, nor does it limit the value of the washer volume that can be entered. Modeling committee to look into possible change to equation based on latest end use study to account for a non-linear relationship between number of bedrooms and loads of laundry.
1. Section 1.0 – I’m surprised to see that the index is proposed for use with multi-family
dwellings. I don’t recall any discussion of this feature, and have always viewed the
context of this initial index as pertaining to single-family homes (including
townhomes). REUWS 2, from which the outdoor water use relationships in the index
were established, was a survey of single-family homes. In multi-family properties,
parking lots and possibly other common area features will influence the proportion of the
parcel given to landscape requiring supplemental irrigation, in ways that are not present
in single-family homes. While it is highly desirable to move toward an index that can be
applied to multi-family properties, I don’t believe this first edition is ready to perform that
function.
2. Section 3.0 – Outdoor Reference GPD. The presence or absence of an automatic
irrigation system is a major unresolved issue. While mentioned as such in the cover
memo, it is under the heading of “Future Improvement.” I believe strongly that further
refinement is necessary and should be made before the initial version of the WER Index
is finalized. Allowing any rated home with an automatic irrigation system to invoke a
reference home similarly equipped in the extensive portions of the country where
automatic systems have not been common ensures a great distortion in WER Index
scores in such areas. The memo notes a consensus of support for this treatment, but
also some dissent. I call attention here to a bit of new information that became public
after most of the outdoor committee work was completed. On November 17, the
WaterSense Program released a draft proposal for pressure regulating irrigation
sprinkler bodies. In the notice, EPA revealed information it has held since the 2005
DOE RECS survey that has not been made public regarding the installed base of
automatic sprinkler systems. The Draft Specification for Spray Sprinkler Bodies
Supporting Statement states that based on 2005 RECS data, “An estimated 13.5 million
in-ground irrigation systems are currently installed in residential landscapes across the
United States.” It is not clear whether the 13.5 million is a restatement of the 2005
count or whether a lower number from 2005 was projected to the present day to reach
13.5 million. At most, a count of 13.5 million sprinkler systems in 2005 would represent
less than 18% of the 76 million occupied single-family homes in 2005. Given the
prevalence of automatic irrigation systems in California, the Southwest, Texas, and
Florida (where an automatic system in the reference home would be appropriate), the
number of such systems in the remainder of the country must necessarily be
vanishingly small –well under 10%.
Allowing any home anywhere in the country with an automatic irrigation system to be
compared with a reference home with an automatic system will be a benefit that will not
easily be withdrawn in a future revision to the WER Index, and I would have very
serious reservations about NRDC endorsing such a scoring system. I urge that this
issue be given more attention and a revised approach formulated before adoption later
this year that can be credibly applied to the eastern portions of the country.
3. Section 4.3 – Lavatory Faucets (rated home). Although lavatory faucets are thought
to use less than half of the water of kitchen faucets, opportunities to save more than 5%
from standard (2.2 gpm) units are widely available. Rather than providing a single point
of credit for an efficient lavatory faucet regardless of the actual flow rate, it would be
preferable to calculate lavatory faucet efficiency using the same method as is proposed
for kitchen faucets and showerheads, i.e., a fraction that fully captures the reduction in
rated flow from a standard faucet.
4. Section 4.5 -- Clothes washers (rated home). Two issues need attention here. First,
although the formula for calculating clothes washer gpd calls for the use of the specific
water factor of the washer, the Excel worksheet has fixed drop-down values (the lowest
of which is 7.0), rather than allowing the machine-specific water factor to be
entered. Values lower than 7.0 are widely available today, so the spreadsheet should
be revised to accommodate a specific WF entry. Secondly, a default value of 2.874 cu
ft for washer capacity is very likely too low for today’s new machines. There has been
upward creep in clothes washer capacity for several years, and while entering the actual
capacity value is certainly preferable, a default value, should it be used, should be more
realistic.
Thank you for your consideration of these comments.
Reason: Part 4: standard does not limit water factor that can be entered, nor does it limit the value of the washer volume that can be entered. Modeling committee to look into possible change to equation based on latest end use study to account for a non-linear relationship between number of bedrooms and loads of laundry.
Comment #16Amendment: WER CommentsComment Intent: Not an ObjectionComment Type: TechnicalComment: I assume the equations establish the baseline home condition and are the default assumed condition for the rated home. I was not clear on how the rated home’s equations would be modified and reduced. Flush and aerators have a rated capacity, so that is easy. But as an example, the leak assumption would be reduced if there was a leak detection of leak water flow monitor ... but how? The landscape assumption would be similar reduce with drought tolerant, zeroscape, or weather sensing irrigation ... again, what do those algorithms look like? Great foundation, just interested in the currently unidentified but very important credit processes, since that will drive the resultant behaviors. Response: Reject Reason: Thank you
I assume the equations establish the baseline home condition and are the default
assumed condition for the rated home.
I was not clear on how the rated home’s equations would be modified and
reduced. Flush and aerators have a rated capacity, so that is easy. But as an example,
the leak assumption would be reduced if there was a leak detection of leak water flow
monitor ... but how? The landscape assumption would be similar reduce with drought
tolerant, zeroscape, or weather sensing irrigation ... again, what do those algorithms
look like?
Great foundation, just interested in the currently unidentified but very important credit
processes, since that will drive the resultant behaviors.
Reason: Thank you
Comment #17Amendment: WER CommentsComment Intent: Not an ObjectionComment Type: TechnicalComment: Overall, I like what you have created. Speaking as someone who has sweated through the implementation of Addendum A, please expect that there will be some need for refinement even after public comments have been addressed and the WER Index adopted. There is a lot to absorb, and many complex interactions. I’m assuming that some elements are being included now even though there may be no pragmatic way for the foreseeable future to assess how the Rated Home can be better than the Reference Home – for example, the aspect of determining leaks in the Rated Home. Typo? Please see “Oc” at the end of the equation for Toiletgpd of the Rated Home. Another observation: In my first look at this, I’m finding it challenging to distinguish between “IrrArea” and “Rat_Irr_Area.” Response: Accept Reason: Typo will be fixed.
Overall, I like what you have created. Speaking as someone who has sweated through
the implementation of Addendum A, please expect that there will be some need for
refinement even after public comments have been addressed and the WER Index
adopted. There is a lot to absorb, and many complex interactions.
I’m assuming that some elements are being included now even though there may be no
pragmatic way for the foreseeable future to assess how the Rated Home can be better
than the Reference Home – for example, the aspect of determining leaks in the Rated
Home.
Typo? Please see “Oc” at the end of the equation for Toiletgpd of the Rated Home.
Another observation: In my first look at this, I’m finding it challenging to distinguish
between “IrrArea” and “Rat_Irr_Area.”
Reason: Typo will be fixed.
Comment #18Amendment: WER CommentsComment Intent: ObjectionComment Type: GeneralComment: The name that RESNET has chosen for this index, Water Efficiency Rating Index (WER Index), needs to be changed to avoid marketplace confusion with the Water Efficiency Rating Score (WERS)® program owned by Green Builder® Coalition. Green Builder® Coalition began development of its WERS Program in February 2014. The WERS Program is a performance-based water efficiency program for residential properties that uses a 0-100 scale to assign a score to a property. Since that time, the WERS Program has been: • Included in the rules of compliance for the State of New Mexico’s Sustainable Building Tax Credit in 2016 • Adopted into the City of Santa Fe’s residential green building code in October 2016 as a mandatory requirement for all new single-family properties effective March 1, 2017 • The subject of training classes and numerous national and regional conference presentations Green Builder® Coalition has obtained a federal trademark registration for Water Efficiency Rating Score (WERS)®. Signed, Mike Collignon, Executive Director of the Green Builder® Coalition (on behalf of the Green Builder® Coalition Board of Directors) Response: Reject Reason: Issue to be addressed by RESNET management.
The name that RESNET has chosen for this index, Water Efficiency Rating Index (WER Index), needs to be changed to avoid marketplace confusion with the Water Efficiency Rating Score (WERS)® program owned by Green Builder® Coalition.
Green Builder® Coalition began development of its WERS Program in February 2014. The WERS Program is a performance-based water efficiency program for residential properties that uses a 0-100 scale to assign a score to a property. Since that time, the WERS Program has been:
• Included in the rules of compliance for the State of New Mexico’s Sustainable Building Tax Credit in 2016 • Adopted into the City of Santa Fe’s residential green building code in October 2016 as a mandatory requirement for all new single-family properties effective March 1, 2017 • The subject of training classes and numerous national and regional conference presentations
Green Builder® Coalition has obtained a federal trademark registration for Water Efficiency Rating Score (WERS)®.
Signed, Mike Collignon, Executive Director of the Green Builder® Coalition (on behalf of the Green Builder® Coalition Board of Directors)
Reason: Issue to be addressed by RESNET management.
Comment #19Amendment: WER CommentsComment Intent: Not an ObjectionComment Type: GeneralComment: When this was developed, I understand that the Residential End Use Water Study was used to determine which variables are predictive to water usage. During the session at the conference, Mr. Schein expressed that not all variables where present/recorded in REUWS data set. He made the comment that energy consumption is data rich while water usage data is scarce. I would suggest that Resnet think about how this tool will create a rich data set for water use consumption. Are there key attributes which could be included and measured easily that will add add considerable value to in later data analysis? Response: Reject Reason: The index will not collect water use data, but only attributes. Outside scope of this committee. Standard is not intended to collect consumption data.
When this was developed, I understand that the Residential End Use Water Study was used to determine which variables are predictive to water usage. During the session at the conference, Mr. Schein expressed that not all variables where present/recorded in REUWS data set. He made the comment that energy consumption is data rich while water usage data is scarce. I would suggest that Resnet think about how this tool will create a rich data set for water use consumption. Are there key attributes which could be included and measured easily that will add add considerable value to in later data analysis?
Reason: The index will not collect water use data, but only attributes. Outside scope of this committee. Standard is not intended to collect consumption data.
Comment #20Amendment: WER CommentsParagraph / Figure / Table / Note: 4Comment Intent: Not an ObjectionComment Type: GeneralComment: The US EPA’s WaterSense program recognizes that the WER Index is intended to be a volumetric representation of a home’s water use. However, we would like to urge caution on the pursuit of ever lower flowrates/more efficient products without consideration for product performance. The plumbing industry has had years of experience with public backlash over poorly performing products. So much so that the WaterSense program includes performance criteria in addition to efficiency criteria in its product specifications. Meaning that a product bearing the WaterSense label has not only been third party certified to save water, but also to perform as well or better than standard efficiency models. We urge RESNET to mindful of product performance in this effort and to take steps to educate its raters, builders, and stakeholders about this important issue as the WER Index is introduced. Response: Accept in Principle Reason: Does not propose any changes, but has important points for RESNET to consider in developing education materials.
The US EPA’s WaterSense program recognizes that the WER Index is intended to be a volumetric representation of a home’s water use. However, we would like to urge caution on the pursuit of ever lower flowrates/more efficient products without consideration for product performance. The plumbing industry has had years of experience with public backlash over poorly performing products. So much so that the WaterSense program includes performance criteria in addition to efficiency criteria in its product specifications. Meaning that a product bearing the WaterSense label has not only been third party certified to save water, but also to perform as well or better than standard efficiency models. We urge RESNET to mindful of product performance in this effort and to take steps to educate its raters, builders, and stakeholders about this important issue as the WER Index is introduced.
Reason: Does not propose any changes, but has important points for RESNET to consider in developing education materials.
Comment #21Amendment: WER CommentsParagraph / Figure / Table / Note: 5.1Comment Intent: ObjectionComment Type: TechnicalComment: “Smart” controllers is a somewhat ambiguous term. In fact, the Residential End Uses of Water Study (which is utilized extensively in the WER Index) experienced problems collecting information about “smart” controllers as many individuals interpreted a clock timer with a digital interface as “smart” (something that would need meet the definition of a smart controller by most industry professionals). Referencing the WaterSense certification for weather and soil moisture sensor based irrigation controllers provides an easy way to ensure that only products that actually include the features likely to result in an expected 15% savings are awarded this credit. Proposed Change: Smart Controllers. Sensor and weather based irrigation controllers that have earned the WaterSense label, shall decrease the portion of predicted rated home outdoor water use associated with irrigation (less the water use associated with pools) by 15% in homes that have automatic irrigation. Response: Accept Reason: Labeled controllers have third party performance verification.
“Smart” controllers is a somewhat ambiguous term. In fact, the Residential End Uses of Water Study (which is utilized extensively in the WER Index) experienced problems collecting information about “smart” controllers as many individuals interpreted a clock timer with a digital interface as “smart” (something that would need meet the definition of a smart controller by most industry professionals). Referencing the WaterSense certification for weather and soil moisture sensor based irrigation controllers provides an easy way to ensure that only products that actually include the features likely to result in an expected 15% savings are awarded this credit.
Smart Controllers. Sensor and weather based irrigation controllers that have earned the WaterSense label, shall decrease the portion of predicted rated home outdoor water use associated with irrigation (less the water use associated with pools) by 15% in homes that have automatic irrigation.
Reason: Labeled controllers have third party performance verification.
Comment #22Amendment: WER CommentsParagraph / Figure / Table / Note: 5.3Comment Intent: ObjectionComment Type: TechnicalComment: Ensuring that an irrigation system performs well via an irrigation audit has been proven to be an effective way to reduce water consumption. In their paper “Impact Evaluation of Residential Irrigation Audits on Water Conservation in Colorado”; Shimabuku, Stellar, and Mayer found an average savings of 6% outdoor water use over 2,000 residential sprinkler audits. The WaterSense program identifies certification programs for irrigation professionals that meet minimum criteria and maintains a directory of these professionals on its website. Providing an easy way to identify individuals who are actually qualified to implement an audit protocol. Meanwhile ASABE 626 provides an ANSI standard that governs how to conduct a uniformity test. Proposed Change: In rated homes where documentation is provided the water use associated with irrigation shall be decreased by 5% were a certified professional (as identified by a WaterSense labeled certification) in accordance with ASABE 626 verifies: • DU is at least 65% on turf areas • Sprinklers are operating at the correct pressure +/- 10% • The system operates without leaks • The system prevents runoff and overspray from leaving the property (checked during the audit) • Two seasonal water schedules (initial grow-in period and established landscape) are posted at the controller Response: Accept as Modified by the Committee Reason: There is a reasonable amount of effort required to achieve this credit and confidence that water savings will be achieved. Committee modification simply improved the clarity of the proposed change.
Ensuring that an irrigation system performs well via an irrigation audit has been proven to be an effective way to reduce water consumption. In their paper “Impact Evaluation of Residential Irrigation Audits on Water Conservation in Colorado”; Shimabuku, Stellar, and Mayer found an average savings of 6% outdoor water use over 2,000 residential sprinkler audits. The WaterSense program identifies certification programs for irrigation professionals that meet minimum criteria and maintains a directory of these professionals on its website. Providing an easy way to identify individuals who are actually qualified to implement an audit protocol. Meanwhile ASABE 626 provides an ANSI standard that governs how to conduct a uniformity test.
In rated homes where documentation is provided the water use associated with irrigation shall be decreased by 5% were a certified professional (as identified by a WaterSense labeled certification) in accordance with ASABE 626 verifies: • DU is at least 65% on turf areas • Sprinklers are operating at the correct pressure +/- 10% • The system operates without leaks • The system prevents runoff and overspray from leaving the property (checked during the audit) • Two seasonal water schedules (initial grow-in period and established landscape) are posted at the controller
Accept as Modified by the Committee
Reason: There is a reasonable amount of effort required to achieve this credit and confidence that water savings will be achieved. Committee modification simply improved the clarity of the proposed change.
Comment #23Amendment: WER CommentsParagraph / Figure / Table / Note: 5.2Comment Intent: Not an ObjectionComment Type: GeneralComment: More clarity and guidance is needed on 5.2 Residential Irrigation Capacity Index. From looking at the example calculator it appears that this one yes/no toggle has an inordinate impact of the resutling WERS Index of a home with an irrigation system. The definition references a percentage performance for every point from a baseline of 5 but the calcuator is just a yes/no selection with no input for a RICI should a Rater have that information. Further, it is completely unclear to me however how to qualify or verify that an irrigation system was designed with this in mind and what types of features would positively or negatively impact a RICI. Google shed little to no light on this when i tried to research RICIs either. Response: Reject Reason: Commenter does not fully understand how the calculator works. RESNET will need to develop proper education on how to use. In addition to yes/no, a flow rate is also required for RICI.
More clarity and guidance is needed on 5.2 Residential Irrigation Capacity Index. From looking at the example calculator it appears that this one yes/no toggle has an inordinate impact of the resutling WERS Index of a home with an irrigation system. The definition references a percentage performance for every point from a baseline of 5 but the calcuator is just a yes/no selection with no input for a RICI should a Rater have that information. Further, it is completely unclear to me however how to qualify or verify that an irrigation system was designed with this in mind and what types of features would positively or negatively impact a RICI. Google shed little to no light on this when i tried to research RICIs either.
Reason: Commenter does not fully understand how the calculator works. RESNET will need to develop proper education on how to use. In addition to yes/no, a flow rate is also required for RICI.
Comment #24Amendment: WER CommentsParagraph / Figure / Table / Note: overallComment Intent: Not an ObjectionComment Type: GeneralComment: As stated in RESNET's email about this development, RESNET is not yet in the ANSI process. It would be very good if RESNET would post the committee, sub committee and task force meetings that are public, either as in person attendance to a meeting or attendance by phone. This would aid RESNET in having a transparent process. For now, at the least post specificaly where this informaiton will be found when it is available. Thank you Proposed Change: Post the committee, sub committee and task force meetings that are public, either as in person attendance to a meeting or attendance by phone. Or at least state where this information will be posted when the meetings are scheduled. Response: Reject Reason: Thank you. This comment will be taken up by RESNET.
As stated in RESNET's email about this development, RESNET is not yet in the ANSI process.
It would be very good if RESNET would post the committee, sub committee and task force meetings that are public, either as in person attendance to a meeting or attendance by phone. This would aid RESNET in having a transparent process.
For now, at the least post specificaly where this informaiton will be found when it is available.
Thank you
Post the committee, sub committee and task force meetings that are public, either as in person attendance to a meeting or attendance by phone. Or at least state where this information will be posted when the meetings are scheduled.
Reason: Thank you. This comment will be taken up by RESNET.
Comment #25Amendment: WER CommentsParagraph / Figure / Table / Note: 4.7Comment Intent: ObjectionComment Type: GeneralComment: 4.7 Determining Toilet gpd in the rated home. Provision must be made for dual flush toilets in the rated home. The “average gallons per flush of all toilets installed in the rated home” should accommodate dual flush toilets at the standard 2 to 1 ratio of light to heavy flushes, incorporating the specific light and heavy flush volumes of the toilet in the rated home. Response: Accept in Principle Reason: The ratio of 2:1 will be implemented in the standard. Guidelines committee requests that the Inspection Committee consider breaking the toilet portion of the checklist into two separate lines (one for standard and one for dual flush).
4.7 Determining Toilet gpd in the rated home. Provision must be made for dual flush toilets in the rated home. The “average gallons per flush of all toilets installed in the rated home” should accommodate dual flush toilets at the standard 2 to 1 ratio of light to heavy flushes, incorporating the specific light and heavy flush volumes of the toilet in the rated home.
Reason: The ratio of 2:1 will be implemented in the standard. Guidelines committee requests that the Inspection Committee consider breaking the toilet portion of the checklist into two separate lines (one for standard and one for dual flush).
Comment #26Amendment: WER CommentsComment Intent: ObjectionComment Type: GeneralComment: Water pressure should be identified in the reference home, and provision made for recording and accounting for water pressure in the rated home. Increased water pressure increases the flow rate through any fixed orifice, whether it be a leak or an open tap. Excessive pressure may also cause water hammer, with the potential to damage plumbing and cause leaks. Data published in the AWWA M-36 Manal, 4th edition (Table 6-1) suggests average system operating pressure of 76 psi, which may be considered for the reference home. In addition to a small pressure drop through the water meter and service line, pressure can be directly attenuated in a dwelling by the addition of pressure reducing valve. The WER Index need not provide “credit” for exceptionally low pressure, as this may compromise the functionality of some appliances and systems. However, a pressure above 80 psi that goes unattenuated in the rated home should definitely be accounted for in the water consumption calculations of both indoor and outdoor uses. See the discussion in the M-36 Manual (pp. 249-251) of Greeley’s formula for relating pressure to rates of leakage. Response: Accept in Principle Reason: Ed to work with modeling committee on the details. Inspection Committee should consider a note on the checklist about excess pressure.
Water pressure should be identified in the reference home, and provision made for recording and accounting for water pressure in the rated home. Increased water pressure increases the flow rate through any fixed orifice, whether it be a leak or an open tap. Excessive pressure may also cause water hammer, with the potential to damage plumbing and cause leaks. Data published in the AWWA M-36 Manal, 4th edition (Table 6-1) suggests average system operating pressure of 76 psi, which may be considered for the reference home. In addition to a small pressure drop through the water meter and service line, pressure can be directly attenuated in a dwelling by the addition of pressure reducing valve. The WER Index need not provide “credit” for exceptionally low pressure, as this may compromise the functionality of some appliances and systems. However, a pressure above 80 psi that goes unattenuated in the rated home should definitely be accounted for in the water consumption calculations of both indoor and outdoor uses. See the discussion in the M-36 Manual (pp. 249-251) of Greeley’s formula for relating pressure to rates of leakage.
Reason: Ed to work with modeling committee on the details. Inspection Committee should consider a note on the checklist about excess pressure.
Comment #27Amendment: WER CommentsComment Intent: ObjectionComment Type: GeneralComment: 3.0 Outdoor Reference Home GPCD. In a previous comment, I raised concern over allowing rated homes with an automatic irrigation system to be compared with a reference home similarly equipped, regardless of whetherautomatic irrigation was commonly installed in new construction in that particular region. Some have brought information forward indicating that installation of automatic irrigation is more common in new homes in the East and Midwest than might have been inferred from the RECS data on total installations in 2005. While I continue to doubt the general prevalence of automatic systems in new landscapes in the humid regions of the country, the WERI task force should consider the possibility of including automatic irrigation in all reference homes, regardless of the irrigation system of the rated home, allowing new landscapes without automatic systems to receive substantial credit. While better data on irrigation installations might allow for a more nuanced characterization of reference home irrigation systems, allowing recognition in the WER Index for homes that forego automatic systems has much merit, and would be a simple adjustment to the draft proposal. Response: Accept Reason: Committee agrees that better data on irrigation installations might allow for a more nuanced characterization of reference home irrigation systems, allowing recognition in the WER Index for homes that forego automatic systems has much merit.
3.0 Outdoor Reference Home GPCD. In a previous comment, I raised concern over allowing rated homes with an automatic irrigation system to be compared with a reference home similarly equipped, regardless of whetherautomatic irrigation was commonly installed in new construction in that particular region. Some have brought information forward indicating that installation of automatic irrigation is more common in new homes in the East and Midwest than might have been inferred from the RECS data on total installations in 2005. While I continue to doubt the general prevalence of automatic systems in new landscapes in the humid regions of the country, the WERI task force should consider the possibility of including automatic irrigation in all reference homes, regardless of the irrigation system of the rated home, allowing new landscapes without automatic systems to receive substantial credit. While better data on irrigation installations might allow for a more nuanced characterization of reference home irrigation systems, allowing recognition in the WER Index for homes that forego automatic systems has much merit, and would be a simple adjustment to the draft proposal.
Reason: Committee agrees that better data on irrigation installations might allow for a more nuanced characterization of reference home irrigation systems, allowing recognition in the WER Index for homes that forego automatic systems has much merit.
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