The following comments have been submitted:
Comment #1Page Number: 14Paragraph / Figure / Table / Note: 4.6.2Comment Intent: Not an ObjectionComment Type: GeneralComment: is and Irrigation Association Certified Landscape Irrigation Auditor acceptable?
is and Irrigation Association Certified Landscape Irrigation Auditor acceptable?
Comment #2Page Number: 20Paragraph / Figure / Table / Note: 6.1.2.4Comment Intent: Not an ObjectionComment Type: GeneralComment: include a d) for conservation fees?
include a d) for conservation fees?
Comment #3Page Number: allParagraph / Figure / Table / Note: allComment Intent: ObjectionComment Type: GeneralComment: RESNET fails to meet the ANSI requirement for “openness” in consensus standards development. What is the evidence for my claim? First from RESNET and ANSI documents- RESNET says: “RESNET shall comply with all of the ANSI Essential Requirements at all times.“(1) ANSI says: “Participation shall be open to all persons who are directly and materially affected by the activity in question.” (2) ANSI says: “Timely and adequate notice of any action to create, revise, reaffirm, or withdraw a standard, and the establishment of a new consensus body shall be provided to all known directly and materially affected interests.” (2) The ANSI Executive Standards Council has clarified that “Agendas and meeting announcements … should be available to anyone”. (3) RESNET does not post either meeting announcements or agendas online. How does one participate in a meeting one does not even know about? The RESNET process is not “open” as required by ANSI. If RESNET actually posts information on meetings and agendas, then I somehow missed it. Please make that meeting and agenda information prominent on the RESNET web site. This is my second written request for the information on meetings and agendas. My first written request was in May 2017.(4) That first request was a comment on the initial draft of this water metric standard. That request is still online. RESNET’s written response to my request was “Reject”.(4) RESNET’s process would be more effective if it was more open. Contrast the RESNET process to that of ICC, RESNET’s “partner” on this standard. ICC encourages participation in the ICC code development process: - ICC posts meeting times and locations well in advance. RESNET does not. - ICC posts the incoming comments. RESNET does also. - ICC holds hearings for committee deliberations that anyone can attend. RESNET does not say how to attend their committee deliberations. - ICC posts the results and committee response and rationale for each individual proposal online. RESNET usually does not. - ICC has a well-publicized process that allows limited time for persons at the hearings to testify. RESNET does not have any such defined process. ICC’s open process accommodates a much bigger volume of comments than RESNET’s non-open process. If ICC can be “open”, then RESNET should be capable of being “open” with a much smaller volume of comments. RESNET is not obligated to follow ICC’s exact process. Other consensus developers accomplish “openness” in different ways. However, RESNET is obligated to be open as defined by ANSI. It should be noted that the openness requirements do not apply to RESNET subcommittees, working groups, analysis studies and the like. Nor do the openness requirements apply to RESNETS non-consensus standards. RESNET routinely sends written responses to individual commenters on their specific comments. As part of being open RESNET should post these written responses to each comment on the same web site where all the comments are listed. In part this is an “Appeal of RESNET Action or Inaction” as described in Section 12.3 of RESNET’s policy.(4) In accordance with RESNET policy “The progress of work on developing a standard shall continue during the appeal process.”so development on the water metric continues.(5) Obviously some items suggested here could be implemented soon to aid in the development of the water metric. In accordance with RESNET policy, I am also sending this comment to the RESNET Standards Manager.(4) References for quoted statements above: ref (1) Standards Development Policy and Procedures Manual, Residential Energy Services Network (RESNET), Version 2.1 Technical Series 1.01 August 25, 2017 Section 14, page 40. Applies to consensus standards. ref (4) Same as above. Section 12.3, Appeal of RESNET Action or Inaction ref (5)Same as above. Section 12.4, Progress of Work During an Appeal Process http://www.resnet.us/blog/wp-content/uploads/2017/10/RESNET_SDO_Procedures.pdf (2) “ANSI Essential Requirements: Due Process Requirements for American National Standards”. January 2018. Section 1.1, “Openness”, for first quote. Section 2.1,”Openness”, for second quote. https://share.ansi.org/Shared%20Documents/Standards%20Activities/American%20National%20Standards/Procedures%2C%20Guides%2C%20and%20Forms/ANSI-Essential-Requirements-2018.pdf ref (3) ANSI Executive Standards Council (ExSC). ExSC_048_2012. “ExSC Interpretation of Openness and Related Issues”. September 1999. To give context, more from Item #4, emphasis is mine: “4. … There is nothing in the current ANSI Procedures that requires developers to distribute minutes upon request. Agendas and meeting announcements, however, should be available to anyone. …” Seehttps://share.ansi.org/Shared%20Documents/Forms/AllItems.aspx?RootFolder=%2fShared%20Documents%2fStandards%20Activities%2fAmerican%20National%20Standards%2fProcedures%2c%20Guides%2c%20and%20Forms&FolderCTID=0x01200019AF95C796227A438566C464851845DB#InplviewHash5a2ba1d4-1170-422b-b0e3-55ccd1ad9232=TreeField%3DFolders-TreeValue%3DStandards%2520Activities%252FAmerican%2520National%2520Standards%252FProcedures%252C%2520Guides%252C%2520and%2520Forms-ProcessQStringToCAML%3D1-National%2520Standards%252FProcedures%252C%2520Guides%252C%2520and%2520Forms%3D-InplaceSearchQuery%3DExSC%255F048%255F2012-InplaceFullListSearch%3Dtrue-RootFolder%3D%252FShared%2520Documents%252FStandards%2520Activities%252FAmerican%2520National%2520Standards%252FProcedures%252C%2520Guides%252C%2520and%2520Forms ref (4)See https://www1.resnet.us/comments/amendments/comments.aspx?SeriesID=69 Comment #24 Proposed Change: RESNET should: - start revising the RESNET consensus standards process to meet the “openness” requirements. While the official consensus process if being revised, RESNET should: - post timely meeting announcements including meeting time and location online. - post meeting agendas online. - state what participation is allowed for attendees at RESNET meetings. At minimum attendees should be able to listen to the committee discussions/votes and respond to direct questions from the committee. If a limited participation by attendees is allowed, RESNET should describe it. - post a response to each individual comment online. - announce elements of a revised “open” process by email and by web post. - give a webinar on the interim revised “open” RESNET process. - continue the current comment period and committee work on the water metric
RESNET fails to meet the ANSI requirement for “openness” in consensus standards development.
What is the evidence for my claim? First from RESNET and ANSI documents-
RESNET says: “RESNET shall comply with all of the ANSI Essential Requirements at all times.“(1)
ANSI says: “Participation shall be open to all persons who are directly and materially affected by the activity in question.” (2)
ANSI says: “Timely and adequate notice of any action to create, revise, reaffirm, or withdraw a standard, and the establishment of a new consensus body shall be provided to all known directly and materially affected interests.” (2)
The ANSI Executive Standards Council has clarified that “Agendas and meeting announcements … should be available to anyone”. (3)
RESNET does not post either meeting announcements or agendas online. How does one participate in a meeting one does not even know about? The RESNET process is not “open” as required by ANSI.
If RESNET actually posts information on meetings and agendas, then I somehow missed it. Please make that meeting and agenda information prominent on the RESNET web site. This is my second written request for the information on meetings and agendas. My first written request was in May 2017.(4) That first request was a comment on the initial draft of this water metric standard. That request is still online. RESNET’s written response to my request was “Reject”.(4)
RESNET’s process would be more effective if it was more open.
Contrast the RESNET process to that of ICC, RESNET’s “partner” on this standard. ICC encourages participation in the ICC code development process:
- ICC posts meeting times and locations well in advance. RESNET does not.
- ICC posts the incoming comments. RESNET does also.
- ICC holds hearings for committee deliberations that anyone can attend. RESNET does not say how to attend their committee deliberations.
- ICC posts the results and committee response and rationale for each individual proposal online. RESNET usually does not.
- ICC has a well-publicized process that allows limited time for persons at the hearings to testify. RESNET does not have any such defined process.
ICC’s open process accommodates a much bigger volume of comments than RESNET’s non-open process. If ICC can be “open”, then RESNET should be capable of being “open” with a much smaller volume of comments. RESNET is not obligated to follow ICC’s exact process. Other consensus developers accomplish “openness” in different ways. However, RESNET is obligated to be open as defined by ANSI.
It should be noted that the openness requirements do not apply to RESNET subcommittees, working groups, analysis studies and the like. Nor do the openness requirements apply to RESNETS non-consensus standards.
RESNET routinely sends written responses to individual commenters on their specific comments. As part of being open RESNET should post these written responses to each comment on the same web site where all the comments are listed.
In part this is an “Appeal of RESNET Action or Inaction” as described in Section 12.3 of RESNET’s policy.(4) In accordance with RESNET policy “The progress of work on developing a standard shall continue during the appeal process.”so development on the water metric continues.(5) Obviously some items suggested here could be implemented soon to aid in the development of the water metric. In accordance with RESNET policy, I am also sending this comment to the RESNET Standards Manager.(4)
References for quoted statements above:
ref (1) Standards Development Policy and Procedures Manual, Residential Energy Services Network (RESNET), Version 2.1 Technical Series 1.01 August 25, 2017 Section 14, page 40. Applies to consensus standards.
ref (4) Same as above. Section 12.3, Appeal of RESNET Action or Inaction
ref (5)Same as above. Section 12.4, Progress of Work During an Appeal Process http://www.resnet.us/blog/wp-content/uploads/2017/10/RESNET_SDO_Procedures.pdf
(2) “ANSI Essential Requirements: Due Process Requirements for American National Standards”. January 2018. Section 1.1, “Openness”, for first quote. Section 2.1,”Openness”, for second quote.
https://share.ansi.org/Shared%20Documents/Standards%20Activities/American%20National%20Standards/Procedures%2C%20Guides%2C%20and%20Forms/ANSI-Essential-Requirements-2018.pdf
ref (3) ANSI Executive Standards Council (ExSC). ExSC_048_2012. “ExSC Interpretation of Openness and Related Issues”. September 1999.
To give context, more from Item #4, emphasis is mine:
“4. … There is nothing in the current ANSI Procedures that requires developers to distribute minutes upon request. Agendas and meeting announcements, however, should be available to anyone. …”
Seehttps://share.ansi.org/Shared%20Documents/Forms/AllItems.aspx?RootFolder=%2fShared%20Documents%2fStandards%20Activities%2fAmerican%20National%20Standards%2fProcedures%2c%20Guides%2c%20and%20Forms&FolderCTID=0x01200019AF95C796227A438566C464851845DB#InplviewHash5a2ba1d4-1170-422b-b0e3-55ccd1ad9232=TreeField%3DFolders-TreeValue%3DStandards%2520Activities%252FAmerican%2520National%2520Standards%252FProcedures%252C%2520Guides%252C%2520and%2520Forms-ProcessQStringToCAML%3D1-National%2520Standards%252FProcedures%252C%2520Guides%252C%2520and%2520Forms%3D-InplaceSearchQuery%3DExSC%255F048%255F2012-InplaceFullListSearch%3Dtrue-RootFolder%3D%252FShared%2520Documents%252FStandards%2520Activities%252FAmerican%2520National%2520Standards%252FProcedures%252C%2520Guides%252C%2520and%2520Forms
ref (4)See https://www1.resnet.us/comments/amendments/comments.aspx?SeriesID=69 Comment #24
RESNET should:
- start revising the RESNET consensus standards process to meet the “openness” requirements.
While the official consensus process if being revised, RESNET should:
- post timely meeting announcements including meeting time and location online.
- post meeting agendas online.
- state what participation is allowed for attendees at RESNET meetings. At minimum attendees should be able to listen to the committee discussions/votes and respond to direct questions from the committee. If a limited participation by attendees is allowed, RESNET should describe it.
- post a response to each individual comment online.
- announce elements of a revised “open” process by email and by web post.
- give a webinar on the interim revised “open” RESNET process.
- continue the current comment period and committee work on the water metric
Comment #4Page Number: allParagraph / Figure / Table / Note: allComment Intent: ObjectionComment Type: TechnicalComment: As noted in the draft standard’s forward, rainwater and gray water are not accounted for. Inability to account for rainwater and gray water is a serious flaw. This water rating tool will not be able to correctly rate homes that use rainwater and/or gray water to reduce the use of municipal water. The rating scale goes from 0 to 100+; however no homes will be able to get the lower (best) scores even if they used almost no municipal water. Suggest RESNET hold off releasing a water metric until rainwater and gray water calculations are in the tool. Proposed Change: Hold off releasing a water metric until rainwater and gray water calculations are in the tool.
As noted in the draft standard’s forward, rainwater and gray water are not accounted for. Inability to account for rainwater and gray water is a serious flaw. This water rating tool will not be able to correctly rate homes that use rainwater and/or gray water to reduce the use of municipal water. The rating scale goes from 0 to 100+; however no homes will be able to get the lower (best) scores even if they used almost no municipal water.
Suggest RESNET hold off releasing a water metric until rainwater and gray water calculations are in the tool.
Hold off releasing a water metric until rainwater and gray water calculations are in the tool.
Comment #5Page Number: 13, othersParagraph / Figure / Table / Note: 4.6Comment Intent: ObjectionComment Type: TechnicalComment: The outdoor water use does not reflect the water use by the specific plants used in the home’s landscaping. The rating would not change for high-water-use plants vs low-water-use plants. The rating would not reflect the organization of plants into high and low water areas of the yard, which is one way to conserve water. Proposed Change: Add consideration of the water needs of the plants in the landscape such that high-water-use plants and low-water-use plants are reflected in the rating.
The outdoor water use does not reflect the water use by the specific plants used in the home’s landscaping. The rating would not change for high-water-use plants vs low-water-use plants.
The rating would not reflect the organization of plants into high and low water areas of the yard, which is one way to conserve water.
Add consideration of the water needs of the plants in the landscape such that high-water-use plants and low-water-use plants are reflected in the rating.
Comment #6Page Number: 13, othersParagraph / Figure / Table / Note: 4.6Comment Intent: ObjectionComment Type: TechnicalComment: The outdoor water use does not reflect the water use by the specific plants used in the home’s landscaping. The rating would not change for high-water-use plants vs low-water-use plants. The rating would not reflect the organization of plants into high and low water areas of the yard, which is one way to conserve water. Proposed Change: Add consideration of the water needs of the plants in the landscape such that high-water-use plants and low-water-use plants are reflected in the rating.
Comment #7Page Number: allParagraph / Figure / Table / Note: allComment Intent: ObjectionComment Type: GeneralComment: RESNET has had several names for the water rating standard. Recently RESNET started using Water Rating Index (WRI). Suggest not using WRI as it will set up a conflict with the WRI that is likely to be coming out in National Green Building Standard, also know as ICC 700. Proposed Change: Select a different name for the standard. Do not use WRI.
RESNET has had several names for the water rating standard. Recently RESNET started using Water Rating Index (WRI). Suggest not using WRI as it will set up a conflict with the WRI that is likely to be coming out in National Green Building Standard, also know as ICC 700.
Select a different name for the standard. Do not use WRI.
Comment #8Page Number: allParagraph / Figure / Table / Note: allComment Intent: ObjectionComment Type: GeneralComment: RESNET has had several names for the water rating standard. Recently RESNET started using Water Rating Index (WRI). Suggest not using WRI as it will set up a conflict with the WRI that is likely to be coming out in National Green Building Standard, also know as ICC 700. Proposed Change: Select a different name for the standard. Do not use WRI.
Comment #9Page Number: 4Paragraph / Figure / Table / Note: forwardComment Intent: Not an ObjectionComment Type: EditorialComment: RESNET says this is based on 2006 base-case values. Exactly what about this it based on 2006? Not much. Could just as easily said it is for 2004 or 2008. For example, there are no water requirements in 2006 IECC, so how can it be based on that? Not a big deal, just odd. Proposed Change: Remove statement that standard is based on a 2006 reference case, so better support that statement.
RESNET says this is based on 2006 base-case values. Exactly what about this it based on 2006? Not much. Could just as easily said it is for 2004 or 2008. For example, there are no water requirements in 2006 IECC, so how can it be based on that?
Not a big deal, just odd.
Remove statement that standard is based on a 2006 reference case, so better support that statement.
Comment #10Page Number: 5Paragraph / Figure / Table / Note: 3.2Comment Intent: ObjectionComment Type: TechnicalComment: The standard includes a poor definition of “approved”. "Approved – shall mean approved by an entity adopting and requiring the use of this Standard as a result of investigation and tests conducted by the entity or by reason of accepted principles or tests by nationally recognized organizations." Approved is a key word in codes / standards. Do not be inconsistent. Use an IRC-type definition of approved. The IRC definition is “Acceptable to the Building Official.” Furthermore, RESNET’s definition is confusing. As the definition names a “nationally recognized organization”, so the adopting entity can not use a “locally recognized organization"? Does the “adopting entity” have to have done an “investigation”? Change the definition to "Acceptable to the adopting entity." Proposed Change: Change the definition of "Approved" to be "Acceptable to the adopting entity."
Change the definition of "Approved" to be "Acceptable to the adopting entity."
Comment #11Page Number: 16Paragraph / Figure / Table / Note: 5.1.1, 5.1.2Comment Intent: ObjectionComment Type: TechnicalComment: Sections 5.1.1 and 5.1.2 specify "dataset approved by RESNET". Is there an evapotranspiration dataset approved by RESNET? Section 5.1.1 requires such a dataset. Lacking an approved dataset, can a water rating even be generated? Proposed Change: Include or post dataset(s) approved by RESNET. Or describe/post the process by which dataset(s) will be submitted and approved.
Sections 5.1.1 and 5.1.2 specify "dataset approved by RESNET". Is there an evapotranspiration dataset approved by RESNET? Section 5.1.1 requires such a dataset. Lacking an approved dataset, can a water rating even be generated?
Include or post dataset(s) approved by RESNET. Or describe/post the process by which dataset(s) will be submitted and approved.
Comment #12Page Number: allParagraph / Figure / Table / Note: allComment Intent: ObjectionComment Type: GeneralComment: RESNET has been inconsistent with the stated comment due date. Sometimes is has been stated as Sept 1, often as Sept 17. . Proposed Change: Communicate the comment due date again. Add days for those who took Sept 1 date as due date. Suggest the new due date be 30 days from when the due date is posted/emailed again.
RESNET has been inconsistent with the stated comment due date. Sometimes is has been stated as Sept 1, often as Sept 17. .
Communicate the comment due date again. Add days for those who took Sept 1 date as due date. Suggest the new due date be 30 days from when the due date is posted/emailed again.
Comment #13Page Number: 21Paragraph / Figure / Table / Note: 6.1.4.1.3, 6.1.4.2.1 and 6.1.4.1.3Comment Intent: ObjectionComment Type: TechnicalComment: This consensus standard should not reference non-concensus RESNET standards and thereby make the non-concenss standard a requirement. The non-consensus standard referenced is "Section 600 of the Mortgage Industry National Home Energy Rating Systems” and "Section 900 of the Mortgage Industry National Home Energy Rating Systems”. This non-consenss standard is referenced in Sections 6.1.4.1.3, 6.1.4.2.1 and 6.1.4.1.3. If the non-consensus standard is included, that portion of the non-consensus standard should be subjected to a consensus style pubic review based on the RESNET/ANSI rules. Proposed Change: Remove the reference to the non-consensus standard or subject it to an RESNET/ANSI review,.
This consensus standard should not reference non-concensus RESNET standards and thereby make the non-concenss standard a requirement. The non-consensus standard referenced is "Section 600 of the Mortgage Industry National Home Energy Rating Systems” and "Section 900 of the Mortgage Industry National Home Energy Rating Systems”. This non-consenss standard is referenced in Sections 6.1.4.1.3, 6.1.4.2.1 and 6.1.4.1.3. If the non-consensus standard is included, that portion of the non-consensus standard should be subjected to a consensus style pubic review based on the RESNET/ANSI rules.
Remove the reference to the non-consensus standard or subject it to an RESNET/ANSI review,.
Comment #14Page Number: 6Paragraph / Figure / Table / Note: 3.2Comment Intent: ObjectionComment Type: TechnicalComment: The standard includes a poor definition of “shall”. “shall” is defined as: "Shall - As used in this Standard, the word ‘shall’ means that the action specified is mandatory and must be accomplished by the responsible party." What does “accomplished by the responsible party” mean? If the wrong party does it, the requirement is not meet? Strike “and must be accomplished by the responsible party” revise definition to be: "Shall - Means that the action specified is mandatory.” Proposed Change: Shall - As used in this Standard, the word ‘shall’ means that the action specified is mandatory and must be accomplished by the responsible party.
"Shall - Means that the action specified is mandatory.”
Shall - As used in this Standard, the word ‘shall’ means that the action specified is mandatory and must be accomplished by the responsible party.
Comment #15Page Number: 0, 5Paragraph / Figure / Table / Note: Title page, 1, 2Comment Intent: ObjectionComment Type: GeneralComment: With or without townhomes? The scope includes townhomes. "Scope. This standard is applicable to the indoor and outdoor water use of all single-family dwellings, including townhomes and duplexes.” (with townhomes) The purpose does not include townhomes. "Purpose. The provisions of this document establish a uniform methodology for evaluating, rating and labeling the water use performance of single family and duplex dwelling unit."(without townhomes) The standard title and forward both say “One- and Two-Family Dwellings“ (without townhomes) Proposed Change: Whichever way the standard goes, with or without townhomes, these should be made consistent.
With or without townhomes?
Whichever way the standard goes, with or without townhomes, these should be made consistent.
Comment #16Page Number: 0, 5Paragraph / Figure / Table / Note: Title page, 1, 2Comment Intent: ObjectionComment Type: GeneralComment: With or without townhomes? The scope includes townhomes. "Scope. This standard is applicable to the indoor and outdoor water use of all single-family dwellings, including townhomes and duplexes.” (with townhomes) The purpose does not include townhomes. "Purpose. The provisions of this document establish a uniform methodology for evaluating, rating and labeling the water use performance of single family and duplex dwelling unit."(without townhomes) The standard title and forward both say “One- and Two-Family Dwellings“ (without townhomes) Proposed Change: Whichever way the standard goes, with or without townhomes, these should be made consistent.
Comment #17Page Number: 0, 5Paragraph / Figure / Table / Note: Title page, 1, 2Comment Intent: ObjectionComment Type: GeneralComment: With or without townhomes? The scope includes townhomes. "Scope. This standard is applicable to the indoor and outdoor water use of all single-family dwellings, including townhomes and duplexes.” (with townhomes) The purpose does not include townhomes. "Purpose. The provisions of this document establish a uniform methodology for evaluating, rating and labeling the water use performance of single family and duplex dwelling unit."(without townhomes) The standard title and forward both say “One- and Two-Family Dwellings“ (without townhomes) Proposed Change: Whichever way the standard goes, with or without townhomes, these should be made consistent.
Comment #18Page Number: 14Paragraph / Figure / Table / Note: 4.6.1Comment Intent: ObjectionComment Type: TechnicalComment: If irrigation controllers must meet specific EPA criteria, then name the EPA specification. "Smart controller" is not a defined term; but is used several times in the draft standard. Does RESNET mean the EPA "WaterSense® Specification for Weather-Based Irrigation Controllers"? Proposed Change: Clarify "smart controller".
If irrigation controllers must meet specific EPA criteria, then name the EPA specification. "Smart controller" is not a defined term; but is used several times in the draft standard. Does RESNET mean the EPA "WaterSense® Specification for Weather-Based Irrigation Controllers"?
Clarify "smart controller".
Comment #19Page Number: 8, 13Paragraph / Figure / Table / Note: 4.4, 4.6Comment Intent: ObjectionComment Type: GeneralComment: Some of the fitted equations in the standard are hard to understand. Anyone who wants to propose amendments to these equations will find it very difficult. RESNET should use another form of equation, otherwise future commenters are limited to those that understand how to fit equations to large data sets. Are the data sets RESNET uses to make the equations documented and available? The process is not open if others can’t do it. Examples of overly compliex fitted equations are those for the Reference Home Outdoor Annual Water Use, Equations 4.4-1a and 4.4-1b. Also Rated Home equations 4.6-1. 4.6-2 and 4.6-3. Proposed Change: Use a different form for the complicated equations, something that many others can also produce.
Use a different form for the complicated equations, something that many others can also produce.
Comment #20Page Number: severalParagraph / Figure / Table / Note: severalComment Intent: Not an ObjectionComment Type: EditorialComment: Sorry about the duplicate comments. Not sure how I did that. Proposed Change: I don't know how to remove duplicate comments.
I don't know how to remove duplicate comments.
Comment #21Page Number: 12Paragraph / Figure / Table / Note: 4.5.6Comment Intent: ObjectionComment Type: TechnicalComment: Comment: The Energy Factor of a dishwasher does not determine its total water usage. The energy factor metric unit for dishwashers is cycles per kWh, not water usage per kWh. The current federal standards for dishwashers are as follows: i) Standard size dishwashers shall not exceed 307 kwh/year and 5.0 gallons per cycle. (ii) Compact size dishwashers shall not exceed 222 kwh/year and 3.5 gallons per cycle. By changing the EF to gallons per cycle, you would get a better estimate of water usage in the rated home, and it would account for the water use compact dishwashers where used. It is also more consistent with the reference home equation, which does not use any sort of energy factor (but only a default 8.16 gallons of water per cycle). Proposed Change: Equation 4.5-7: ....(4.6415*(1 / DW_EF DW_GC)... DW_EF= The energy factor of the dishwasher installed in the Rated Home DW_GC = The gallons per cycle of the dishwasher installed in the Rated home.
Comment:
The Energy Factor of a dishwasher does not determine its total water usage. The energy factor metric unit for dishwashers is cycles per kWh, not water usage per kWh. The current federal standards for dishwashers are as follows:
i) Standard size dishwashers shall not exceed 307 kwh/year and 5.0 gallons per cycle.
(ii) Compact size dishwashers shall not exceed 222 kwh/year and 3.5 gallons per cycle.
By changing the EF to gallons per cycle, you would get a better estimate of water usage in the rated home, and it would account for the water use compact dishwashers where used.
It is also more consistent with the reference home equation, which does not use any sort of energy factor (but only a default 8.16 gallons of water per cycle).
Equation 4.5-7: ....(4.6415*(1 / DW_EF DW_GC)...
DW_EF= The energy factor of the dishwasher installed in the Rated Home
DW_GC = The gallons per cycle of the dishwasher installed in the Rated home.
Comment #22Page Number: 12Paragraph / Figure / Table / Note: 4.5.7Comment Intent: ObjectionComment Type: TechnicalComment: For the rated home, the standard should account for dual-flush toilets that use less than 1.0 or 0.5 gallons per liquid flush. A weighted average could be 4 liquid flushes for every 1 (or 1.05) solid flushes. According to the following 2013 report: http://www.energy.ca.gov/appliances/2013rulemaking/documents/proposals/12-AAER-2C_Water_Appliances/California_IOUs__and__Natural_Resources_defense_Councils_Responses_to_the_Invitation_for_Standards_Proposals_for_Toilets__and__Urinals_2013-07-29_TN-71765.pdf "Most dual flush toilets use 1.6 gpf for the full-volume flush and between 0.8 and 1.1 gpf for the reduced-volume flush. However, there are several models such as those offered by Caroma that use 1.28 gpf and 0.8 gpf, respectively. The effective flush volume of dual- flush toilets varies based on usage patterns (i.e., how often the toilet is flushed at the full and reduced volumes). Dual -flush toilets achieve an effective flush volume that is lower than the current federal maximum flush volume of 1.6 gpf." Proposed Change: gpf= the average gallons per flush of all toilets installed in the Rated Home. For dual-flush toilets, use the weighted average gallons per flush based on manufacturer or EPA Water Sense guidelines.
For the rated home, the standard should account for dual-flush toilets that use less than 1.0 or 0.5 gallons per liquid flush. A weighted average could be 4 liquid flushes for every 1 (or 1.05) solid flushes.
According to the following 2013 report:
http://www.energy.ca.gov/appliances/2013rulemaking/documents/proposals/12-AAER-2C_Water_Appliances/California_IOUs__and__Natural_Resources_defense_Councils_Responses_to_the_Invitation_for_Standards_Proposals_for_Toilets__and__Urinals_2013-07-29_TN-71765.pdf
gpf= the average gallons per flush of all toilets installed in the Rated Home. For dual-flush toilets, use the weighted average gallons per flush based on manufacturer or EPA Water Sense guidelines.
Comment #23Page Number: 15Paragraph / Figure / Table / Note: Table 5Comment Intent: Not an ObjectionComment Type: EditorialComment: In Table 5, item 5 (clothes washers), the text in the second column is missing the word "Home" at the end before the period. Proposed Change: Washer capacity (cubic feet) from manufacturer’s data or the CEC Appliance Efficiency Database or the EPA ENERGY STAR website for all clothes washers located within the Rated Home.
In Table 5, item 5 (clothes washers), the text in the second column is missing the word "Home" at the end before the period.
Washer capacity (cubic feet) from manufacturer’s data or the CEC Appliance Efficiency Database or the EPA ENERGY STAR website for all clothes washers located within the Rated Home.
Comment #24Page Number: pp. 8-10; pp. 13-16Paragraph / Figure / Table / Note: 4.4 and 4.6Comment Intent: Not an ObjectionComment Type: TechnicalComment: Section 4.2 presents the Water Rating Index as a relationship between the daily water use of the Rated Home and the daily water use of the Reference Home. However, while Sections 4.3 and 4.5 lay out the steps for determining the daily indoor water use of the Reference and Rated Homes, respectively, Sections 4.4 and 4.6 prescribe calculations for determining annual outdoor water use. The missing step is the conversion of annual outdoor water use to daily outdoor use. This may be as simple as dividing the the results from sections 4.4 and 4.6 by 365. Alternatively, Sec. 4.2 could be revised for WRI to be based on the comparison of the annual water use of the Reference and Rated Homes, in whiich case the results of Sections 4.3 and 4.5 would be multiplied by 365. The committee should consider whether one approach is preferred over the other, but either way, the now implicit conversion needs to be made explicit in the text of the standard. Language to convert annual outdoor water use to daily outdoor water use is presented here. Proposed Change: 4.4.Determining the Reference Home Outdoor Annual Water Use (in thousands of gallons per year). The reference home outdoor annual water use (in thousands of gallons per year) shall be calculated using the following two equations: * * * * * * * 4.4.2. Determining Outdoor Daily Water Use for the Reference Home. Reference Home daily outdoor water use shall be determined by multiplying the result of either Eq 4.4-1a or Eq 4.4-1b, as appropriate, by 1,000 and dividing the product by 365. * * * * * * * 4.6.5. Determing Outdoor Daily Water Use for the Rated Home. Rated Home daily outdoor water use shall be determined by multiplying the result of either Eq 4.6-1 or Eq 4.6-2, as appropriate, as such result may be further modified pursuant to Sections 4.6.1 through 4.6.4, by 1,000 and dividing the product by 365.
Section 4.2 presents the Water Rating Index as a relationship between the daily water use of the Rated Home and the daily water use of the Reference Home. However, while Sections 4.3 and 4.5 lay out the steps for determining the daily indoor water use of the Reference and Rated Homes, respectively, Sections 4.4 and 4.6 prescribe calculations for determining annual outdoor water use. The missing step is the conversion of annual outdoor water use to daily outdoor use. This may be as simple as dividing the the results from sections 4.4 and 4.6 by 365.
Alternatively, Sec. 4.2 could be revised for WRI to be based on the comparison of the annual water use of the Reference and Rated Homes, in whiich case the results of Sections 4.3 and 4.5 would be multiplied by 365. The committee should consider whether one approach is preferred over the other, but either way, the now implicit conversion needs to be made explicit in the text of the standard.
Language to convert annual outdoor water use to daily outdoor water use is presented here.
4.4.Determining the Reference Home Outdoor Annual Water Use (in thousands of gallons per year). The reference home outdoor annual water use (in thousands of gallons per year) shall be calculated using the following two equations:
* * * * * * *
4.4.2. Determining Outdoor Daily Water Use for the Reference Home. Reference Home daily outdoor water use shall be determined by multiplying the result of either Eq 4.4-1a or Eq 4.4-1b, as appropriate, by 1,000 and dividing the product by 365.
4.6.5. Determing Outdoor Daily Water Use for the Rated Home. Rated Home daily outdoor water use shall be determined by multiplying the result of either Eq 4.6-1 or Eq 4.6-2, as appropriate, as such result may be further modified pursuant to Sections 4.6.1 through 4.6.4, by 1,000 and dividing the product by 365.
Comment #25Page Number: 22Paragraph / Figure / Table / Note: 7Comment Intent: Not an ObjectionComment Type: EditorialComment: As proposed, the References section includes a single reference. This section should have a more complete listing of refences in the text, and those required to be used (or listed as options for use in a mandatory requirement) should be listed as "Normative" References. Section 4.6.1, 4.6.2, 5.1.1, 5.1.2, 6.1.4.1.3, 6.1.4.2.1, 6.1.4.2.3, and Table 5 all contain refences to publications or data sets that should be properly cited in Section 7. The source and location of some of this material is not apparent from the text.
As proposed, the References section includes a single reference. This section should have a more complete listing of refences in the text, and those required to be used (or listed as options for use in a mandatory requirement) should be listed as "Normative" References. Section 4.6.1, 4.6.2, 5.1.1, 5.1.2, 6.1.4.1.3, 6.1.4.2.1, 6.1.4.2.3, and Table 5 all contain refences to publications or data sets that should be properly cited in Section 7. The source and location of some of this material is not apparent from the text.
Comment #26Page Number: p. 5; pp. 21-22Paragraph / Figure / Table / Note: 3.2 and 6.2Comment Intent: Not an ObjectionComment Type: EditorialComment: The reference to an "Approved IDR authority" in Section 6.2 is ambiguous. While "approved" is a defined term in the Definitions section, some description of the responsibilities and/or qualifications of the entity providing this function would be useful, as was provided in the definition of Approved Rating Provider in Section 3.2. Perhaps an Approved IDR authority and an Approved Rating Provider are one in the same. Clarification of this point should be informed by RESNET's experience to date with IDR usage in the implementation of HERS energy ratings.
The reference to an "Approved IDR authority" in Section 6.2 is ambiguous. While "approved" is a defined term in the Definitions section, some description of the responsibilities and/or qualifications of the entity providing this function would be useful, as was provided in the definition of Approved Rating Provider in Section 3.2. Perhaps an Approved IDR authority and an Approved Rating Provider are one in the same. Clarification of this point should be informed by RESNET's experience to date with IDR usage in the implementation of HERS energy ratings.
Comment #27Page Number: 1Paragraph / Figure / Table / Note: BSR/RESNET/ICC Standard 1101Comment Intent: ObjectionComment Type: TechnicalComment: In Colorado I know of at least two jurisdictions that have their own Water Effeiciency Plan. One of the programs was presented with the RESENT WRI and rejected it. Their professional life does not revolve around the RESNET standard development process; however, these individuals and municipalities are exactly who this system is trying to attract and who will be the largest obstacle to acceptance from builders or others who what to promote its use. Did RESNET reach out to these individuals around the country to get feed back from professional in the arena regarding the technical and practical use of the program? In this case this objection is based on not being able to adequately assess the equations and other data that is the basis of the standard. Although this has been open to public comment it also needed to include some public out reach to get comments from professionals who are dealing with water efficiency in their communities directly. RESNET Raters and WaterSense Raters are not qualified to asses these standards beyond the implementation portions. I worry that all this work as been done and the WRI will still not be accepted as it does not meet the needs of water districts/jurisdictions. Proposed Change: As this is a bran new system/program it would make sense to open a separate public comment period that is specifically designed to get feedback from professionals that run water conservation programs in water jurisdictions and or districts around the country. I know of one that had specific feed back that could impact the overall acceptance of the WRI. The WaterSense program administrators and WaterSense and Energy Raters could be a resource for finding these professional and for seeking their feedback.
In Colorado I know of at least two jurisdictions that have their own Water Effeiciency Plan. One of the programs was presented with the RESENT WRI and rejected it. Their professional life does not revolve around the RESNET standard development process; however, these individuals and municipalities are exactly who this system is trying to attract and who will be the largest obstacle to acceptance from builders or others who what to promote its use. Did RESNET reach out to these individuals around the country to get feed back from professional in the arena regarding the technical and practical use of the program?
In this case this objection is based on not being able to adequately assess the equations and other data that is the basis of the standard. Although this has been open to public comment it also needed to include some public out reach to get comments from professionals who are dealing with water efficiency in their communities directly. RESNET Raters and WaterSense Raters are not qualified to asses these standards beyond the implementation portions. I worry that all this work as been done and the WRI will still not be accepted as it does not meet the needs of water districts/jurisdictions.
As this is a bran new system/program it would make sense to open a separate public comment period that is specifically designed to get feedback from professionals that run water conservation programs in water jurisdictions and or districts around the country. I know of one that had specific feed back that could impact the overall acceptance of the WRI. The WaterSense program administrators and WaterSense and Energy Raters could be a resource for finding these professional and for seeking their feedback.
Comment #28Page Number: 16Paragraph / Figure / Table / Note: Section 5 Minimum Rated FeaturesComment Intent: ObjectionComment Type: TechnicalComment: Hot water distribution and recirculation has been included in the minimum rated features yet it has not been mentioned in any other portion of the standard. How is it being quantified and calculated. No equations have been shown that include this feature. In ANSI 301 the inclusion of hot water circulation systems has been a shame. The data that derived the impact on the HERS Index was primarily based on data from one house and thought experiments and extrapolations from that data. We are simply not able to correctly modeled many of the available systems in the market. These systems have a significant impact on the water usage in a home yet we do not have proper data to model their impact correctly. Proposed Change: Reach out to industry, national laboratories, or others to get the data that is needed to properly assess the impact of hot water recirculation systems on the energy and water efficiency of our homes so that they can be properly modeled using the WRI and the HERS/Energy Rating Index
Hot water distribution and recirculation has been included in the minimum rated features yet it has not been mentioned in any other portion of the standard. How is it being quantified and calculated. No equations have been shown that include this feature. In ANSI 301 the inclusion of hot water circulation systems has been a shame. The data that derived the impact on the HERS Index was primarily based on data from one house and thought experiments and extrapolations from that data. We are simply not able to correctly modeled many of the available systems in the market. These systems have a significant impact on the water usage in a home yet we do not have proper data to model their impact correctly.
Reach out to industry, national laboratories, or others to get the data that is needed to properly assess the impact of hot water recirculation systems on the energy and water efficiency of our homes so that they can be properly modeled using the WRI and the HERS/Energy Rating Index
Comment #29Page Number: allComment Intent: ObjectionComment Type: GeneralComment: RESNET has not met the RESNET/ANSI requirements for the minimum public comment period on the proposed water metric. RESNET selected the 45 day comment period as was noted in the email notice concerning the Preliminary Draft Standard and online. However the required criteria for the 45 day comment period was not met. According to RESNET’s own policy, the only remaining choice for comment period is 60 days. RESNET's requirement for a 45 day comment period is: --"The Preliminary Draft Standard shall be posted for public comments for a period as prescribed below. … The public comment period shall be: … a minimum of forty-five (45) days if the document is available in an electronic format from the SDO [Standard Development Organization] within one (1) day and the URL or email address is published in Standards Action”; --"RESNET shall send an announcement on the public comment on draft standards to its Constant Contacts list of registered interested parties and shall post an announcement on its website.” The quoted text is from "Standards Development Policy and Procedures Manual, Residential Energy Services Network (RESNET)", Version 2.1. Section 10.8.5 "ANSI Public Comment Process" The required email announcement was sent out on August 9th and stated an end date of September 17th. This is a 39-day period. The URL for the Preliminary Draft Standard is http://www.resnet/us/blog/resnet-consensus-standards/ as was named in the August 3rd Standards Action https://share.ansi.org/Shared%20Documents/Standards%20Action/2018-PDFs/SAV4931.pdf The 45 days was calculated as August 3 to September 17th. However, RESNET has agreed that the Preliminary Draft Standard was missing from the URL named in Standards Action for a part of the 45-days. I don’t know the number of days the Preliminary Draft Standard was actually posted; however, the Preliminary Draft Standard was posted for less than the 45 day period from August 3rd to September 17th. The only remaining choice of comment period in the RESNET/ANSI procedure is " a minimum of sixty (60) days… ”. This would be an additional 15 days. Potential commenters should get notice of the extended comment period. The clock on the additional comment time should not start until the notice goes out to potential commenters. Notice should include both mechanisms named in RESNET’s policy, RESNET’s "list of registered interested parities" and announcement in ANSI’s "Standards Action”. The 15 days should not start until both notices have gone out. Dates related to the Standards Action publications are at https://share.ansi.org/Shared%20Documents/Standards%20Action/2018-PDFs/SA-Pub-Schedule-2018-Vol-No-49.pdf. According to this items submitted by 5 PM ET on 9/17/2018 would be published in Standards Action September 28th. 15 days would make the new deadline for comments October 13th. This is a procedural comment, not a content comment. In part this is an “Appeal of RESNET Action or Inaction” as described in Section 12.3 of RESNET’s policy. In accordance with that RESNET policy, I am also sending this comment to the RESNET Standards Manager. Proposed Change: The water metric comment period should be extend to 60 days with notice to potential commenters. The clock on the additional 15 days should start after the notice goes out to potential commenters; including notice of a revised comment period by both an announcement in ANSI’s "Standards Action” and by email to RESNET’s "list of registered interested parities".
RESNET has not met the RESNET/ANSI requirements for the minimum public comment period on the proposed water metric. RESNET selected the 45 day comment period as was noted in the email notice concerning the Preliminary Draft Standard and online. However the required criteria for the 45 day comment period was not met. According to RESNET’s own policy, the only remaining choice for comment period is 60 days.
The water metric comment period should be extend to 60 days with notice to potential commenters. The clock on the additional 15 days should start after the notice goes out to potential commenters; including notice of a revised comment period by both an announcement in ANSI’s "Standards Action” and by email to RESNET’s "list of registered interested parities".
Comment #30Page Number: 6 & 7Paragraph / Figure / Table / Note: 4.3Comment Intent: ObjectionComment Type: TechnicalComment: The most recent Residential End Use of Water Study (REUWS 2016) revealed there is no faucet use reduction for homes that do not include an automatic dishwasher (DW). It is commonly believed that dishwashers use less water than handwashing. There is no study of equal or greater scientific validity to refute these findings of REUWS 2016. Currently, the draft Standard does not give proper water savings credit for homes that do not install a DW. Removing the DW use in the reference home correctly gives credit to the homes without a DW. To quote REUWS 2016: “… found use of a dishwasher did not result in less faucet use, which normally would be supposed. The 520 households in REU2016 that used dishwashers had an average faucet use of 26.3 gphd and the 241 homes that did not use dishwashers used an average of 26.4 gphd for faucets. These two values are not statistically different, which suggests that in this group, the use of dishwashers was not associated with less faucet use." A DW has thus been proven to increase water use in the home. Even if the DW used only 1 gallon per week, that would be 1 gallon greater compared to a similar home without a dishwasher. While it is true that a DW should theoretically use less water than hand washing the dishes, user behavior and other factors cause the faucet use to not decrease in any measureable means. It is hypothesized that users are pre-washing or rinsing the dishes before placing them in the DW. In addition, it is hypothesized that some users are still filling a sink with soapy water to: wash wood handled implements, large vessels and sharp knives; scour pans; wipe clean counters, stove tops, and tables. All we know for certain is that the data show that a home with a DW does not decrease its water use at faucets as many presume. Proposed Change: 4.3. Determining the Daily Indoor Water Use for the Reference Home. The indoor daily water use for the Reference Home shall be calculated as follows: (Eq 4.3-1) ????????????????=??????????????+??????????????+????????????????+????????????????+??????????????+?????????????????? +??????????h???? Where: CANDIDATE--BSR/RESNET/ICC Standard 1101-- Water Rating Index PDS-01.2 refFgpd = daily fixture water use for the Reference Home refWgpd = daily water use wasted from hot water outlets for the Reference Home refDWgpd = daily dishwasher water use for the Reference Home refCWgpd = daily clothes washer water use for the Reference Home refTgpd = daily toilet water use for the Reference Home refSofgpd = daily water softener water use for the Reference Home refOther = daily total other/unidentified water use for the Reference Home
The most recent Residential End Use of Water Study (REUWS 2016) revealed there is no faucet use reduction for homes that do not include an automatic dishwasher (DW). It is commonly believed that dishwashers use less water than handwashing. There is no study of equal or greater scientific validity to refute these findings of REUWS 2016. Currently, the draft Standard does not give proper water savings credit for homes that do not install a DW. Removing the DW use in the reference home correctly gives credit to the homes without a DW.
To quote REUWS 2016:
“… found use of a dishwasher did not result in less faucet use, which normally would be supposed. The 520 households in REU2016 that used dishwashers had an average faucet use of 26.3 gphd and the 241 homes that did not use dishwashers used an average of 26.4 gphd for faucets. These two values are not statistically different, which suggests that in this group, the use of dishwashers was not associated with less faucet use."
A DW has thus been proven to increase water use in the home. Even if the DW used only 1 gallon per week, that would be 1 gallon greater compared to a similar home without a dishwasher. While it is true that a DW should theoretically use less water than hand washing the dishes, user behavior and other factors cause the faucet use to not decrease in any measureable means. It is hypothesized that users are pre-washing or rinsing the dishes before placing them in the DW. In addition, it is hypothesized that some users are still filling a sink with soapy water to: wash wood handled implements, large vessels and sharp knives; scour pans; wipe clean counters, stove tops, and tables. All we know for certain is that the data show that a home with a DW does not decrease its water use at faucets as many presume.
4.3. Determining the Daily Indoor Water Use for the Reference Home. The indoor daily water use for the Reference Home shall be calculated as follows:
(Eq 4.3-1) ????????????????=??????????????+??????????????+????????????????+????????????????+??????????????+?????????????????? +??????????h????
Where: CANDIDATE--BSR/RESNET/ICC Standard 1101-- Water Rating Index PDS-01.2
refFgpd = daily fixture water use for the Reference Home
refWgpd = daily water use wasted from hot water outlets for the Reference Home
refDWgpd = daily dishwasher water use for the Reference Home
refCWgpd = daily clothes washer water use for the Reference Home
refTgpd = daily toilet water use for the Reference Home
refSofgpd = daily water softener water use for the Reference Home
refOther = daily total other/unidentified water use for the Reference Home
Comment #31Page Number: 7Paragraph / Figure / Table / Note: 4.3.3Comment Intent: ObjectionComment Type: TechnicalComment: The most recent Residential End Use of Water Study (REUWS 2016) revealed there is no faucet use reduction for homes that do not include an automatic dishwasher (DW). It is commonly believed that dishwashers use less water than handwashing. There is no study of equal or greater scientific validity to refute these findings of REUWS 2016. Currently, the draft Standard does not give proper water savings credit for homes that do not install a DW. Removing the DW use in the reference home correctly gives credit to the home without a DW. To quote REUWS 2016: “… found use of a dishwasher did not result in less faucet use, which normally would be supposed. The 520 households in REU2016 that used dishwashers had an average faucet use of 26.3 gphd and the 241 homes that did not use dishwashers used an average of 26.4 gphd for faucets. These two values are not statistically different, which suggests that in this group, the use of dishwashers was not associated with less faucet use." A DW has thus been proven to increase water use in the home. Even if the DW used only 1 gallon per week, that would be 1 gallon greater compared to a similar home without a dishwasher. While it is true that a DW should theoretically use less water than hand washing the dishes, user behavior and other factors cause the faucet use to not decrease in any measureable means. It is hypothesized that users are pre-washing or rinsing the dishes before placing them in the DW. In addition, it is hypothesized that some users are still filling a sink with soapy water to: wash wood handled implements, large vessels and sharp knives; scour pans; wipe clean counters, stove tops, and tables. All we know for certain is that the data show that a home with a DW does not decrease its water use at faucets as many presume. Proposed Change: 4.3.3. Determining Daily Reference Home Dish Washer Water Use. Reference Home dish washer use shall not presume to have an automatic dish washer and shall not include any dish washer water use. shall be calculated as follows: refDWgpd=(88.4+34.9 ?? ??????)∗8.16365 (Eq 4.3-4) Which simplifies to: refDWgpd = 1.97 + 0.7802 * Nbr Where: Nbr= number of bedrooms This value is determined in accordance with ANSI/RESNET/ICC 301Addendum A.
The most recent Residential End Use of Water Study (REUWS 2016) revealed there is no faucet use reduction for homes that do not include an automatic dishwasher (DW). It is commonly believed that dishwashers use less water than handwashing. There is no study of equal or greater scientific validity to refute these findings of REUWS 2016. Currently, the draft Standard does not give proper water savings credit for homes that do not install a DW. Removing the DW use in the reference home correctly gives credit to the home without a DW.
4.3.3. Determining Daily Reference Home Dish Washer Water Use. Reference Home dish washer use shall not presume to have an automatic dish washer and shall not include any dish washer water use. shall be calculated as follows:
refDWgpd=(88.4+34.9 ?? ??????)∗8.16365 (Eq 4.3-4)
Which simplifies to:
refDWgpd = 1.97 + 0.7802 * Nbr
Where:
Nbr= number of bedrooms
This value is determined in accordance with ANSI/RESNET/ICC 301Addendum A.
Comment #32Page Number: 9Paragraph / Figure / Table / Note: 4.3.6Comment Intent: ObjectionComment Type: TechnicalComment: There is no need to soften water with hardness less than 200 milligrams per liter, despite the sales pitches of softener industry. Unnecessary softeners not only waste water, but they also put salt into the wastewater stream hampering reclaimed water efforts. In addition, there are only problems on the hot water side (pipes and fittings) where water hardness is below 500 milligrams/liter. This proposed change will encourage softeners, where installed, to send the softened water only to the water heater. Most all needs for soft water are when using hot water. This proposal eliminates the waste of salt and discharge water (during recharge cycles) by greatly reducing the demand for softened water. In addition, the current draft standard assumes that softened water only goes to indoor fittings: I propose a language change to include outdoor use where applicable. I have witnessed many homes that installed the softener at the main water supply line; thus, sending softened water to outdoor fittings. Proposed Change: 4.3.6.1. Determining Daily Reference Home Water Softener Use. Where the Rated Home has a water softener and the water hardness at the Rated Home location is greater than or equal to 180 200 milligrams/liter and less than 500 milligrams/liter, the Reference Home water softener daily water use shall be calculated as follows: refSofgpd = ???????????? ???? h?????????????? ???????????? ???? ?????????? ∗ ?????? ???? ???????????? softened ?????????? ???????? ???? ??h?? ?????????????????? ???????? ∗ 5 ?????????????? ???????? 1,000 ???????????? ?????????????? ----------------------------------------------------------------------------------------------------------(Eq 4.3-7) Where Rated Home does not meet these conditions of 4.3.6.1 and conditions of 4.3.6.2 the refSofgpd = 0. 4.3.6.2. Determining Daily Reference Home Water Softener Use. Where the Rated Home has a water softener and the water hardness at the Rated Home location is greater than or equal to 500 milligrams/liter, the Reference Home water softener daily water use shall be calculated as follows: refSofgpd = ???????????? ???? h?????????????? ???????????? ???? ?????????? ∗ ?????? ???? softened ?????????? ???????? ???? ??h?? ?????????????????? ???????? ∗ 5 ?????????????? ???????? 1,000 ???????????? ?????????????? ---------------------------------------------------------------------------------------------------------(Eq 4.3-7) 4.3.6.3. Determining Daily Reference Home Water Softener Use, Where Rated Home does not meet the conditions of 4.3.6.1 and conditions of 4.3.6.2 the refSofgpd = 0.
There is no need to soften water with hardness less than 200 milligrams per liter, despite the sales pitches of softener industry. Unnecessary softeners not only waste water, but they also put salt into the wastewater stream hampering reclaimed water efforts. In addition, there are only problems on the hot water side (pipes and fittings) where water hardness is below 500 milligrams/liter.
This proposed change will encourage softeners, where installed, to send the softened water only to the water heater. Most all needs for soft water are when using hot water. This proposal eliminates the waste of salt and discharge water (during recharge cycles) by greatly reducing the demand for softened water.
In addition, the current draft standard assumes that softened water only goes to indoor fittings: I propose a language change to include outdoor use where applicable. I have witnessed many homes that installed the softener at the main water supply line; thus, sending softened water to outdoor fittings.
4.3.6.1. Determining Daily Reference Home Water Softener Use. Where the Rated Home has a water softener and the water hardness at the Rated Home location is greater than or equal to 180 200 milligrams/liter and less than 500 milligrams/liter, the Reference Home water softener daily water use shall be calculated as follows:
refSofgpd = ???????????? ???? h??????????????
???????????? ???? ?????????? ∗ ?????? ???? ???????????? softened ?????????? ???????? ???? ??h?? ?????????????????? ????????
∗ 5 ?????????????? ????????
1,000 ???????????? ??????????????
----------------------------------------------------------------------------------------------------------(Eq 4.3-7)
Where Rated Home does not meet these conditions of 4.3.6.1 and conditions of 4.3.6.2 the refSofgpd = 0.
4.3.6.2. Determining Daily Reference Home Water Softener Use. Where the Rated Home has a water softener and the water hardness at the Rated Home location is greater than or equal to 500 milligrams/liter, the Reference Home water softener daily water use shall be calculated as follows:
???????????? ???? ?????????? ∗ ?????? ???? softened ?????????? ???????? ???? ??h?? ?????????????????? ????????
---------------------------------------------------------------------------------------------------------(Eq 4.3-7)
4.3.6.3. Determining Daily Reference Home Water Softener Use, Where Rated Home does not meet the conditions of 4.3.6.1 and conditions of 4.3.6.2 the refSofgpd = 0.
Comment #33Page Number: 6,7,8,9 etcParagraph / Figure / Table / Note: 4.xComment Intent: ObjectionComment Type: GeneralComment: This website is converting my text of algorithms for the proposed text cahnges into a series of question marks ???????? This problem will not allow the review committee to see my proposed changes.
This website is converting my text of algorithms for the proposed text cahnges into a series of question marks ????????
This problem will not allow the review committee to see my proposed changes.
Comment #34Page Number: 12Paragraph / Figure / Table / Note: 4.5.6Comment Intent: ObjectionComment Type: TechnicalComment: ResNet is not transparent in its debelopment of this draft standard. The draft standard uses constants in the algorithms without providing details of the source of the constants. It is not possible to adequately review the integrity of these algorithms unless the details are provided. In addition, the example spreadsheet provided by ResNet does NOT use the manufacturer data to determine capacity size. The spreadsheet makes assumptions based on the appearance of an Energy Star label. Many dishwasher models not labeled as Energy Star use the same or less water as Energy Star models. This has been corroborated by the REUWS 2016, which could find no difference in water use of homes with Energy Star dishwashers compared to homes with non-ES labeled dishwashers. The question marks are placeholders for ResNet to provide information. Proposed Change: 4.5.6. Determining Daily Dishwasher Water Use for the Rated Home. Rated Home daily dish washer water use shall be calculated as follows: DWgpd = [(88.4+34.9*Nbr) * (12/dWcap) * (4.6415*(1/DW_EF)-1.9295)] / 365 (Eq 4.5-7) Where: 88.4= ?????????? 34.9= ?????????? Nbr= number of bedrooms in the Rated Home 12= ?????????? 4.6415= ??????? 1.9295= ?????????? dWcap= capacity of the dishwasher in the Rated Home (in place settings) as included in the manufacturer’s data DW_EF= The energy factor of the dishwasher installed in the Rated Home
ResNet is not transparent in its debelopment of this draft standard. The draft standard uses constants in the algorithms without providing details of the source of the constants. It is not possible to adequately review the integrity of these algorithms unless the details are provided.
In addition, the example spreadsheet provided by ResNet does NOT use the manufacturer data to determine capacity size. The spreadsheet makes assumptions based on the appearance of an Energy Star label. Many dishwasher models not labeled as Energy Star use the same or less water as Energy Star models. This has been corroborated by the REUWS 2016, which could find no difference in water use of homes with Energy Star dishwashers compared to homes with non-ES labeled dishwashers.
The question marks are placeholders for ResNet to provide information.
4.5.6. Determining Daily Dishwasher Water Use for the Rated Home. Rated Home daily dish washer water use shall be calculated as follows:
DWgpd = [(88.4+34.9*Nbr) * (12/dWcap) * (4.6415*(1/DW_EF)-1.9295)] / 365 (Eq 4.5-7)
88.4= ??????????
34.9= ??????????
Nbr= number of bedrooms in the Rated Home
12= ??????????
4.6415= ???????
1.9295= ??????????
dWcap= capacity of the dishwasher in the Rated Home (in place settings) as included in the manufacturer’s data
Comment #35Page Number: 13Paragraph / Figure / Table / Note: 4.6Comment Intent: ObjectionComment Type: TechnicalComment: ResNet in not transparent in the development of this draft standard. The draft standard uses constants in the algorithms without providing details of the source of the constants. It is not possible to adequately review the integrity of these algorithms unless the details are provided. The "????" are placeholders for ResNet to reveal the source of the constants. It is known that pools use roughly two to three times ETo in semi-arid climates in California. This is also corroborated with the data from the REUWS 2016. A swimming pool at a home greatly affects not only outdoor water use, but also increases indoor water use and greatly increases water leaks. REUWS 2016: “The indicator variable for automatic pool refill systems is highly significant and its coefficient estimate is relatively large in magnitude. Homes that had pool auto-refill systems on average had 66 percent higher logged faucet use than those homes that did not. This is also an expected result since small water uses for pool refilling would normally be labeled as faucet use during analysis. Finally, the presence of swimming pools has a statistically significant estimated effect on water use identified as leaks. The presence of a pool alone on average increases the estimated amount of leaks by about 60 percent. The coefficient estimates also suggest that homes with pool auto-refill systems have more than double the amount of use assigned to leaks (+259 percent) than other homes, given the effects of other variables in the model. This can be the result of small refills of pools being identified as leakage and the fact that pools are often sources of actual leaks, which are assigned to this category during analysis. On average, the presence of a swimming pool was found to increase estimates of indoor use by about 8.4 percent.” Proposed Change: 4.6. Determining Outdoor Water Use for the Rated Home. The Rated Home Outdoor Water Use shall be calculated as follows: (algorithm remains unchanged) Where: Exp(A)= exponent of [1.4416 + 0.5069 * (Rat_Irr_Area/1,000)] Exp(B)= exponent of [0.6911 + 0.00301 * netET * (Rat_Irr_Area/1,000)] 1.18086= ????? 2.0341- ?????? 0.7154= ????? 0.6227+ ?????? Rat_Irr_Area= The size of the landscape that might receive supplemental water in the rated home netET= The annual historic sum of mean reference evapotranspiration minus the mean precipitation for all months that evapotranspiration exceeds precipitation 1.22257= ????? 1.4233= ????? 0.6311= ????? 0.9376= ????? 1.22257= ???? 1.4233= ????? 0.6311= ????? 0.9376= ????? ind_Pool= Indicator representing the presence or absence of a swimming pool Pool_use= equation 1 (using ind_Pool = 1) – equation 1 (using ind_Pool = 0)
ResNet in not transparent in the development of this draft standard. The draft standard uses constants in the algorithms without providing details of the source of the constants. It is not possible to adequately review the integrity of these algorithms unless the details are provided. The "????" are placeholders for ResNet to reveal the source of the constants.
It is known that pools use roughly two to three times ETo in semi-arid climates in California. This is also corroborated with the data from the REUWS 2016.
A swimming pool at a home greatly affects not only outdoor water use, but also increases indoor water use and greatly increases water leaks.
REUWS 2016:
“The indicator variable for automatic pool refill systems is highly significant and its coefficient estimate is relatively large in magnitude. Homes that had pool auto-refill systems on average had 66 percent higher logged faucet use than those homes that did not. This is also an expected result since small water uses for pool refilling would normally be labeled as faucet use during analysis.
Finally, the presence of swimming pools has a statistically significant estimated effect on water use identified as leaks. The presence of a pool alone on average increases the estimated amount of leaks by about 60 percent. The coefficient estimates also suggest that homes with pool auto-refill systems have more than double the amount of use assigned to leaks (+259 percent) than other homes, given the effects of other variables in the model. This can be the result of small refills of pools being identified as leakage and the fact that pools are often sources of actual leaks, which are assigned to this category during analysis.
On average, the presence of a swimming pool was found to increase estimates of indoor use by about 8.4 percent.”
4.6. Determining Outdoor Water Use for the Rated Home. The Rated Home Outdoor Water Use shall be calculated as follows:
(algorithm remains unchanged)
Exp(A)= exponent of [1.4416 + 0.5069 * (Rat_Irr_Area/1,000)]
Exp(B)= exponent of [0.6911 + 0.00301 * netET * (Rat_Irr_Area/1,000)]
1.18086= ?????
2.0341- ??????
0.7154= ?????
0.6227+ ??????
Rat_Irr_Area= The size of the landscape that might receive supplemental water in the rated home
netET= The annual historic sum of mean reference evapotranspiration minus the mean precipitation for all months that evapotranspiration exceeds precipitation
1.22257= ?????
1.4233= ?????
0.6311= ?????
0.9376= ?????
1.22257= ????
ind_Pool= Indicator representing the presence or absence of a swimming pool
Pool_use= equation 1 (using ind_Pool = 1) – equation 1 (using ind_Pool = 0)
Comment #36Page Number: 8Paragraph / Figure / Table / Note: 4.3.6Comment Intent: ObjectionComment Type: TechnicalComment: The calculation for Determining Daily Reference Home Water Softener Use, 4.3.6, appears to discourage softening of water below 180 mg/L (10 grains per gallon) of hardness. While there are numerous classifications for what level of hardness should be considered “soft water”, only one of those classifications is based on science showing the level which provides benefits for consumers. That level is the classification system in the American National Standard NSF/ANSI 44, which requires water softening products to reduce the hardness level to <17.1 mg/L (<1 grain per gallon). That classification is backed by research conducted through the Water Quality Research Foundation, and the Battelle Memorial Institute, which shows the negative impact hardness levels above 17.1 mg/L have on consumers. Above that level you will begin to see many negative impacts including: large drops in energy efficiency of water heating applications; damage to premise plumbing; damage to water related appliances; increased detergent usage and other negative environmental impacts. You will also void warranties for many appliances. NSF International, who publishes standard NSF/ANSI 44, is a very reputable organization that takes the process of establishing these standards very seriously. I would encourage you to review their mission and values (http://www.nsf.org/about-nsf/mission-values-history), and then to harmonize your standard with the existing NSF standard. Proposed Change: Replace 180 mg/L with 17.1 mg/L
The calculation for Determining Daily Reference Home Water Softener Use, 4.3.6, appears to discourage softening of water below 180 mg/L (10 grains per gallon) of hardness. While there are numerous classifications for what level of hardness should be considered “soft water”, only one of those classifications is based on science showing the level which provides benefits for consumers. That level is the classification system in the American National Standard NSF/ANSI 44, which requires water softening products to reduce the hardness level to <17.1 mg/L (<1 grain per gallon). That classification is backed by research conducted through the Water Quality Research Foundation, and the Battelle Memorial Institute, which shows the negative impact hardness levels above 17.1 mg/L have on consumers. Above that level you will begin to see many negative impacts including: large drops in energy efficiency of water heating applications; damage to premise plumbing; damage to water related appliances; increased detergent usage and other negative environmental impacts. You will also void warranties for many appliances. NSF International, who publishes standard NSF/ANSI 44, is a very reputable organization that takes the process of establishing these standards very seriously. I would encourage you to review their mission and values (http://www.nsf.org/about-nsf/mission-values-history), and then to harmonize your standard with the existing NSF standard.
Replace 180 mg/L with 17.1 mg/L
Comment #37Page Number: 14Paragraph / Figure / Table / Note: 4.6.1Comment Intent: ObjectionComment Type: TechnicalComment: There is no scientifically valid evidence of “smart controllers attaining sustained saving water” in the residential sector. Section 4.6.1 should be deleted until such evidence is obtained and verified. REUWS 2016: “Fifty-three homes reported having what they believe to be a “smart, weather-based” irrigation controller. This coefficient had a positive slope (0.096) indicating a rise in water use, but the p value was 0.644 indicating very low statistical significance. Consequently, the data set provides no indication that “smart” controller, or things that people believe to be smart controllers are affecting outdoor water use.” Proposed Change: 4.6.1. Smart Controllers. Sensor and weather based irrigation controllers that are certified by the U.S. EPA WaterSense program 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
There is no scientifically valid evidence of “smart controllers attaining sustained saving water” in the residential sector. Section 4.6.1 should be deleted until such evidence is obtained and verified.
“Fifty-three homes reported having what they believe to be a “smart, weather-based” irrigation controller. This coefficient had a positive slope (0.096) indicating a rise in water use, but the p value was 0.644 indicating very low statistical significance. Consequently, the data set provides no indication that “smart” controller, or things that people believe to be smart controllers are affecting outdoor water use.”
4.6.1. Smart Controllers. Sensor and weather based irrigation controllers that are certified by the U.S. EPA WaterSense program 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
Comment #38Page Number: 12Paragraph / Figure / Table / Note: 4.5.8Comment Intent: ObjectionComment Type: TechnicalComment: No factor is given in this section to account for new plumbing strategies which can further reduce the water usage associated with softeners. For example, strategies such as bypassing water closets and drinking water faucets are being used in some areas to reduce water usage associated with softening. These new strategies should be encouraged by adding such a factor into the equation. Proposed Change: Add a factor to the equation which adjusts for the overall percentage of indoor water which is being softened.
No factor is given in this section to account for new plumbing strategies which can further reduce the water usage associated with softeners. For example, strategies such as bypassing water closets and drinking water faucets are being used in some areas to reduce water usage associated with softening. These new strategies should be encouraged by adding such a factor into the equation.
Add a factor to the equation which adjusts for the overall percentage of indoor water which is being softened.
Comment #39Page Number: 16Paragraph / Figure / Table / Note: 5.1.2Comment Intent: ObjectionComment Type: TechnicalComment: Determination of the hardness level is key to configuring the water softener to provide soft water in the most efficient manner. This section is lacking in detail regarding how inspectors would make that determination. For example, it is unclear what “A dataset approved for use by RESNET” means. The level of hardness present in one well versus an adjacent well can vary greatly. We have seen the end result of this approach when working with municipalities, such as Waukesha WI, on softener optimization strategies. To encourage reliance on general hardness datasets is to invite poor optimization of softeners, and this will have an overall negative impact on chloride discharge and salt usage. The strategy you suggest in this section has proven counter-productive to your end goals because it will have a negative impact on the environment. Proposed Change: Replace with “A hardness test of water collected in the home using an EPA approved method for determination of hardness”
Determination of the hardness level is key to configuring the water softener to provide soft water in the most efficient manner. This section is lacking in detail regarding how inspectors would make that determination. For example, it is unclear what “A dataset approved for use by RESNET” means. The level of hardness present in one well versus an adjacent well can vary greatly. We have seen the end result of this approach when working with municipalities, such as Waukesha WI, on softener optimization strategies. To encourage reliance on general hardness datasets is to invite poor optimization of softeners, and this will have an overall negative impact on chloride discharge and salt usage. The strategy you suggest in this section has proven counter-productive to your end goals because it will have a negative impact on the environment.
Replace with “A hardness test of water collected in the home using an EPA approved method for determination of hardness”
Comment #40Page Number: 7Paragraph / Figure / Table / Note: 4,3,3Comment Intent: ObjectionComment Type: TechnicalComment: Resnet is not transparent in the development of this draft standard. The draft standard uses constants in the algorithms without providing details of the source of the constants. It is not possible to adequately review the integrity of these algorithms unless the details are provided. The "????" are placeholders for Resnet to provide the required information on source of the constant. While I object to the inclusion of a DW in the reference home (other comment), if ResNet chooses to include it, ResNet should be transparent on how it calculates such use. Proposed Change: 4.3.3. Determining Daily Reference Home Dish Washer Water Use. Reference Home dish washer water use shall be calculated as follows: [No change to algorithm] Where: 88.4= ???? 34.9= ???? 8.16= ???? 1.97 = ???? 0.7802= ???? Nbr= number of bedrooms This value is determined in accordance with ANSI/RESNET/ICC 301Addendum A
Resnet is not transparent in the development of this draft standard. The draft standard uses constants in the algorithms without providing details of the source of the constants. It is not possible to adequately review the integrity of these algorithms unless the details are provided. The "????" are placeholders for Resnet to provide the required information on source of the constant.
While I object to the inclusion of a DW in the reference home (other comment), if ResNet chooses to include it, ResNet should be transparent on how it calculates such use.
4.3.3. Determining Daily Reference Home Dish Washer Water Use. Reference Home dish washer water use shall be calculated as follows:
[No change to algorithm]
88.4= ????
34.9= ????
8.16= ????
1.97 = ????
0.7802= ????
This value is determined in accordance with ANSI/RESNET/ICC 301Addendum A
Comment #41Page Number: 12Paragraph / Figure / Table / Note: 4.5.8Comment Intent: ObjectionComment Type: TechnicalComment: The current draft assumes that softened water only goes to indoor fittings: I propose a language change to include outdoor use where applicable. I have witnessed many homes that installed the softener at the main water supply line; thus, using softened water on outdoor fittings. This also correlates to a prior comment that suggests granting water use reduction credit to homes where the water softener is installed to only supply to the water heater. Proposed Change: 4.5.8. Determining Daily Water Softener Water Use for the Rated Home. Rated Home daily water softener water Use shall be calculated as follows: refSofgpd = ???????????? ???? h?????????????? ???????????? ???? ?????????? ∗ ?????? ???? softened indoor ?????????? ???????? ???? ??h?? Rated ???????? ∗ 5 ?????????????? ???????? 1,000 ???????????? ??????????????
The current draft assumes that softened water only goes to indoor fittings: I propose a language change to include outdoor use where applicable. I have witnessed many homes that installed the softener at the main water supply line; thus, using softened water on outdoor fittings. This also correlates to a prior comment that suggests granting water use reduction credit to homes where the water softener is installed to only supply to the water heater.
4.5.8. Determining Daily Water Softener Water Use for the Rated Home. Rated Home daily water softener water Use shall be calculated as follows:
???????????? ???? ?????????? ∗ ?????? ???? softened indoor ?????????? ???????? ???? ??h?? Rated ????????
Comment #42Page Number: 7 & 8Paragraph / Figure / Table / Note: 4.3.4Comment Intent: ObjectionComment Type: TechnicalComment: The draft standard uses constants in the algorithms without providing details of the source of the constants. It is not possible to adequately review the integrity of these algorithms unless the details are provided. To be transparent, ResNet need to include the source of the constants used in the algorithms. The question marks are placeholders for ResNet to supply source information. Proposed Change: 4.3.4. Determining Daily Reference Home Clothes Washer Water Use. Reference Home daily clothes washer water use shall be calculated as follows: Where: Nbr= number of bedrooms 4.52= ???? 164= ???? 46.5= ???? 3= ???? 2.08= ???? 1.59= ???? 2.874= ???? 2.08= ???? 1.59= ???? 9.5= ???? 19.96= ???? 5.66= ????
The draft standard uses constants in the algorithms without providing details of the source of the constants. It is not possible to adequately review the integrity of these algorithms unless the details are provided. To be transparent, ResNet need to include the source of the constants used in the algorithms.
The question marks are placeholders for ResNet to supply source information.
4.3.4. Determining Daily Reference Home Clothes Washer Water Use. Reference Home daily clothes washer water use shall be calculated as follows:
4.52= ????
164= ????
46.5= ????
3= ????
2.08= ????
1.59= ????
2.874= ????
9.5= ????
19.96= ????
5.66= ????
Comment #43Page Number: GeneralComment Intent: ObjectionComment Type: GeneralComment: RESNET development process lacks the ANSI requirements for “openness” despite RESNET stating that they will comply with all of the ANSI essential requirements. This is a standard that our team has tried to follow very closely. However, it seems as though RESNET has not made meeting announcements and agendas readily available to the public. ANSI Essential Requirements state: “Notifications of standards, activity shall be announced in suitable media as appropriate to demonstrate an opportunity for participation by all directly and material affected persons.” “Timely and adequate notice of any action to create, revise, reaffirm, or withdraw a standard, and the establishment of a new consensus body shall be provided to all known directly and materially affected interests.” RESNET does not comply with either of these essential requirements. The National Association of Home Builders is a federation of more than 700 state and local associations representing more than 140,000 member firms nationwide. NAHB’s members are involved in home building, remodeling, multifamily construction, land development, property management and light commercial construction. NAHB is an organization that is directly affected by the material and we have been unable to locate any notice of meeting, or action for the development of this standard. Proposed Change: RESNET would be better served if they opened their standard development process and make it more readily available to liaisons and interested parties. Send out regular meeting notices and make it easily attainable to find meeting notices and agendas on their website.
RESNET development process lacks the ANSI requirements for “openness” despite RESNET stating that they will comply with all of the ANSI essential requirements. This is a standard that our team has tried to follow very closely. However, it seems as though RESNET has not made meeting announcements and agendas readily available to the public.
ANSI Essential Requirements state:
“Notifications of standards, activity shall be announced in suitable media as appropriate to demonstrate an opportunity for participation by all directly and material affected persons.”
“Timely and adequate notice of any action to create, revise, reaffirm, or withdraw a standard, and the establishment of a new consensus body shall be provided to all known directly and materially affected interests.”
RESNET does not comply with either of these essential requirements. The National Association of Home Builders is a federation of more than 700 state and local associations representing more than 140,000 member firms nationwide. NAHB’s members are involved in home building, remodeling, multifamily construction, land development, property management and light commercial construction. NAHB is an organization that is directly affected by the material and we have been unable to locate any notice of meeting, or action for the development of this standard.
RESNET would be better served if they opened their standard development process and make it more readily available to liaisons and interested parties. Send out regular meeting notices and make it easily attainable to find meeting notices and agendas on their website.
Comment #44Page Number: 16Paragraph / Figure / Table / Note: 5.1.1 & 5.1.2Comment Intent: ObjectionComment Type: TechnicalComment: Located in section 5.1.1 and 5.1.2 it requires datasets to be approved by RESNET. Requiring a dataset to be approved by RESNET is making the approval process proprietary and that is not a good practice. Proposed Change: RESNET should change the language so it reads that a “dataset shall meet these criteria” then proceed to provide information on the criteria that is to be met.
Located in section 5.1.1 and 5.1.2 it requires datasets to be approved by RESNET. Requiring a dataset to be approved by RESNET is making the approval process proprietary and that is not a good practice.
RESNET should change the language so it reads that a “dataset shall meet these criteria” then proceed to provide information on the criteria that is to be met.
Comment #45Page Number: 21Paragraph / Figure / Table / Note: 6.1.4.1.3 & 6.1.4.2.1Comment Intent: ObjectionComment Type: GeneralComment: In sections 6.1.4.1.3 and 6.1.4.2.1 the “Mortgage Industry National Home Energy Rating Systems” is referenced. There is a couple things wrong with this. First, this is a non-consensus based standard and should not be referenced in a consensus based standard. This is bad practice and lacks credibility. Second, when the standard is referenced it fails to mention a version or year of the standard and this standard has multiple. Proposed Change: This is not good practice and reference of this should be removed.
In sections 6.1.4.1.3 and 6.1.4.2.1 the “Mortgage Industry National Home Energy Rating Systems” is referenced. There is a couple things wrong with this. First, this is a non-consensus based standard and should not be referenced in a consensus based standard. This is bad practice and lacks credibility. Second, when the standard is referenced it fails to mention a version or year of the standard and this standard has multiple.
This is not good practice and reference of this should be removed.
Comment #46Page Number: 0Comment Intent: ObjectionComment Type: GeneralComment: Use of the generic “Water Rating Index” term in a standard which reflects the HERSH2O program methodology has the potential to cause confusion in the marketplace, as there are other WRI indices available for use now and coming online. The relative water use is not expressed in the same way in the different programs, adding to the potential confusion if this ANSI Standard is branded with a generic term. Proposed Change: Seek alternate naming convention.
Use of the generic “Water Rating Index” term in a standard which reflects the HERSH2O program methodology has the potential to cause confusion in the marketplace, as there are other WRI indices available for use now and coming online. The relative water use is not expressed in the same way in the different programs, adding to the potential confusion if this ANSI Standard is branded with a generic term.
Seek alternate naming convention.
Comment #47Page Number: 0Comment Intent: ObjectionComment Type: TechnicalComment: The omission of incorporating the potable water savings afforded by utilizing alternative water use sources in a rated home results in a missed opportunity for projects to be granted full recognition of their true water efficiency in the HERSH2O score. Additionally, it potentially weakens the credibility of these technologies - by failing to include them in the standard, it sends a message to regulators that RESNET does not consider rainwater or gray water capture/reuse to be viable market-ready strategies and may discourage officials from including them as options in local codes and regulations and/or providing incentives for their use in homes. The omission of credit for these strategies results in a rating index less robust than it could be; these strategies should be incorporated into the program as soon as possible, with some level of credit provided in this initial version, in order to provide developers and builders with the maximum possible options to best showcase the water savings of their properties. Proposed Change: Information is available to include a fundamental accounting of the benefit realized through the use of alternative water sources to displace potable water use; this could be incorporated into the standard now and refined in the next version as more data becomes available, rather than choosing to omit these strategies at this time. The reasoning that they are not included “In order to maintain the technical rigor of the calculations in the rest of the standard” is selective, as the outdoor water use calculations in the standard are rudimentary as compared to other available rating indices. (They do not account for the landscape plants used, the placement of the plantings or the types of pervious/impervious surfaces on the lot.) There could be a set of calculations in this initial standard that includes the fundamental elements driving the quantification of the potable water savings: the amount of reuse water available based on the size of the holding tank(s); for outdoor reuse the average monthly rainfall for the site location and the calculated irrigation needs; and for indoor use the amount of treated reuse available monthly offsetting indoor potable water demand.
The omission of incorporating the potable water savings afforded by utilizing alternative water use sources in a rated home results in a missed opportunity for projects to be granted full recognition of their true water efficiency in the HERSH2O score. Additionally, it potentially weakens the credibility of these technologies - by failing to include them in the standard, it sends a message to regulators that RESNET does not consider rainwater or gray water capture/reuse to be viable market-ready strategies and may discourage officials from including them as options in local codes and regulations and/or providing incentives for their use in homes.
The omission of credit for these strategies results in a rating index less robust than it could be; these strategies should be incorporated into the program as soon as possible, with some level of credit provided in this initial version, in order to provide developers and builders with the maximum possible options to best showcase the water savings of their properties.
Information is available to include a fundamental accounting of the benefit realized through the use of alternative water sources to displace potable water use; this could be incorporated into the standard now and refined in the next version as more data becomes available, rather than choosing to omit these strategies at this time. The reasoning that they are not included “In order to maintain the technical rigor of the calculations in the rest of the standard” is selective, as the outdoor water use calculations in the standard are rudimentary as compared to other available rating indices. (They do not account for the landscape plants used, the placement of the plantings or the types of pervious/impervious surfaces on the lot.)
There could be a set of calculations in this initial standard that includes the fundamental elements driving the quantification of the potable water savings: the amount of reuse water available based on the size of the holding tank(s); for outdoor reuse the average monthly rainfall for the site location and the calculated irrigation needs; and for indoor use the amount of treated reuse available monthly offsetting indoor potable water demand.
Comment #48Page Number: 0Comment Intent: ObjectionComment Type: TechnicalComment: The outdoor water usage calculations do not demonstrate ‘technical rigor’, they do not include many factors of a home lot that will impact outdoor water usage including, but not limited to: ratio of the home footprint to the lot size; the types/amounts of impervious/semi-pervious/pervious areas (calculations based strictly on lot size); water demand of different types of plantings; the impact of hydrozone landscaping; the flow rates and ET loss rates for different types of irrigation; and the impacts of what time of day the irrigation system is employed. The basis for the calculations is not provided; the committee has determined one of two calculations should be used to determine the outdoor water use of the reference home based solely on the net evapotranspiration and the presence/absence of an automatic irrigation system without providing the reasoning for these demarcations. Proposed Change: Include factors in calculations that more accurately reflect water use. -Provide background for reasoning.
The outdoor water usage calculations do not demonstrate ‘technical rigor’, they do not include many factors of a home lot that will impact outdoor water usage including, but not limited to: ratio of the home footprint to the lot size; the types/amounts of impervious/semi-pervious/pervious areas (calculations based strictly on lot size); water demand of different types of plantings; the impact of hydrozone landscaping; the flow rates and ET loss rates for different types of irrigation; and the impacts of what time of day the irrigation system is employed.
The basis for the calculations is not provided; the committee has determined one of two calculations should be used to determine the outdoor water use of the reference home based solely on the net evapotranspiration and the presence/absence of an automatic irrigation system without providing the reasoning for these demarcations.
Include factors in calculations that more accurately reflect water use.
-Provide background for reasoning.
Comment #49Page Number: 8Paragraph / Figure / Table / Note: 4.3.6Comment Intent: ObjectionComment Type: TechnicalComment: The establishment of a baseline for the “Reference Home” is allegedly based on “the attributes of a standard home built circa 2006”. This alleged basis for the standard is not consistent with how RESNET has structured 4.3.6. No scientific basis is provided to support the conclusion that a standard home built circa 2006 would not have softening down to 17.1 mg/L. In fact, the American National Standard, NSF/ANSI 44, which has been in place much longer than 2006, would require softening down to 17.1 mg/L. It appears that RESNET has adjusted the “Reference Home” baseline in this section based on a bias against the softening industry, which is unwarranted since the industry is required by plumbing codes in many states to meet the requirements in the American National Standard, NSF/ANSI 44. The baseline should be adjusted to a standard home built circa 2006. Proposed Change: Replace 180 mg/L with 17.1 mg/L
The establishment of a baseline for the “Reference Home” is allegedly based on “the attributes of a standard home built circa 2006”. This alleged basis for the standard is not consistent with how RESNET has structured 4.3.6. No scientific basis is provided to support the conclusion that a standard home built circa 2006 would not have softening down to 17.1 mg/L. In fact, the American National Standard, NSF/ANSI 44, which has been in place much longer than 2006, would require softening down to 17.1 mg/L. It appears that RESNET has adjusted the “Reference Home” baseline in this section based on a bias against the softening industry, which is unwarranted since the industry is required by plumbing codes in many states to meet the requirements in the American National Standard, NSF/ANSI 44. The baseline should be adjusted to a standard home built circa 2006.
Comment #50Page Number: 8Paragraph / Figure / Table / Note: 4.3.6Comment Intent: ObjectionComment Type: TechnicalComment: There are no water savings benefits to soften water with hardness less than 200 milligrams per liter, despite the sales pitches of softener industry. The industry wants to require water softeners where water hardness is above 1 grain (17milligrams/liter). There is no known water retailer that delivers water at 1 grain. The water softener manufactuers and service providers wants us to believe every home in USA needs a water softener. They are trying to use this standard as a means to increase their sales and profits; they have made similar attempts with other green codes and standards. The water softener industry base their claims on a study they financed and and conducted in 2009. The study compared the effects of hardness on appliances and fittings. The study results were clear in that water with a hardness of 0.55 grains of hardness leaves less calcium deposits than water eith a hardness of 26.2 grains - shocking discovery no doubt! No known water utility delivers water as low as 9.4 ppm, and no known water utility regularly delivers water at 448 ppm. As an example of a water utility in a very hard water area; Orem Utah's water hardness ranges from 120 ppm to 420 ppm throughout the year. It is reasonable to assume this study was designed to sell water softeners. There are some energy saving benefits from softer water from reduced scaling on water heaters, but this standard is not about rating energy efficiency. This standard can meet energy and water efficiency goals by encouraging the water softener be installed so only the water heater recieves the softened water. Unnecessary softeners not only waste water, but they also put salt into the wastewater stream hampering reclaimed water efforts. In addition, there are only problems on the hot water side (pipes and fittings) where water hardness is below 500 milligrams/liter. This proposed change will encourage softeners, where installed, to send the softened water only to the water heater. Most all needs for soft water are when using hot water. This proposal eliminates the waste of salt and discharge water (during recharge cycles) by greatly reducing the demand for softened water. In addition, the current draft assumes that softened water only goes to indoor fittings: I propose a language change to include outdoor use where applicable. I have witnessed many homes that installed the softener at the main water supply line; thus, using softened water on outdoor fittings. Proposed Change: 4.3.6.1. Determining Daily Reference Home Water Softener Use. Where the Rated Home has a water softener and the water hardness at the Rated Home location is greater than or equal to 180 200 milligrams/liter and less than 500 milligrams/liter, the Reference Home water softener daily water use shall be calculated as follows: refSofgpd = ???????????? ???? h?????????????? ???????????? ???? ?????????? ∗ ?????? ???? softened indoor ?????????? ???????? ???? ??h?? ?????????????????? ???????? ∗ 5 ?????????????? ???????? 1,000 ???????????? ?????????????? --------------------------------------------------------------------------------------------------(Eq 4.3-7) Where Rated Home does not meet these conditions of 4.3.6.1 and conditions of 4.3.6.2 the refSofgpd = 0. 4.3.6.2. Determining Daily Reference Home Water Softener Use. Where the Rated Home has a water softener and the water hardness at the Rated Home location is greater than or equal to 500 milligrams/liter, the Reference Home water softener daily water use shall be calculated as follows: refSofgpd = ???????????? ???? h?????????????? ???????????? ???? ?????????? ∗ ?????? ???? softened ?????????? ???????? ???? ??h?? ?????????????????? ???????? ∗ 5 ?????????????? ???????? 1,000 ???????????? ?????????????? ------------------------------------------------------------------------------------------------------(Eq 4.3-7) 4.3.6.3. Determining Daily Reference Home Water Softener Use, Where Rated Home does not meet these conditions of 4.3.6.1 and conditions of 4.3.6.2 the refSofgpd = 0.
There are no water savings benefits to soften water with hardness less than 200 milligrams per liter, despite the sales pitches of softener industry. The industry wants to require water softeners where water hardness is above 1 grain (17milligrams/liter). There is no known water retailer that delivers water at 1 grain. The water softener manufactuers and service providers wants us to believe every home in USA needs a water softener. They are trying to use this standard as a means to increase their sales and profits; they have made similar attempts with other green codes and standards.
The water softener industry base their claims on a study they financed and and conducted in 2009. The study compared the effects of hardness on appliances and fittings. The study results were clear in that water with a hardness of 0.55 grains of hardness leaves less calcium deposits than water eith a hardness of 26.2 grains - shocking discovery no doubt! No known water utility delivers water as low as 9.4 ppm, and no known water utility regularly delivers water at 448 ppm. As an example of a water utility in a very hard water area; Orem Utah's water hardness ranges from 120 ppm to 420 ppm throughout the year. It is reasonable to assume this study was designed to sell water softeners.
There are some energy saving benefits from softer water from reduced scaling on water heaters, but this standard is not about rating energy efficiency. This standard can meet energy and water efficiency goals by encouraging the water softener be installed so only the water heater recieves the softened water.
Unnecessary softeners not only waste water, but they also put salt into the wastewater stream hampering reclaimed water efforts. In addition, there are only problems on the hot water side (pipes and fittings) where water hardness is below 500 milligrams/liter. This proposed change will encourage softeners, where installed, to send the softened water only to the water heater. Most all needs for soft water are when using hot water. This proposal eliminates the waste of salt and discharge water (during recharge cycles) by greatly reducing the demand for softened water. In addition, the current draft assumes that softened water only goes to indoor fittings: I propose a language change to include outdoor use where applicable. I have witnessed many homes that installed the softener at the main water supply line; thus, using softened water on outdoor fittings.
???????????? ???? ?????????? ∗ ?????? ???? softened indoor ?????????? ???????? ???? ??h?? ?????????????????? ????????
--------------------------------------------------------------------------------------------------(Eq 4.3-7)
------------------------------------------------------------------------------------------------------(Eq 4.3-7)
4.3.6.3. Determining Daily Reference Home Water Softener Use, Where Rated Home does not meet these conditions of 4.3.6.1 and conditions of 4.3.6.2 the refSofgpd = 0.
Comment #51Page Number: 12Paragraph / Figure / Table / Note: 4.5.8Comment Intent: ObjectionComment Type: TechnicalComment: There is no need to soften water with hardness less than 200 milligrams per liter, despite the sales pitches of softener industry. Unnecessary softeners not only waste water, but they also put salt into the wastewater stream hampering reclaimed water efforts. In addition, there are only problems on the hot water side (pipes and fittings) where water hardness is below 500 milligrams/liter. This proposed change will encourage softeners, where installed, to send the softened water only to the water heater. Needs for soft water are when using hot water. This proposal eliminates the waste of salt and discharge water (during recharge cycles) by greatly reducing the demand for softened water. In addition, the current draft assumes that softened water only goes to indoor fittings: I propose a language change to include outdoor use where applicable. I have witnessed many homes that installed the softener at the main water supply line; thus, using softened water on outdoor fittings. I changed :indoor water to softened water use to offer credit to water softeners installed for only the hot water uses. Proposed Change: 4.5.8. Determining Daily Water Softener Water Use for the Rated Home. Rated Home daily water softener water Use shall be calculated as follows: ??????????????= ???????????? ???? h?????????????? ???????????? ???? ?????????? ∗ [?????? ???? ???????????? softened ?????????? ???????? ???? ??h?? ?????????? ????????] * [?????????????? ???????? ?????? 1,000 ???????????? ???? h??????????????]
There is no need to soften water with hardness less than 200 milligrams per liter, despite the sales pitches of softener industry. Unnecessary softeners not only waste water, but they also put salt into the wastewater stream hampering reclaimed water efforts.
In addition, there are only problems on the hot water side (pipes and fittings) where water hardness is below 500 milligrams/liter. This proposed change will encourage softeners, where installed, to send the softened water only to the water heater. Needs for soft water are when using hot water. This proposal eliminates the waste of salt and discharge water (during recharge cycles) by greatly reducing the demand for softened water.
In addition, the current draft assumes that softened water only goes to indoor fittings: I propose a language change to include outdoor use where applicable. I have witnessed many homes that installed the softener at the main water supply line; thus, using softened water on outdoor fittings. I changed :indoor water to softened water use to offer credit to water softeners installed for only the hot water uses.
??????????????= ???????????? ???? h??????????????
???????????? ???? ?????????? ∗ [?????? ???? ???????????? softened ?????????? ???????? ???? ??h?? ?????????? ????????]
* [?????????????? ???????? ?????? 1,000 ???????????? ???? h??????????????]
Comment #52Page Number: allParagraph / Figure / Table / Note: allComment Intent: ObjectionComment Type: GeneralComment: This portal turns all Cambria math fonts into ?????? thus, all the formulas transfer as ??????.
This portal turns all Cambria math fonts into ?????? thus, all the formulas transfer as ??????.
Comment #53Page Number: 12Paragraph / Figure / Table / Note: 4.5.8Comment Intent: ObjectionComment Type: TechnicalComment: There is no need to soften water with hardness less than 200 milligrams per liter, despite the sales pitches of softener industry. Unnecessary softeners not only waste water, but they also put salt into the wastewater stream hampering reclaimed water efforts. In addition, there are only problems on the hot water side (pipes and fittings) where water hardness is below 500 milligrams/liter. This proposed change will encourage softeners, where installed, to send the softened water only to the water heater. Needs for soft water are when using hot water. This proposal eliminates the waste of salt and discharge water (during recharge cycles) by greatly reducing the demand for softened water. In addition, the current draft assumes that softened water only goes to indoor fittings: I propose a language change to include outdoor use where applicable. I have witnessed many homes that installed the softener at the main water supply line; thus, using softened water on outdoor fittings. I changed :indoor water to softened water use to offer credit to water softeners installed for only the hot water uses. Proposed Change: 4.5.8. Determining Daily Water Softener Water Use for the Rated Home. Rated Home daily water softener water Use shall be calculated as follows: Softgpd = grains of hardness gallons of water * sum of indoor softened water uses in rated home * [gallons used per 1,000 grains of hardness]
Softgpd = grains of hardness
gallons of water * sum of indoor softened water uses in rated home
* [gallons used per 1,000 grains of hardness]
Comment #54Page Number: 8Paragraph / Figure / Table / Note: 4.3.6Comment Intent: ObjectionComment Type: TechnicalComment: Comment: There are no water savings benefits to soften water with hardness less than 200 milligrams per liter, despite the sales pitches of softener industry. The industry wants to require water softeners where water hardness is above 1 grain (17milligrams/liter). There is no known water retailer that delivers water at 1 grain. The water softener manufactuers and service providers wants us to believe every home in USA needs a water softener. A cynic would presume they are trying to use this standard as a means to increase their sales and profits. The softener industry have made similar attempts with other green codes and standards. The water softener industry base their claims on a study they financed and conducted in 2009. The study compared the effects of hardness on appliances and fittings. The study results were clear in that water with a hardness of 0.55 grains of hardness leaves less calcium deposits than water with a hardness of 26.2 grains - shocking discovery no doubt! No known water utility delivers water as low as 9.4 ppm, and no known water utility regularly delivers water at 448 ppm. As an example of a water utility in a very hard water area; Orem Utah's water hardness ranges from 120 ppm to 420 ppm throughout the year. It is reasonable to assume this study was designed to sell water softeners. There are some energy saving benefits from softer water from reduced scaling on water heaters, but this standard is not about rating energy efficiency. This standard can give proper credit for water savings while preseving energy efficiency by encouraging the water softener be installed so only the water heater recieves the softened water. Unnecessary softeners not only waste water, but they also put salt into the wastewater stream hampering reclaimed water efforts. In addition, there are only problems on the hot water side (pipes and fittings) where water hardness is below 500 milligrams/liter. This proposed change will encourage softeners, where installed, to send the softened water only to the water heater. Most all needs for soft water are when using hot water. This proposal eliminates the waste of salt and discharge water (during recharge cycles) by greatly reducing the demand for softened water. In addition, the current draft assumes that softened water only goes to indoor fittings: I propose a language change to include outdoor use where applicable. I have witnessed many homes that installed the softener at the main water supply line; thus, using softened water on outdoor fittings. Proposed Change: 4.3.6.1. Determining Daily Reference Home Water Softener Use. Where the Rated Home has a water softener and the water hardness at the Rated Home location is greater than or equal to 180 200 milligrams/liter and less than 500 milligrams/liter, the Reference Home water softener daily water use shall be calculated as follows: Softgpd = grains of hardness gallons of water * sum of indoor hot water uses in reference home * [gallons used per 1,000 grains of hardness] Where Rated Home does not meet these conditions of 4.3.6.1 and conditions of 4.3.6.2 the refSofgpd = 0. 4.3.6.2. Determining Daily Reference Home Water Softener Use. Where the Rated Home has a water softener and the water hardness at the Rated Home location is greater than or equal to 500 milligrams/liter, the Reference Home water softener daily water use shall be calculated as follows: Softgpd = grains of hardness gallons of water * sum of indoor water uses in reference home * [gallons used per 1,000 grains of hardness] 4.3.6.3. Determining Daily Reference Home Water Softener Use, Where Rated Home does not meet these conditions of 4.3.6.1 and conditions of 4.3.6.2 the refSofgpd = 0.
There are no water savings benefits to soften water with hardness less than 200 milligrams per liter, despite the sales pitches of softener industry. The industry wants to require water softeners where water hardness is above 1 grain (17milligrams/liter). There is no known water retailer that delivers water at 1 grain. The water softener manufactuers and service providers wants us to believe every home in USA needs a water softener. A cynic would presume they are trying to use this standard as a means to increase their sales and profits. The softener industry have made similar attempts with other green codes and standards.
The water softener industry base their claims on a study they financed and conducted in 2009. The study compared the effects of hardness on appliances and fittings. The study results were clear in that water with a hardness of 0.55 grains of hardness leaves less calcium deposits than water with a hardness of 26.2 grains - shocking discovery no doubt! No known water utility delivers water as low as 9.4 ppm, and no known water utility regularly delivers water at 448 ppm. As an example of a water utility in a very hard water area; Orem Utah's water hardness ranges from 120 ppm to 420 ppm throughout the year. It is reasonable to assume this study was designed to sell water softeners.
There are some energy saving benefits from softer water from reduced scaling on water heaters, but this standard is not about rating energy efficiency. This standard can give proper credit for water savings while preseving energy efficiency by encouraging the water softener be installed so only the water heater recieves the softened water.
gallons of water * sum of indoor hot water uses in reference home
gallons of water * sum of indoor water uses in reference home
Comment #55Page Number: NAParagraph / Figure / Table / Note: NAComment Intent: Not an ObjectionComment Type: GeneralComment: I finally got this system to quit turning my submitted formulas in "????". I submitted new corrected comments. Please delete Comments 32, 41, 50, 1nd 51.
I finally got this system to quit turning my submitted formulas in "????".
I submitted new corrected comments. Please delete Comments 32, 41, 50, 1nd 51.