The following comments have been submitted:
Comment #1Page Number: 14Paragraph / Figure / Table / Note: 4.5.6Comment Intent: ObjectionComment Type: TechnicalComment: There aree two equations for Dishwasher Water Use that have outdated and slightly incorect values. The error occurs because the number loads per year provided on the Energy Guide lable was incorrectly assumed to be 215 instead of 4 loads per week, which is 208 instead of 215. Proposed Change: Change equations as follows: elec_h2o= gallons of hot water use per cycle per unit of annual electricity use in gal·y/kWh·cyc = 1/(80*0.0024*215208) = 0.024230.02504 gas_h2o = gallons of hot water use per cycle per unit of annual gas use in gal·y/therm·cyc = 1/(80*8.2/0.75*215208/100,000) = 0.531760.5497
There aree two equations for Dishwasher Water Use that have outdated and slightly incorect values. The error occurs because the number loads per year provided on the Energy Guide lable was incorrectly assumed to be 215 instead of 4 loads per week, which is 208 instead of 215.
Change equations as follows:
elec_h2o= gallons of hot water use per cycle per unit of annual electricity use in gal·y/kWh·cyc = 1/(80*0.0024*215208) = 0.024230.02504
gas_h2o = gallons of hot water use per cycle per unit of annual gas use in gal·y/therm·cyc = 1/(80*8.2/0.75*215208/100,000) = 0.531760.5497
Comment #2Page Number: 4Paragraph / Figure / Table / Note: ForwardComment Intent: ObjectionComment Type: TechnicalComment: Relevant quote from the draft standard: “The Reference Home used for this comparative analysis has the attributes of a standard home built circa 2006.” Data on softening in a standard home built circa 2006 was not collected or represented. The draft standard assumes, without support, the reference home does not include softening below 10.5 grains of hardness. Homes not remediating hardness would void warranties on many water-related appliances. Private well owners rely on water softeners to remove dangerous contaminants from their drinking water including contaminants such as radium, barium and strontium. Water softeners protect plumbing and fixtures from scale build up. Water softeners decrease the need for chemical cleaners designed to remove scale build up from sinks, tubs, shower stalls and fixtures. Water softeners also make laundry cycles more efficient, allowing the use of less water and less detergent. The concept that homeowners were not doing these things in 2006 and prior is false and has no basis in reality. This appears to be a thinly veiled attempt to unfairly target a specific industry sector by employing criteria which evaluates softeners against a reference home which is not representative of a standard home built circa 2006. Proposed Change: The committee should treat each industry sector impacted by this standard in an equal and fair manner, focusing on an unbiased implementation of the stated methodology to base ratings on comparison to a reference home which has the attributes of a standard home build circa 2006. To provide a fair evaluation of the impact of the softener, the standard should compare the efficiency (water usage) of the actual softener in the home to the efficiency (water usage) of softeners sold circa 2006.
Relevant quote from the draft standard:
“The Reference Home used for this comparative analysis has the attributes of a standard home built circa 2006.”
Data on softening in a standard home built circa 2006 was not collected or represented. The draft standard assumes, without support, the reference home does not include softening below 10.5 grains of hardness. Homes not remediating hardness would void warranties on many water-related appliances. Private well owners rely on water softeners to remove dangerous contaminants from their drinking water including contaminants such as radium, barium and strontium. Water softeners protect plumbing and fixtures from scale build up. Water softeners decrease the need for chemical cleaners designed to remove scale build up from sinks, tubs, shower stalls and fixtures. Water softeners also make laundry cycles more efficient, allowing the use of less water and less detergent. The concept that homeowners were not doing these things in 2006 and prior is false and has no basis in reality. This appears to be a thinly veiled attempt to unfairly target a specific industry sector by employing criteria which evaluates softeners against a reference home which is not representative of a standard home built circa 2006.
The committee should treat each industry sector impacted by this standard in an equal and fair manner, focusing on an unbiased implementation of the stated methodology to base ratings on comparison to a reference home which has the attributes of a standard home build circa 2006. To provide a fair evaluation of the impact of the softener, the standard should compare the efficiency (water usage) of the actual softener in the home to the efficiency (water usage) of softeners sold circa 2006.
Comment #3Page Number: 4Paragraph / Figure / Table / Note: ForwardComment Intent: ObjectionComment Type: TechnicalComment: Relevant quote from the draft standard: “The underpinnings of the indoor Reference Home model are based on ANSI/RESNET/ICC Standard 301-2014, Addendum A.” Data on softening in a standard home built circa 2006 is also not represented in the ANSI/RESNET/ICC Standard 301-2014, Addendum A. The draft standard assumes, without support or reference, that a home built circa 2006 would not include softening below 10.5 grains of hardness. This is a false and misleading reference to a standard that contains no such language. Proposed Change: The committee should treat each industry sector impacted by this standard in an equal and fair manner, focusing on an unbiased implementation of the stated methodology to base ratings on comparison to a reference home which has the attributes of a standard home build circa 2006. To provide a fair evaluation of the impact of the softener, the standard should compare the efficiency (water usage) of the actual softener in the home to the efficiency (water usage) of softeners sold circa 2006.
“The underpinnings of the indoor Reference Home model are based on ANSI/RESNET/ICC Standard 301-2014, Addendum A.”
Data on softening in a standard home built circa 2006 is also not represented in the ANSI/RESNET/ICC Standard 301-2014, Addendum A. The draft standard assumes, without support or reference, that a home built circa 2006 would not include softening below 10.5 grains of hardness. This is a false and misleading reference to a standard that contains no such language.
Comment #4Page Number: 9Paragraph / Figure / Table / Note: 4.3.6Comment Intent: ObjectionComment Type: TechnicalComment: Relevant quote from the draft standard: “Where the Rated Home has a water softener and the water hardness at the Rated Home location is greater than or equal to 180 milligrams/liter, the Reference Home water softener daily water use shall be calculated as follows…” “Where Rated Home does not meet these conditions the refSofgpd = 0” This section establishes a penalty for softening below 10.5 grains of hardness per gallon which is inconsistent with the methodology used in this standard. The intent of this standard is to compare a candidate home to a reference home that has the attributes of a standard home built circa 2006. Homes not remediating hardness below 10.5 grains would void warranties on many water-related appliances that require soft water of <1 grain of hardness per gallon. Private well owners rely on water softeners to remove dangerous contaminants from their drinking water including contaminants such as radium, barium and strontium. Water softeners protect plumbing and fixtures from scale build up. Water softeners decrease the need for chemical cleaners designed to remove scale build up from sinks, tubs, shower stalls and fixtures. Water softeners also make laundry cycles more efficient, allowing the use of less water and less detergent. The concept that homeowners were not softening below 10.5 grains in 2006 and prior is false and has no basis in reality. This appears to be a thinly veiled attempt to unfairly target a specific industry sector by employing criteria which evaluates softeners against a reference home which is not representative of a standard home built circa 2006. Proposed Change: The committee should treat each industry sector impacted by this standard in an equal and fair manner, focusing on an unbiased implementation of the stated methodology to base ratings on comparison to a reference home which has the attributes of a standard home build circa 2006. To provide a fair evaluation of the impact of the softener, the standard should compare the efficiency (water usage) of the actual softener in the home to the efficiency (water usage) of softeners sold circa 2006. Proposed language change: “Where the Rated Home has a water softener and the water hardness at the Rated Home location is greater than or equal to 180 milligrams/liter, the Reference Home water softener daily water use shall be calculated as follows…” “Where Rated Home does not meet these conditions the refSofgpd = 0”
“Where the Rated Home has a water softener and the water hardness at the Rated Home location is greater than or equal to 180 milligrams/liter, the Reference Home water softener daily water use shall be calculated as follows…”
“Where Rated Home does not meet these conditions the refSofgpd = 0”
This section establishes a penalty for softening below 10.5 grains of hardness per gallon which is inconsistent with the methodology used in this standard. The intent of this standard is to compare a candidate home to a reference home that has the attributes of a standard home built circa 2006. Homes not remediating hardness below 10.5 grains would void warranties on many water-related appliances that require soft water of <1 grain of hardness per gallon. Private well owners rely on water softeners to remove dangerous contaminants from their drinking water including contaminants such as radium, barium and strontium. Water softeners protect plumbing and fixtures from scale build up. Water softeners decrease the need for chemical cleaners designed to remove scale build up from sinks, tubs, shower stalls and fixtures. Water softeners also make laundry cycles more efficient, allowing the use of less water and less detergent. The concept that homeowners were not softening below 10.5 grains in 2006 and prior is false and has no basis in reality. This appears to be a thinly veiled attempt to unfairly target a specific industry sector by employing criteria which evaluates softeners against a reference home which is not representative of a standard home built circa 2006.
Proposed language change:
Comment #5Page Number: 9Paragraph / Figure / Table / Note: 4.3.6Comment Intent: ObjectionComment Type: TechnicalComment: Relevant quote from the draft standard: “Where the Rated Home has a water softener and the water hardness at the Rated Home location is greater than or equal to 180 milligrams/liter, the Reference Home water softener daily water use shall be calculated as follows…” “Where Rated Home does not meet these conditions the refSofgpd = 0” This section would be counter-productive by discouraging the use of high efficiency water appliances which use less water and less energy, but also require soft water with <1 grain of hardness per gallon to avoid damage. The warranties of those products would be voided. Proposed Change: In replacement of a penalty for softening below 10.5 grains of hardness, this standard should focus on water softener efficiency which will allow homeowners to use high efficiency water appliances that require soft water of <1 grain of hardness per gallon. To provide a fair evaluation of the efficiency of the softener, the standard should compare the efficiency (water usage) of the actual softener in the home to the efficiency of softeners sold prior to 2006. Proposed language change: “Where the Rated Home has a water softener and the water hardness at the Rated Home location is greater than or equal to 180 milligrams/liter, the Reference Home water softener daily water use shall be calculated as follows…” “Where Rated Home does not meet these conditions the refSofgpd = 0"
This section would be counter-productive by discouraging the use of high efficiency water appliances which use less water and less energy, but also require soft water with <1 grain of hardness per gallon to avoid damage. The warranties of those products would be voided.
In replacement of a penalty for softening below 10.5 grains of hardness, this standard should focus on water softener efficiency which will allow homeowners to use high efficiency water appliances that require soft water of <1 grain of hardness per gallon. To provide a fair evaluation of the efficiency of the softener, the standard should compare the efficiency (water usage) of the actual softener in the home to the efficiency of softeners sold prior to 2006. Proposed language change:
“Where Rated Home does not meet these conditions the refSofgpd = 0"
Comment #6Page Number: 9Paragraph / Figure / Table / Note: 4.3.6Comment Intent: ObjectionComment Type: TechnicalComment: Relevant quote from the draft standard: “Where the Rated Home has a water softener and the water hardness at the Rated Home location is greater than or equal to 180 milligrams/liter, the Reference Home water softener daily water use shall be calculated as follows…” “Where Rated Home does not meet these conditions the refSofgpd = 0” Some private well owners rely on water softeners to remove dangerous contaminants from their water which would otherwise cause serious health concerns, including barium, radium and strontium. It is irresponsible to publish a water efficiency standard that would penalize private well owners who seek to protect their family and loved ones from dangerous drinking water contaminants. Proposed Change: Instead of a penalty for softening below 10.5 grains of hardness, this standard should focus on water softener efficiency. This approach will encourage less water use but also allow homeowners to use water softeners for the removal of dangerous drinking water contaminants including barium, radium and strontium. To provide a fair evaluation of the efficiency of the softener, the standard should compare the efficiency (water usage) of the actual softener in the home to the efficiency of softeners sold prior to 2006. Proposed language change: “Where the Rated Home has a water softener and the water hardness at the Rated Home location is greater than or equal to 180 milligrams/liter, the Reference Home water softener daily water use shall be calculated as follows…” “Where Rated Home does not meet these conditions the refSofgpd = 0”
Some private well owners rely on water softeners to remove dangerous contaminants from their water which would otherwise cause serious health concerns, including barium, radium and strontium. It is irresponsible to publish a water efficiency standard that would penalize private well owners who seek to protect their family and loved ones from dangerous drinking water contaminants.
Instead of a penalty for softening below 10.5 grains of hardness, this standard should focus on water softener efficiency. This approach will encourage less water use but also allow homeowners to use water softeners for the removal of dangerous drinking water contaminants including barium, radium and strontium. To provide a fair evaluation of the efficiency of the softener, the standard should compare the efficiency (water usage) of the actual softener in the home to the efficiency of softeners sold prior to 2006. Proposed language change:
Comment #7Page Number: 9Paragraph / Figure / Table / Note: 4.3.6Comment Intent: ObjectionComment Type: TechnicalComment: Relevant quote from the draft standard: “Where the Rated Home has a water softener and the water hardness at the Rated Home location is greater than or equal to 180 milligrams/liter, the Reference Home water softener daily water use shall be calculated as follows…” “Where Rated Home does not meet these conditions the refSofgpd = 0” This will be counter-productive by forcing home owners to use more water for laundry and cleaning activities. Independent studies done by New Mexico State University and the Battelle Memorial Institute have long ago established that softened water improves the efficiency of laundry, and also prevents the need for frequent cleaning of sinks, tubs, shower stalls and fixtures to remove the build up of scale. By penalizing home owners for softening below 10.5 grains of hardness, you will cause them to use more water in these activities. There will also be undesired environmental impacts due to the need for more detergent, and chemical cleaners. Proposed Change: Instead of a penalty for softening below 10.5 grains of hardness, this standard should focus on water softener efficiency. This approach will promote softener optimization (less water use) while also allowing homeowners to employ more efficient settings on their clothes washer, and to avoid the need for wasteful cleaning activities to keep sinks, tubs, shower stalls and fixtures clear of insoluble soap curd and scale. To provide a fair evaluation of the impact of the softener, the standard should compare the efficiency (water usage) of the actual softener in the home to the efficiency (water usage) of softeners sold circa 2006. Proposed language change: “Where the Rated Home has a water softener and the water hardness at the Rated Home location is greater than or equal to 180 milligrams/liter, the Reference Home water softener daily water use shall be calculated as follows…” “Where Rated Home does not meet these conditions the refSofgpd = 0"
This will be counter-productive by forcing home owners to use more water for laundry and cleaning activities. Independent studies done by New Mexico State University and the Battelle Memorial Institute have long ago established that softened water improves the efficiency of laundry, and also prevents the need for frequent cleaning of sinks, tubs, shower stalls and fixtures to remove the build up of scale. By penalizing home owners for softening below 10.5 grains of hardness, you will cause them to use more water in these activities. There will also be undesired environmental impacts due to the need for more detergent, and chemical cleaners.
Instead of a penalty for softening below 10.5 grains of hardness, this standard should focus on water softener efficiency. This approach will promote softener optimization (less water use) while also allowing homeowners to employ more efficient settings on their clothes washer, and to avoid the need for wasteful cleaning activities to keep sinks, tubs, shower stalls and fixtures clear of insoluble soap curd and scale. To provide a fair evaluation of the impact of the softener, the standard should compare the efficiency (water usage) of the actual softener in the home to the efficiency (water usage) of softeners sold circa 2006. Proposed language change:
Comment #8Page Number: 19Paragraph / Figure / Table / Note: 5.1.2Comment Intent: ObjectionComment Type: TechnicalComment: Relevant quote from the draft standard: “5.1.2. Hardness of Water. Data for the hardness of water shall be determined by the location of the Rated Home and one of the following: a) U.S. Geological Survey Concentrations of Hardness as Calcium Carbonate Map” The U.S. Geological Survey Concentrations of Hardness as Calcium Carbonate Map is an inaccurate way to estimate hardness in the home and should be stricken from the standard. The USGS itself does not support this as an intended use of their data. The USGS webpage summarizes the limitations of the data contained in the map and its intended use: “There are, however, several caveats about the nature, use, and interpretations of these data: (1) the data illustrated represent water hardness on a national and regional scale and must be so interpreted; (2) the 1975 data are not designed to be used to make local decisions or decisions on the scale of individual homeowner property; and (3) information that is directly relevant to water hardness and other chemical properties at a home or immediate locale should be provided by the local health agency, local water utility, or by the vendor of a local water-softening system.” https://water.usgs.gov/owq/hardness-alkalinity.html Encouraging the use of the USGS dataset for the purpose of making local decisions on an individual homeowner’s property goes against the USGS warning on data use and will result in extremely inaccurate assessments of hardness. Proposed Change: Remove reference to the U.S. Geological Survey Concentrations of Hardness as Calcium Carbonate Map as a viable mechanism to determine hardness in a home.
“5.1.2. Hardness of Water. Data for the hardness of water shall be determined by the location of the Rated Home and one of the following:
a) U.S. Geological Survey Concentrations of Hardness as Calcium Carbonate Map”
The U.S. Geological Survey Concentrations of Hardness as Calcium Carbonate Map is an inaccurate way to estimate hardness in the home and should be stricken from the standard. The USGS itself does not support this as an intended use of their data. The USGS webpage summarizes the limitations of the data contained in the map and its intended use: “There are, however, several caveats about the nature, use, and interpretations of these data: (1) the data illustrated represent water hardness on a national and regional scale and must be so interpreted; (2) the 1975 data are not designed to be used to make local decisions or decisions on the scale of individual homeowner property; and (3) information that is directly relevant to water hardness and other chemical properties at a home or immediate locale should be provided by the local health agency, local water utility, or by the vendor of a local water-softening system.”
https://water.usgs.gov/owq/hardness-alkalinity.html
Encouraging the use of the USGS dataset for the purpose of making local decisions on an individual homeowner’s property goes against the USGS warning on data use and will result in extremely inaccurate assessments of hardness.
Remove reference to the U.S. Geological Survey Concentrations of Hardness as Calcium Carbonate Map as a viable mechanism to determine hardness in a home.
Comment #9Page Number: 9Paragraph / Figure / Table / Note: 4:3:6Comment Intent: ObjectionComment Type: GeneralComment: “Where the Rated Home has a water softener and the water hardness at the Rated Home location is greater than or equal to 180 milligrams/liter, the Reference Home water softener daily water use shall be calculated as follows…” “Where Rated Home does not meet these conditions the refSofgpd = 0” This will be counter-productive by forcing home owners to use more water for laundry and cleaning activities. Independent studies done by New Mexico State University and the Battelle Memorial Institute have long ago established that softened water improves the efficiency of laundry, and also prevents the need for frequent cleaning of sinks, tubs, shower stalls and fixtures to remove the build up of scale. By penalizing home owners for softening below 10.5 grains of hardness, you will cause them to use more water in these activities. There will also be undesired environmental impacts due to the need for more detergent, and chemical cleaners. Proposed Change: Maytag states in their own dishwasher manual that " a mechanical water softener may be necessary to improve water quality, deterfent effectiveness, and protect the dishwasher parts from the damange that hard water can cause." Also, many tankless water heaters have warranties that are void if hard water is present. Instead of a penalty for softening below 10.5 grains of hardness, this standard should focus on water softener efficiency. This approach will promote softener optimization (less water use) while also allowing homeowners to employ more efficient settings on their clothes washer, and to avoid the need for wasteful cleaning activities to keep sinks, tubs, shower stalls and fixtures clear of insoluble soap curd and scale. In fact, To provide a fair evaluation of the impact of the softener, the standard should compare the efficiency (water usage) of the actual softener in the home to the efficiency (water usage) of softeners sold circa 2006. Proposed language change: “Where the Rated Home has a water softener and the water hardness at the Rated Home location is greater than or equal to 180 milligrams/liter, the Reference Home water softener daily water use shall be calculated as follows…” “Where Rated Home does not meet these conditions the refSofgpd = 0"
Maytag states in their own dishwasher manual that " a mechanical water softener may be necessary to improve water quality, deterfent effectiveness, and protect the dishwasher parts from the damange that hard water can cause." Also, many tankless water heaters have warranties that are void if hard water is present.
Instead of a penalty for softening below 10.5 grains of hardness, this standard should focus on water softener efficiency. This approach will promote softener optimization (less water use) while also allowing homeowners to employ more efficient settings on their clothes washer, and to avoid the need for wasteful cleaning activities to keep sinks, tubs, shower stalls and fixtures clear of insoluble soap curd and scale. In fact,
To provide a fair evaluation of the impact of the softener, the standard should compare the efficiency (water usage) of the actual softener in the home to the efficiency (water usage) of softeners sold circa 2006. Proposed language change:
Comment #10Page Number: N/AParagraph / Figure / Table / Note: NamingComment 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: Use a different term for the index.
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.
Use a different term for the index.
Comment #11Page Number: PDS-02Comment Intent: ObjectionComment Type: TechnicalComment: I am a homebuilder in Central Texas who has been building homes that use rainwater as the sole source of water. We have been building these homes since 2006 and have close to 100 homes that use only rainwater. These homes all have meters for domestic use but also separate meters for landscaping and autofills when they have pools. We have data from homes that can broken down by resident demographics. Our data will also show the difference in homes with Water Sence Products or how much water is saved using structured plumbing. I would be willing to discuss with the committee this data in the interest of considering using rainwater harvesting as part of the water efficiency calculations of the HERS H2O index.
I am a homebuilder in Central Texas who has been building homes that use rainwater as the sole source of water. We have been building these homes since 2006 and have close to 100 homes that use only rainwater. These homes all have meters for domestic use but also separate meters for landscaping and autofills when they have pools. We have data from homes that can broken down by resident demographics. Our data will also show the difference in homes with Water Sence Products or how much water is saved using structured plumbing. I would be willing to discuss with the committee this data in the interest of considering using rainwater harvesting as part of the water efficiency calculations of the HERS H2O index.