JOHN KOELLER, P.E.
SPECIAL TO CONTRACTOR
I WAS PARTICULARLY interested in CONTRACTOR's news story and Editorial in June regarding California's AB2496 proposal to reduce flush volumes of toilets by requiring high-efficiency-toilets and high-efficiency urinals. I'd like to make some comments:
First, HETs have been available in the marketplace here since 1999 and, today, 17 different toilet manufacturers are marketing more than 90 such models of fixtures! HEUs (flushing at 0.5 gpf or less) have been in the marketplace for 15 years and non-water urinals for a similar period. Today, manufacturers are developing and introducing more models (both flushing and non-water) that will meet the 0.5-gpf maximum.
California's AB2496 would require that HETs be installed in new buildings beginning in 2009 and that only HETs be sold beginning in 2010. Your news story ("Calif. bill would mandate lower-flushing fixtures," pg. 1) states that Lake Coulson, vice president/government affairs for the Plumbing-Heating-Cooling Contractors - National Association, has three questions about AB2496:
1. Is the change to 1.3-gpf toilets feasible and economically justified?
The U.S. Environmental Protection Agency has been working closely with toilet manufacturers to develop a voluntary HET program for the purpose of saving water through toilets that use no more than 1.28 gal. per flush. Toilets that meet the flush volume and performance requirements will be allowed to display the "WaterSense" label. This program will roll out shortly. Clearly, the manufacturers and EPA think these HET fixtures are feasible and economical.
On its WaterSense Web page, the EPA says that HETs are not any more expensive than "regular" toilets and that HETs provide sufficient water to carry wastes to the stack. Expect to see a tidal wave of new HET models from the industry in 2007.
2. Have the failures of 1.6-gpf (toilet) models been corrected?
Absolutely! The plumbing industry is to be commended for the remarkable improvements in fixture performance that have occurred in the last six years. While some "marginal performers" still exist in the marketplace, the consumer, specifier, contractor and others now have access to authoritative information on performance that did not exist in the 1990s such that they can avoid those flushers.
Today, Maximum Performance, or MaP, testing of toilet fixtures is a widespread and important measure of flush performance for all tank-type toilet fixtures. For further information and the latest report, readers should consult www.cuwcc.org/maptesting.lasso
Not only do the 1.6-gpf toilets of today outperform the models of the early 1990s, but the HETs do even better, as demonstrated by strong customer satisfaction and by MaP testing scores. Although flushometer valve toilets are yet to be added to our ongoing MaP work, one initial study measures 49 different popular valve-bowl combinations. Download this information at www.veritec.ca/FV%20Revised%20Final%20Report%20Aug,%2023.pdf
3. Can federal standards for flushing requirements pre-empt any new California law?
In 1992, Congress did establish national toilet flush volume maximums, essentially adopting the standards set by a number of states and pre-empting further state actions. That 1992 federal pre-emption has expired.
Bob Miodonski's Editorial ("Wrong way to lower fixture requirements," pg. 98) infers that California should wait for national standards instead of embarking upon a "piecemeal" state-by-state approach. In pre-empting the states in 1992, the federal government implied it would lower toilet flush volumes, but it has not done so.
The EPA's excellent, voluntary WaterSense program is the only major effort since 1992 to move in that direction. This might be the first step toward a new national standard, although it is not yet being thought of that way.
California is a semi-arid state with most of its major rivers already developed and most of its population hundreds of miles away from any potential new river sources. With a population that increases by 500,000 every year, California needs to pursue water conservation as one of the tools to meet this burgeoning population.
Later in the Editorial, Bob quotes Mary Ann Dickinson, executive director of the California Urban Water Conservation Council, as saying that one-third of California's "urban water use could be saved with existing technologies." He then goes on to incorrectly assume that she was not including HETs and HEUs in that category. In fact, both HETs and HEUs are existing, viable, proven technologies, and these technologies, and many others, are needed to provide for the families and businesses of California!
Both the news story and Editorial cite quotes by Plumbing Manufacturers Institute President Claude Theisen that actually are contrary to that organization's stated position on the legislation. In fact, because so many members of PMI support AB2496, PMI took a neutral position on the bill.
As a point of general information, the proposed legislation would take effect initially in 2009, rather than 2008. A postponing of the date resulted from ongoing discussions with the plumbing fixture manufacturers.
Now, the most interesting and really encouraging part of this move forward on the path to water efficiency is the support of the fixture manufacturers.
The legislative office that crafted the legislation and has refined it over the past months has done so in cooperation with those manufacturers.
Together, the parties have defined, refined, modified and amended the language to accommodate industry issues, while still retaining a path to significant water use reduction in the state of California. Over the past few months, it has been the clearly stated goal of the legislative office to always work with manufacturers to take advantage of the very significant technology and performance improvements in toilets and urinals that this very industry has so successfully delivered to today's marketplace!
I commend American Standard, Mansfield, Sloan Flushmate, WDI, Vitra USA, Caroma USA, (most of whom are PMI members, by the way) and others for standing up for water-use efficiency as a high priority!
I think that it is also interesting to consider that 19% of all electricity consumed in the state of California is related to water, that is, pumping, conveying, treating, using and treating again as wastewater. Water-use reduction results in significant reductions in electricity use as well. As such, capital infrastructure requirements for water systems, wastewater treatment systems, and electricity production and transmission are all reduced when water use is reduced.
The question that probably everyone is asking is: "Will these toilets work??"
I indicated earlier that MaP testing numbers show that these latest HETs are far and away superior to their 10-year-old 1.6-gal. counterparts. However, even though the implementation date for AB2496 is nearly 2 1 /2 years away, there will still likely be some "dogs" that make it to the marketplace if strict flush performance requirements are not added to the legislation.
It is my strong hope that AB2496 adopts the new U.S. EPA's WaterSense program requirements for HETs. Those requirements (still in draft form and downloadable from www.epa.gov/watersense/ps/plumbing.htm) mandate a minimum MaP score of 350 grams, which we believe to be sufficient to result in satisfied customers.
Finally, I find it absolutely ironic that I am arguing the plumbing industry has done a superb job in delivering new technology HETs and HEUs that significantly outperform their predecessors, while plumbing industry folks such as Mr. Coulson are essentially saying: "Oh, no, our products really don't work very well after all. We will have to deal with customer complaints!"
Thanks to Bob Miodonski for this chance to respond to some of the issues brought up in his Editorial. CONTRACTOR is an excellent publication, and I urge Bob and Managing Editor Bob Mader to keep up the good work!
John Koeller, P.E., is principal of Koeller and Co. in Yorba Linda, Calif. He is a technical adviser to the California Urban Water Conservation Council. His e-mail address is [email protected]