Letter to the Editor: Bringing a New Dimension to Toilets

Dear Editor:

As one of the strongest proponents of High-Efficiency Toilet technology and as a representative of U.S. water utilities that promote these new products, I must respond to (and maybe even expand upon) your Jan. 29 story, “New EPA-Certified Toilets Address Water Shortages.”

A few points to note:

1. WaterSense and UNAR (Uniform North American Requirements):  No HETs are currently "labeled" by WaterSense, since the specification was just released. That will change soon. However, the EPA specification was based largely upon UNAR for toilet fixtures that have been in place for a little more than a year. UNAR-qualified HETs meet or exceed the requirements in the EPA WaterSense specification. A full listing (updated monthly) of the qualified HETs is always available on our Web site: click here (cuwcc.org/toilet_fixtures.lasso).
   
   
2. Technologies and Qualified Products: As of today, a total of 68 HET fixtures meet the rigorous requirements of UNAR. These same fixtures will be tested again in order to qualify for WaterSense. Another 36 HET models have yet to be tested for UNAR compliance. We expect somewhere in the neighborhood of another 30 to 50 HET models to be introduced by manufacturers in 2007, so the selections will be vast. All types of technologies are represented: gravity-fed, pressure-assist, dual- and single-flush, and flushometer valve.
   
   
3. History of Installations: Water utilities in California have been purchasing UNAR-qualified HETs for several years for their residential toilet replacement programs. More than 15,000 of these fixtures have been installed in California homes since they were first introduced there in 1999. Customer satisfaction with HETs has been exceptionally high. By the way, about one-half of the installations are of pressure-assist HETs and one-half are gravity-fed. The argument against the pressure-assist technology in single-family residential homes is no longer valid because noise levels are much lower than they were just a few years ago.
   
   
4. Price: The price of HETs has dropped significantly since their introduction in 1999. Today, bulk purchases (similar to the purchase schemes of the production home builders) of the best of these toilets are yielding prices well below $100 per toilet for some gravity-fed models. Pressure-assist fixtures from major manufacturers are priced as low as $140, equal in price to their 1.6-gallon counterpart. So our recent experience has been that HETs are NOT "$100 more than a typical builder-grade unit." In fact, we expect to soon see them at parity with their equivalent 1.6-gallon counterpart with equal performance.
   
   
5. Performance: Flush performance is measured by the MaP test, which was developed in 2003 by 22 water utilities in the U.S. and Canada. MaP is now the accepted performance benchmark for consumers, builders, specifiers, architects, water utilities and others. It represents a sizable "raising of the bar" from the minimal requirements associated with fixture certification.
   
   EPA's WaterSense for HETs adopted the MaP test protocol and established a 350-gram minimum threshold of flush performance. We have repeatedly found that many of the "typical builder-grade" toilets are seldom MaP-tested and when they are, they are poor performers. Therefore, a WaterSense or UNAR HET cannot be directly equated with a "typical builder-grade" toilet, either in price or performance. A builder can choose to "pay now" (purchase a MaP-tested toilet that meets the 350-gram threshold) or "pay later" (through callbacks to the buyer's home).
   
   The latest MaP testing results can be found by clicking here (cuwcc.org/maptesting.lasso). The report can also be downloaded from ToolBase by clicking here (www.toolbase.org/Building-Systems/Plumbing/Toilet-Testing-Condensed).
   
   
6. Finally, we have been studying toilet fixtures and their performance for more than 10 years. We can state without reservation that there is NO correlation between the price of a toilet and its flush performance!  We always tell builders and consumers that they can purchase outstanding flushers for commodity pricing, they just need to do a little research!

We are excited about the steps that the EPA is taking through the new WaterSense Program. Their emphasis upon product performance and customer satisfaction (rather than just flush or flow rates) adds an important dimension to the program. Builders should look to WaterSense as their guide as new product categories are rolled out by the EPA.

WaterSense for HETs is ONLY possible because the plumbing industry undertook in the late 1990s to re-engineer their products, improve performance and incorporate water efficiency as an important element of design. Both the EPA and the manufacturers are to be commended for their bold steps forward.

I urge subscribers to Nations Building News to view and bookmark the Web sites shown above as the best resources for the latest information on toilets.

John Koeller
California Urban Water Conservation Council
Koeller and Company
Yorba Linda, California

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