Improvements Suggested for New EPA Water Efficiency Designation
In public comments submitted last week to the U.S. Environmental Protection Agency, NAHB has made a number of suggestions to improve a draft of the agency’s Water-Efficient Single-Family New Home Specification, which will be used to designate “WaterSense” homes.
Introduced two years ago, WaterSense is a counterpart to Energy Star, a joint program of the EPA and the U.S. Department of Energy. While Energy Star issues voluntary guidelines and rates products for energy efficiency, WaterSense rates products for water efficiency.
Builder members of NAHB are participating in a pilot program based on the EPA’s draft specification for water efficiency.
The association supports resource efficiency programs that are voluntary, affordable and cost-effective and that take consumer preferences into account, NAHB said in its comments. “Therefore, first and foremost, NAHB and its members believe that the WaterSense label must be clearly defined and recognized as an above-code and voluntary program,” NAHB said in its letter to the EPA.
“While the program can provide important incentives for builders to install water-saving devices in the homes they build,” NAHB said, “product availability, cost considerations, the availability of WaterSense partners and verifiers, and consumer demand will ultimately dictate participation. Furthermore, product performance, both individually and as a system, must meet the needs and expectations of consumers if the program is to be successful.”
NAHB outlined a number of concerns with the draft program:
- Water Pressure. In homes served by private well systems, a requirement for builders to install a Pressure Regulating Valve (PRV) ensuring that the domestic water delivery system maintains a static service pressure of 60 psi or less may not work as intended, NAHB said. The EPA should consider separate guidelines for homes using public water systems and those using well water, NAHB advised.
The regulating valve can also affect the design and operation of residential fire sprinkler systems. “The program criteria and supporting statements should note this important issue so that builders who include fire sprinkler systems and want to follow the WaterSense program can communicate appropriately with their installers and be prepared for potential design alterations and cost increases,” the letter said.
- Insulation. Because a typical home's hot-water usage generally occurs twice a day — in the morning and the evening — a requirement that all hot water pipes be insulated to an R4 minimum will not “translate to enough real-world water and energy savings to justify the increased material and labor cost of insulating all hot water pipes,” the NAHB letter said.
“While NAHB acknowledges that insulating hot-water supply runs located below-grade, below-slab and in crawlspaces may be cost-effective in some climates, the association cannot support the measure to require insulation on all hot water pipes until sufficient data on hot water usage patterns exists to justify it,” the letter said.
“Given the unknown level of real-world benefit/detriment offered by pipe insulation in conditioned space, NAHB suggests the practice be given the same consideration as smaller diameter pipe,” which can also save water and energy, “and be included as an option rather than a requirement for WaterSense certification,” the letter said.
- Turf. The draft specification lists criteria for landscaping, including limiting the amount of turf grass the builder can include on the lot. “Many jurisdictions have landscape requirements that may differ from the EPA’s due to local vegetation or water issues,” the letter pointed out.
“The WaterSense program should be sufficiently flexible to give consideration to what vegetation a jurisdiction deems appropriate for the community.”
- Ornamental water features. The draft specification prohibits the use of fountains and other landscape devices. “This prohibition is excessive and ignores the possibility of installing features that incorporate captured stormwater, grey water, shading, closed loop or recirculating pump systems, or features that otherwise have no negative impact on potable water usage or have been designed to minimize evaporation,” the NAHB letter said.
The letter also asked for clarification on the certification process, on the role of WaterSense-qualified irrigation installation contractors and on storm water management.
“NAHB looks forward to the release of a second draft and the possibilities it may provide to those innovative builders who volunteer the time and resources to ensure the start of a successful program. However, failure to provide flexibility and clear definition on key program specifics will limit participation until such issues are appropriately addressed,” the letter said.
For more information, e-mail Calli Schmidt at NAHB, or call her at 800-368-5242 x8132.