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Comments Regarding the WaterSense Specifications for New Homes
Commenter Name:
Commenter Affiliation:
Date of Comment Submission:
The following comments are to serve as our official comments regarding the second draft of the WaterSense Water-Efficient Single-Family New Home Specification. The comments below are to reflect the best options as we see fit given the draft presented to the public for comment. They should by no means be accepted as an “endorsement” of the full specification, as there is much science that, in our estimation, has not been considered during the development of the first and second drafts. Such deviations from best available science should be corrected and the specifications should be subject to an additional public comment prior to the formal release of the outdoor criteria.
As stated in California Assembly Bill 1881(enacted 2006): “…landscapes are essential to the quality of life in California by providing areas for active and passive recreation and as an enhancement to the environment by cleaning air and water, preventing erosion, offering fire protection, and replacing ecosystems lost to development…” we believe the statement within AB1881 can apply across the country and as such, is hopeful the EPA will make constructive improvements that embrace the value of the outdoor living environment prior to publication of its WaterSense Model New Home Specification.
We recommend to the EPA that decisions impacting landscape irrigation should be driven locally and that the EPA not move forward with the outdoor criteria of the specification until locally driven and clearer outcome-based performance criteria are developed in partnership with qualified stakeholders. We also recommend to EPA that the comments submitted by the Irrigation Association in September 2008 (supported by more than 90 individuals and organizations) in response to the first draft of the new home specifications are revisited as they are based on best available science and best management practices. If the EPA decides to move forward with the final publication, we urge the EPA to take into consideration the comments below from the irrigation industry, as they are based on market data, best management practices and best available science.
Topic:
4.1 – At a minimum, the front yard shall be landscaped to meet the criteria in either option. The entire yard shall be landscaped to meet the criteria in either option where landscaping of the entire yard is financed, installed, or sold as an upgrade through the homebuilder. The entire yard shall also be landscaped to meet the criteria in either option when irrigation systems, pools, spas, or water features have been financed, installed, or sold by the homebuilder.
Comment:
If the EPA is going to support having any prescriptive requirements associated with the outdoor criteria, then the requirements should apply to the entire landscapable area, not just the front yard, regardless of whether an irrigation system, pool, spa or other water feature is installed.
Rationale:
We not support any language that does not treat the entire landscape equally.
Suggested Change (or Language):
Any option associated with the outdoor criteria shall apply to the entire landscapable area.
Topic:
4.1.1.1 Option 1 – Turfgrass shall not exceed 40 percent of the landscapable area.
Comment:
We do not support any arbitrary limits on landscape plant material. This national criterion, voluntary or otherwise, is inappropriate and not based on best available science. For this reason, and as previously commented, we do not support the inclusion of Option 1.
Rationale:
We believe in the practice of “right plant in the right place,” and works very closely with the green industry in promoting local and adapted plant materials appropriate for each climate and geographical location. The 40% turfgrass limitation, in our estimation, is an arbitrary limit placed on landscapes. Local geographies, climates and markets should guide the make-up of landscape materials, including types of turfgrass, trees and shrubs.
Suggested Change (or Language):
The EPA should use best available science to produce a performance-based approach to landscape design criteria, rather than an arbitrary prescriptive approach. We urge the EPA to continue the dialogue with all segments of the green industry on best practices and stewardship to determine the best performance-based criteria to implement as part of the new homes specification.
Topic:
4.1.1.2 Option 2 – Landscape design shall be developed using the water budget tool based on a 70 percent evapotranspiration adjustment factor.
Comment:
Best available science dictates that evapotranspiration adjustment factors should be determined based on geography and climate. If a national water budget continues to be a part of the specification, we recommend that the ETAF be implemented at 80%.
In addition to the recommendation that the EPA use a 80% ETAF for the water budget calculator, we are also including, as part of these comments, significant comments focusing on the data and assumptions used within the proposed water budget tool. We urge the EPA to consider all recommendations associated with the water budget tool, in addition to the recommended change to 80% ETAF. We feel that an 80% ETAF would be a significant increase in efficiency (as much as 50%) from the current market norm. Any evapotranspiration adjustment factor that is implemented as a “one-size-fits-all” ETAF less than 80% is not based on the best available science and is not supported by any of the best management practices or applicable educational resources.
Rationale:
We believe that high irrigation efficiency can be reached with an evapotranspiration adjustment factor of 80%. According to the EPA, many irrigation systems are using approximately 50% more water than what is needed by the landscape. Implementing 80% ETAF will meet and surpass the goals set forth by the WaterSense program of 20% water-use savings.
Suggested Change (or Language):
4.1.1.2 Option 2 – Landscape design shall be developed using the water budget tool based on an 80 % evapotranspiration adjustment factor.
Topic:
Alternative water supplies for landscape irrigation
Comment:
The current draft is silent about incorporating the use of alternative water supplies and the addition of this section would provide an excellent opportunity to promote the use of such resources for landscape irrigation.
Rationale:
In addition to lessening the demand on domestic potable water, a goal of the EPA WaterSense program, using alternative supplies can become part of a comprehensive disposal solution as natural plant processes aid in cleansing effluent, grey or other undrinkable water before its ultimate return to the hydrologic cycle.
Suggested Change (or Language):
The specification should include an option, or incentives, to use alternate, non-potable water for supplemental irrigation. All water sources must meet locally applicable standards and codes. Sources of such water could be untreated surface waters, wells, treated waste water, site collected grey water, captured rain/storm water or other reclaimed water meeting locally applicable standards and codes. Because of potential poor water quality, consideration should be made to accommodate the need for additional leaching fractions deemed appropriate to make the water useable in the landscape.
Topic:
4.1.2 Turfgrass – Turfgrass shall not be installed in strips less than 4 feet wide.
Comment:
We believe that this section is not based on the best available science and that all plant material (turfgrass, trees, shrubs, etc.) in strips less than four feet wide can be irrigated efficiently, if proper design and installation practices and manufacturer recommendations are employed during installation and best management practices are performed when scheduling and operating irrigation systems. We recommend the removal of this restriction and urge the EPA to employ performance-based criteria, rather than the prescriptive approach currently taken in the draft, to determine irrigation efficiency in these areas.
Rationale:
The choice of plant material in the landscape should take geography, climate, local codes and requirements into consideration. In some areas of the United States four feet wide strips of turf may be inappropriate, in others it is a valuable part of the landscape that is much needed.
In many instances throughout the United States, areas of turfgrass of four feet wide are efficiently irrigated using methods such as drip, spray strip nozzles, and rotator-style nozzles, among others.
Suggested Change (or Language):
4.1.2 Turfgrass – Irrigation installed in strips less than 4 feet wide shall not result in overspray onto sidewalks, curbs, and roadways and shall be programmed to not create runoff.
Topic:
4.1.3 Slopes – Plantings other than turfgrass shall be installed on slopes in excess of 4 feet of horizontal run per 1 foot vertical rise (4:1).
Comment:
We believe that this section is not based on the best available science and that all plant material (turfgrass, trees, shrubs, etc.) installed on slopes in excess of 4 feet of horizontal run per 1 foot vertical rise can be irrigated efficiently, if proper design and installation practices and manufacturer recommendations are employed during installation and best management practices are performed when scheduling and operating irrigation systems. In many areas throughout the United States turfgrass is used as the primary plant material on four feet of horizontal run per one foot of vertical rise (4:1) slopes in landscapes. Arbitrarily eliminating the planting of turfgrass on these slopes with this reactionary, prescriptive approach would significantly adversely change the market, without any assurance of less water-use or elimination of run-off. We believe that plant material for 4:1 slopes should be selected based on local climate, geography and markets.
Furthermore, we recommend the elimination of prescriptive choices of irrigation methods and that the choice of plant materials in the landscape should be made by a landscape designer, as this would be the competent person to decide what the appropriate planting should be throughout all portions of the landscape.
Rationale:
Based on years of research, science and best management practice development, the best applicable science indicates that all plant material, including turfgrass, planted on 4:1 slopes in landscapes can be efficiently irrigated, with little to no increase in run-off.
Soil Erosion Control and Dust Stabilization
Turf protects nonrenewable soil resources from water and wind erosion. Turf's high shoot density and root mass stabilize surface soil, preventing erosion. Mowed turfgrasses are estimated to have shoot densities ranging from 75 million to greater than 20 billion shoots per hectare. During storms, turf's high biomass matrix provides resistance to lateral surface water flow, which slows otherwise potentially erosive water velocities. Quality turfgrass stands modify the overland process of water flow so that run-off is insignificant in all but the most intense rainfall events. Perennial turfgrasses offer one of the most cost-effective methods to control water and wind erosion of soil, reducing dust and mud problems around homes, schools, factories, and businesses. Turf can function as vegetative filter strips that greatly reduce the sediment transported into surface streams and rivers, especially when positioned down slope from cropland, mines, and animal production facilities. The reduction in sediment movement not only protects soil resources, but it also reduces sediment-linked nonpoint surface water pollution in rivers, lakes, and streams. (Beard, J.B. and R. L. Green. 1994. The Role of Turfgrasses in Environmental Protection and Their Benefits to Humans. J. Environ. Qual. 23:452-460.)
Irrigation systems have been and continue to be successfully installed and properly maintained throughout the United States not only on 4:1 slopes (15 degree angle), but also on slopes (of turfgrass and other plant material) at steeper inclines. Any limits of turfgrass and/or plant material on slopes have no scientific or best practice foundation and should not be implemented as part of the final specification.
Suggested Change (or Language):
4.1.3 Slopes – When irrigated turfgrass is installed on slopes in excess of 4 feet of horizontal run per 1 foot vertical rise (4:1), the irrigation system shall be designed, installed and programmed to match the soil infiltration rate and not create run-off.
Topic:
4.2 Irrigation Systems
Comment:
We believe in the value of a labeled WaterSense irrigation partner and feel that these new home specifications, in addition to promoting water use efficiency compared to conventional home should be a tool to expand the label’s value. EPA has removed the WaterSense Partner as designer and installer from the original draft citing issues related to “cost” and “availability”. The Irrigation Association and others have worked and continue to work toward expanding the number of WaterSense partners available to install and audit irrigation systems. However, we would like to see more expanded data regarding the claim that there is a significant difference in cost between a WaterSense labeled and non-labeled irrigation professional especially when compared to best practice-approaches vs.
We recommend that the EPA should implement a requirement that all irrigation systems installed upon a WaterSense labeled new home be designed, installed and audited by a WaterSense labeled irrigation partner.
Rationale:
As a public-private partnership, the WaterSense program’s irrigation partner label continues to grow throughout the irrigation industry, thus increasing the amount of efficient irrigation education and best management practice implementation throughout the United States. We agree with the EPA in standing behind excellence in efficient irrigation and feels that an essential tool to ensure that the irrigation partner label enjoys a high brand value is through the promotion of the label through the WaterSense specifications for new homes.
We support concept of the WaterSense irrigation partner label. According to the EPA, “…all too often, landscape irrigation wastes water—up to 1.5 billion gallons every day across the country. WaterSense irrigation partners can help you reduce your water consumption, save money, and maintain a healthy and beautiful landscape...” The EPA continues by stating “…when every drop counts, we count on our partners....” An efficient irrigation system is multi-faceted; it needs high-level competence, best available technology and regular maintenance to ensure efficiency. We urge the EPA to stand behind the labeled partners, as they have done the labeled products, through the specifications for new homes.
Suggested Change (or Language):
4.2.10 Irrigation Partner Requirement – The WaterSense program believes in the quality of work associated with the WaterSense label. All irrigation systems shall be designed, installed inspected and audited by a WaterSense labeled irrigation partner.
Topic:
4.2.1 Post-installation audit – All irrigation systems shall be audited by a WaterSense irrigation partner. A listing of irrigation partners by state can be found at www.epa.gov/watersense/pp/lists/irr_partners.htm.
Comment:
Irrigation system audits are an important component of any water-use savings program.
Though calculating distribution uniformity (DU) does measure how well water is applied to a landscape; it does not calculate efficiency. We maintain that the WaterSense program can be successful in significant water-use savings in new homes if a visual inspection is conducted on all installed irrigation systems and full audits conducted at random, with the irrigation system designer, installer and builder partner not knowing whether or not a full audit will be performed at the time of installation.
Rationale:
Variable conditions, including weather, play an important role when calculating DU. Weather in many areas often delays the test for days, sometimes weeks, until conditions allow a test to be performed. When there is a re-inspection/co-inspection required, this process may be delayed even further. If efficient products and services already included within the criteria, an assumption for high distribution uniformity exists. The goals of the Water-Efficient Single-Family New Home Specification will be achieved without having to calculate each irrigation system’s DU. DU measures how evenly water is applied to an area, not the rate of application. Water savings will be achieved through proper irrigation scheduling.
We do believe in the use of proper audits and believes that “spot-checking” irrigation systems through a traditional audit protocol will allow the program to keep the high integrity it is striving to achieve without increasing costs and the likelihood of significant delays in the labeling process.
Suggested Change (or Language):
4.2.1 Post-installation audit – All irrigation systems shall be visually inspected by a WaterSense irrigation partner. All audits conducted on an installed irrigation system shall be conducted on a random basis and should be conducted by a WaterSense partner who is not the installer of the irrigation system. The irrigation system designer, installer and the WaterSense builder partner shall not be aware of whether or not a full audit protocol or a visual audit will be conducted on the system. A listing of irrigation partners by state can be found at www.epa.gov/watersense/pp/lists/irr_partners.htm.
Topic:
4.2.4 Distribution uniformity – Irrigation systems shall achieve a lower quarter distribution uniformity (DULQ) of 70 percent or greater. Distribution uniformity will be measured during the post-installation audit.
Comment:
EPA can meet the goal of more than 20% water savings through a specification for the largest turf area to be a DULQ of .63 or greater.
Rationale:
The chart below, referenced from (http://www.ncwcd.org/ims/ims_info/SummaryEvaluationSprinklerSystems.pdf), represents the lower quarter distribution uniformity results from audits performed on residential sprinkler systems as well as large commercial type projects. Over 6800 audits are represented in this table with the average results shown.
Sprinkler System Performance
Residences |
Fixed Spray |
Rotors |
|||||||
Location |
# of Audits |
Avg. DULQ % |
Range % |
Avg. PR (in/hr) |
Range (in/hr) |
Avg. DULQ % |
Range % |
Avg. PR (in/hr) |
Range (in/hr) |
Utah |
4500 |
52 |
1.4 |
.70-3.70 |
58 |
.70 |
.10-2.30 |
||
Utah USU |
164 |
52 |
18-80 |
1.57 |
.50-3.20 |
49 |
15-86 |
.76 |
.20-1.70 |
Colorado |
973 |
53 |
20-89 |
1.34 |
.22-4.06 |
54 |
19-92 |
.62 |
.12-1.60 |
Oregon |
398 |
55* |
54* |
||||||
Florida |
576 |
54 |
11-89 |
||||||
U of FL Case Study |
19 |
40 |
48 |
||||||
California |
19 |
41 |
16-54 |
1.61 |
.66-2.97 |
||||
Commercial |
Fixed Spray |
Rotors |
|||||||
Location |
# of Audits |
Avg. DULQ% |
Range % |
Avg. PR (in/hr) |
Range (in/hr) |
Avg. DULQ |
Range % |
Avg. PR (in/hr) |
Range (in/hr) |
Utah |
166 |
55 |
7-82 |
1.49 |
.26-3.10 |
55 |
8-84 |
.74 |
.13-2.46 |
Colorado |
20 |
52 |
6-77 |
1.36 |
.60-2.12 |
50 |
3-88 |
.60 |
.10-1.12 |
Arizona |
7 |
41 |
20-56 |
.76 |
.57-.92 |
||||
Texas |
6 |
58 |
27-79 |
||||||
* reflects the lower-third distribution uniformity information of 61 and 60 reduced by 6 points (weighted average)
According to the data used in the table above, the weighted average DULQ for residential sprinkler systems is .524 and this is for the visually best performing sprinkler zones when the auditor selected a zone to do a catch can test. Case studies from Florida and California shows even lower DU but these audits were for the entire turf area, not the visually best sprinkler zones.
Using the EPA WaterSense goal to decrease water use by 20%, the DULQ of .524 x.20 = .105. The proposed value for sprinkler uniformity would be .629 rounded to .63. This will represent a significant improvement because of the challenges of achieving high uniformity on small, curvilinear turf areas that will be typical in the proposed specification. The audit of the sprinkler system should be on the largest turf area and the DULQ calculated for that area.
Suggested Change (or Language):
4.2.4 Distribution uniformity – Irrigation systems shall achieve a lower quarter distribution uniformity (DULQ) of .63 or greater. When an audit is performed, distribution uniformity will be measured on the largest turf area during the post-installation audit.
Topic:
4.2.5 Rainfall shutoff device – Irrigation systems shall be equipped with technology that inhibits or interrupts operation of the irrigation system during periods of rainfall (e.g., rain sensors).
Comment:
We support the inclusion of rainfall shutoff technologies.
Rationale:
N/A
Suggested Change (or Language):
N/A
Topic:
4.2.6 Irrigation controllers
Comment:
We support the inclusion of “smart controllers” in installed irrigation systems.
Rationale:
Smart controllers are an integral part of any efficient irrigation system.
Overall water usage in a landscape can be reduced with proper installation and programming of a smart controller.
Suggested Change (or Language):
4.2.6 Irrigation controllers –Irrigation systems shall be equipped with irrigation smart control technology.
Topic:
4.2.7 Sprinkler irrigation – Sprinkler irrigation, other than as components of a microirrigation system, shall not be used to water plantings other than maintained turfgrass. Sprinkler heads shall have a 4-inch or greater popup height and matched precipitation nozzles.
Comment:
There are many variables that are taken into consideration when determining the best and most efficient way to irrigate plant material in a landscape. Climate, geography, location in the landscape, etc., all play major roles and the responsibility should be placed the irrigation designer to determine the best type of irrigation for each portion of the landscape.
Rationale:
Certified irrigation professionals should have the flexibility to make the correct determination for each individual site and location.
Suggested Change (or Language):
Sprinkler and microirrigation installed in turfgrass and other plant material shall not result in overspray onto sidewalks, curbs, and roadways and shall be programmed to not create run-off.
Topic:
Water Meters
Comment:
Any voluntary water-use savings program should include the use of water meters.
Rationale:
Water meters are not required in all areas throughout the United States. The program should also promote using water wisely, which includes accurately knowing how much water has been used.
Water management is simply not possible without water measurement.
Suggested Change (or Language):
Water Meters for Irrigation Systems – The WaterSense labeled new home shall include the installation of a separate, dedicated water meter, sub-meter or flow sensor that meets applicable local standards or otherwise measures water use in billing units used by the local utility. In the event such use is not monitored by the local utility, measurement units in either gallons or cubic feet are acceptable.
Topic:
Soils
Comment:
A key component to landscape design and water-use efficiency in a landscape is appropriate soil preparation. Neglecting its inclusion in the final specification is equitable to neglecting the key component to ensuring the landscape can thrive in a water efficient manner.
Rationale:
Soil is the reservoir that both stores and delivers water and nutrients to plants as well as the support structure for root development. Many of the reactionary proposals set forth in these specifications (including but not limited to 40% turfgrass restriction, 4:1 turfgrass slope restriction, etc.) would not be needed if performance criteria were put forward and the proper soil preparation were included in the specification.
Suggested Change (or Language):
Soils – During the construction process, the WaterSense builder partner shall minimize site disturbance to preserve existing topsoil. The property’s landscapable area shall receive appropriate soil preparation according to locally accepted best practices including soil amendments and tillage requirements to create an acceptable planting medium for all plant material, including shrubs, turfgrass, flowers and trees. Conformity to soil preparation requirements shall be verified by a WaterSense program inspector, referencing the criteria set forth by the WaterSense Water-Efficient Single-Family New Home Specification guidelines and inspection checklist.
Topic:
The Use of the Words “If Installed”
Comment:
Throughout the draft specifications, the words “if installed” are associated to the installation of irrigation systems. The words “if installed” should be removed from the specification.
Rationale:
Irrigation systems are the only equipment referenced in the specification that is singled out by stating “if installed.”
Suggested Change (or Language):
Remove “if installed” and replace with language referencing “installed irrigation systems.”
Topic:
Definition of Landscapable Area
Comment:
The definition in the revised draft, though favorable to the landscape community, is confusing as it is not a widely-used definition. The specification should revert to the original definition as stated in the original draft specification. Due to the changes this will cause within the outdoor criteria, we urge the EPA to accept the recommended changes throughout this document, in addition to the recommended definition change.
Rationale:
The definition of “landscapable area” as the building lot area not under the roof is not based on science nor is it the market accepted definition of “landscapable area.
Suggested Change (or Language):
Landscapable Area: The area of a site less the building area, driveways, paved walkways, pools and spas, natural water features, and hardscapes such as decks and patios.
Topic:
Water Budget Calculator – Peak Watering Month
Comment:
When performing steps 1B and 2A, it should be more clearly stated to use the same peak month data in each area. Also, it should state that the peak watering month in each section should be the same month to avoid any confusion that may occur.
Rationale:
The data entered into the calculator may be misapplied, thus providing incorrect data at the outset.
Suggested Change (or Language):
Explicitly state, in detail, that the peak watering month data should be used in each step and that the same month’s data needs to be used to determine the LWA and LWR.
Topic:
Water Budget Calculator – Run Time Multiplier (RTM)
Comment:
Run Time Multiplier should be defined as 1/[.4 (0.6 x DULQ)].
Rationale:
The method for determining Run Time Multiplier (RTM) is stated incorrectly in the Water Budget Tool as 1/DULQ. The correct method would be to use the equation as defined in the document Landscape Irrigation Scheduling and Water Management (IA 2005), which is 1 / .4 (.6 x DULQ).
Suggested Change (or Language):
Run time multiplier (RTM) – 1/[.4 (0.6 x DULQ)] (Landscape Irrigation Scheduling and Water Management IA 2005).
Topic:
Water Budget Calculator – Distribution Uniformity (DU)
Comment:
The distribution uniformity for the new home specification should be .63 and should likewise be used in the water budget calculator so that the water budget tool reflects the performance standard for the irrigation system.
Rationale:
Distribution uniformity for the water budget calculator should match the specification for acceptable DU. Currently the calculator uses .65 but the specification calls for .70.
Suggested Change (or Language):
Change DULQ from .65 to .63, as recommended by the Irrigation Association.
Topic:
Irrigation Audit Guidelines – Data
Comment:
The WaterSense irrigation audit guidelines should reflect the changes recommended as part of the WaterSense Specifications for New Homes.
Rationale:
There are many suggestions we have put forth that have bearing on the specifics of the irrigation audit guidelines. In order for there to be uniformity throughout the specifications, the EPA should reflect the changes in the guidelines as well as the specifications.
Suggested Change (or Language):
Incorporate the recommended changes in the audit guidelines as well as the Specifications for New Homes.
Topic:
Irrigation Audit Guidelines
Comment:
The Irrigation Association has developed a set of minimum guidelines to create a standardized procedure to perform an audit of a landscape irrigation system. These guidelines were published in May 2009 and ASABE standards have been reviewed and incorporated wherever possible. Consultation and review of the guidelines has been conducted with many irrigation auditors, contractors, statisticians, educators, irrigation consultants and the Irrigation Association Certification Board. We urge the EPA to take the following changes into consideration for those irrigation systems that will be audited as part of the labeling process.
Rationale:
The guidelines were developed by the Irrigation Association and are intended to function as recommendations in the auditing of landscape irrigation systems. They have been designed to aid irrigation professionals in fieldwork procedures, techniques and performance calculations.
Recommendations and projections from the guidelines and their accuracy depend upon the quality of measurements and data provided by the individual user. It should be pointed out, the Irrigation Association makes no warranty, implied or expressed, as to the results obtained from these proposed procedures.
Suggested Change (or Language):
Implement the Irrigation Association recommended guidelines for an irrigation system audit, which can be found at http://www.irrigation.org/certification/pdf/AuditGuidelines_FINAL.pdf.
