EPA Will Maintain WaterSense Specifications and Measure Consumer Satisfaction with WaterSense Products

*Update on Federal Register Notice: Click here*

In a press statement released last week, the US Environmental Protection Agency (EPA) announced that it is not making any changes at this time in WaterSense® efficiency specifications for toilets, showerheads and faucets. However, EPA is now seeking public comment and information on consumer satisfaction with the WaterSense® program and its labeled products, according to a notice published in the Federal Register on Friday, April 10, 2020. The deadline for public comment is June 9, 2020.

EPA is following up on President Trump’s frequent complaints that efficient toilets, faucets and showerheads don’t work. “People are flushing toilets 10 times, 15 times, as opposed to once,” the President said in December, adding that he had asked EPA to look into the federal efficiency standards and WaterSense® product specifications.

It is vital that everyone concerned with efficient and sustainable water supplies tell the EPA that WaterSense® products work—that the American public is not interested in changing products that have saved more than 3.4 TRILLION gallons of water and more than $84.2 billion in water and energy bills. (Statistics are as of 2018, according to EPA.)

We are committed to demonstrating once again that the current generation of WaterSense® products meets consumer expectations while functioning properly at the flush volumes and flow rates specified. See the information below on what the Alliance for Water Efficiency is planning to do to help you make your voice heard.

Here’s what has happened

On April 7, 2020 EPA announced in a press release that it has completed a review of WaterSense® product performance criteria, and decided not to make any changes in WaterSense® specifications at this time. That review actually was required by America’s Water Infrastructure Act (AWIA), the 2018 law that statutorily authorized WaterSense® after the program had operated at EPA for 12 years at the direction of both Republican and Democratic administrations.

At the same time, however, EPA said it is seeking to measure consumer satisfaction with WaterSense® labeled products as a possible factor to be considered in future changes to WaterSense® specifications. On April 10, 2020, EPA published a notice in the Federal Register seeking public comment on this issue. Comments are due by June 9, 2020.

Here’s what we plan to do

We believe that it is urgent that everyone concerned with preserving the current WaterSense® product specifications – water utilities, government agencies, manufacturers, businesses and other stakeholders -- submit their views to EPA. We must make a compelling argument that any changes proposed to roll back WaterSense® specifications will have a damaging effect on both American-based industry, water supplies, and the environment.

To assist in our collective response, AWE will do the following steps within the next week:

1. Form a coalition of manufacturers, utilities, government agencies, codes and standards bodies, and environmental groups to coordinate messaging and present a united front on support of the current WaterSense® product specifications.
2. Prepare a factsheet that everyone can use in their comments to the Federal Register.
3. Prepare an official AWE response letter which others may sign on to if they wish (although we would prefer that everyone send their own separate letters).
4. Prepare a short report documenting what the 2016 Residential End Use Study actually found with respect to the issue of toilet double-flushing: that it was not a statistically significant finding for high efficiency toilets.
5. Develop a press strategy which will include reaching out to major media outlets and corporate sustainability managers.
6. Develop and distribute social media messaging that can be widely used by all stakeholders.
7. Distribute a Survey Monkey link to a short consumer satisfaction survey that utilities can send to their customers who received rebates on WaterSense® products.
8. Begin discussions with key members of Congress to ensure that they are fully aware of the risks inherent in changing federal water efficiency standards or the terms of the WaterSense® program authorization. This is imperative to start soon, because legislators could be vulnerable to a campaign to “get the government out of our bathrooms,” the same refrain that was used in a previous effort to change federal water efficiency standards in 1996.
9. Raise the funds necessary to undertake this campaign. Any and all contributions to this effort will be welcome.

Can we do all this in the midst of the COVID-19 pandemic?

Yes. It will be a little more difficult, but we can certainly do it. We cannot lose sight of the need for WaterSense® labeled products -- and for maintaining federal water efficiency standards -- even as we struggle to deal with this deadly virus. All of this Federal Register comment activity can be handled virtually. And we will do our utmost to make certain you are aware of all the developments in this important effort. Stay tuned.

In the meantime, make plans to submit your comments to EPA by June 9, 2020, and be sure to get into the process the necessary approvals for sending such a letter. We will help you with template letters beginning next week.

Here’s how to submit your comments to the Federal Register:

1. Go to: https://www.regulations.gov/comment?D=EPA-HQ-OW-2020-0026-0001
2. Submit your comments, which can include documents, audio or video material. Note than any multimedia must be accompanied by a written comment. The written comment is considered the official comment and should include discussion of all points the commenter wishes to make. We all need to work together on this, and your help will be invaluable. 

We all need to work together on this, and your help will be invaluable. Email us at office@a4we.org if you have any questions. 

Mary Ann Dickinson

President and CEO
Alliance for Water Efficiency