Call To Action: Supportive Comments are Needed on WaterSense Products by July 24

We need your help! Supportive comments are needed in response to a Federal Register notice. 

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. The deadline for comments has been extended to July 24, 2020.

The Alliance for Water Efficiency (AWE) fears that without strong public support for the WaterSense program and the performance of its labeled products, the Administration will change its mind and consider potentially disastrous changes for the WaterSense program and its product specifications.  AWE has drafted a very detailed comment letter which you can join. We also suggest that you send your own separate letter, as we wish to have a large number of supportive responses in the Federal Register record.  Here are points to emphasize in your letter:

1. WaterSense products are tested to ensure that they perform as specified. The rigorous testing required for all products bearing the WaterSense label is in itself a guarantee of product performance.
2. WaterSense products perform well and customers are satisfied with them. If you are a water utility that has issued rebates for WaterSense products, and if you have positive experiences to share about your customers’ satisfaction, please do so.
3. Current WaterSense product specification levels are important to maintain to help protect our nation’s water resources. WaterSense products make an important contribution to saving water in the United States, water that is desperately needed to be conserved in many water utility systems. If you are a water utility dealing with scarcity in your drinking water supplies, please make this point in your letter.
4. WaterSense products are widely available in the marketplace and manufacturers have worked hard to design these products to meet WaterSense specifications. There would be serious economic disruption to US plumbing manufacturers should this situation be required to change.

To also help you with your comment letter, we have prepared the following resources:

1. Download our Call to Action and distribute it as widely as you can.
2. Download our Factsheet with messages that you can use in your letter.
3. Download the Memorandum by Peter Mayer clarifying that data from the two Residential End Use Studies document the lack of increased flushing frequency with higher efficiency toilets. Toilets are not flushed any more now than they were in 1999.
4. Download our AWE letter, which was signed by 62 organizations, companies, and government entities and filed on July 22, 2020.
5. Download our AWE Showerhead Letter, which was filed on July 22, 2020.
6. View a copy of AWE's press release here.

AWE has requested a 60-day extention of the comment period. Click here to view the letter we sent to the EPA. 

Comments to the Federal Register are due July 24, 2020. Remember to do the following:

1. Identify in the subject line of your letter Docket ID No. EPA–HQ–OW–2020– 0026
2. Click here  to file your comments. 
3. Click here to send a copy of your letter to AWE!