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You would think that establishing a definition for “showerhead” would be simple. But, as the Department of Energy (DOE) is discovering after issuing a draft interpretive rule on the matter, nothing is simple when it comes to getting people wet.

Some showerhead background
Back in early 1994, under the Energy Policy and Conservation Act (EPCA) of 1975, all showerheads manufactured in the U.S. could have a maximum flow no greater than 2.5 gallons per minute (gpm) at 80 psi. The intent, of course, was to save water, particularly hot water and its associated energy use.

Over the years, plumbing manufacturers have gotten pretty creative about how people can get wet in their showers or baths. In recent years, the trend has been toward “multi-spray” systems, which have up to six “showerheads” (each of which complies with the 2.5 gpm flow maximum) and “waterfalls,” which aren’t really “showerheads” and therefore aren’t subject to the requirement (see photo: this Kohler shower system has 8 separate showerheads, each one complying with the 2.5 gpm maximum). These systems can use up to 20 gallons of water per minute, just for one person. And even though the actual installation number for these DOE-dodging plumbing fixtures is relatively low, they represent an important, high-end product for plumbing manufacturers. Manufacturers erupt over new ruling
When DOE quietly issued a draft interpretive ruling earlier this year that essentially made these systems illegal, the water world erupted. The ruling said:

  1.  “…a showerhead is any [emphasis added] plumbing fitting that is designed to direct water onto a bather.”
  2. “…the Department will find a showerhead to be noncompliant with EPCA’s maximum water use standard if the showerhead’s standard components, operating in their maximum design flow configuration, taken together, use in excess of 2.5 gpm when flowing at 80 psi, even if each component individually does not exceed 2.5 gpm.”

Bye-bye “multi-spray” and “waterfall” direct-water-to-bather devices.

Water conservation community not happy either
It’s not just the plumbing manufacturers but also the water conservation community and water conservation experts who are upset with the DOE showerhead rule. It all stems from the key word “interpretive”—both camps agree that DOE should have invited them to comment on this “interpretation,” which they say actually represents a rule change.

Here is what DOE says about its action in the draft rule itself:

“This draft interpretative rule represents the Department’s interpretation of its existing regulations and is exempt from the notice and comment requirements of the Administrative Procedure Act. See 5 U.S.C. § 553(b)(A).“

In other words, DOE did not need to treat this rule as a “substantive” rule change, an approach with exacting and lengthy requirements for input from the outside. So plumbing manufacturers and trade industry groups are upset because they consider this change to be more than a little bit substantive and one in which they should have a say (see the trade industry letter to DOE Secretary Chu opposing the interpretive rule affecting multiple showerhead systems).

Water conservationists are upset for the same reason, but from a different side of the issue—they’re quite certain that manufacturers will manage to find loopholes. “This is a substantive change and working out all the definitions and conditions to make sure the language is watertight will take a lot of effort from a lot of folks,” says water expert John Koeller, P.E. “And frankly, lots of hard work has been done on this topic within ASHRAE 189.1 (a code-ready green building standard) and the IAPMO Green Building Supplement, work that is not reflected in the DOE interpretive rule.”

One source within the plumbing industry who asked not to be named said, “I know that DOE is way behind on its rulemaking and is even under a consent decree including this particular rule, but this is not the way to get caught up.”

Rule will harm the elderly? NAHB goes too far
Of course, every rule change brings along a few fear mongerers. I was flabbergasted to get a press release from the National Association of Home Builders (NAHB) entitled, “DOE Showerhead Rule Limits Choices for Elderly and Disabled, Says NAHB.” The release included this quote from current NAHB President Bob Jones:

“This is going to make it much more difficult for older Americans to live independently. Under the new definition, replacing a traditional, single showerhead with one that includes a flexible hose to take a shower while seated will result in half the water pressure for each—which would be too weak for either one.”

This sort of overstatement undermines NAHB’s credibility and the legitimate concerns the building industry has with the nature of the rule change. I contacted Marsha Mazz, the Technical Assistance Coordinator for the U.S. Access Board, the agency that handles accessibility issues for the federal government. “We don’t see it as a disability issue at all,” stated Mazz. “People with     disabilities will not use both showerheads simultaneously and all the combination hand-held/mounted showerheads of which we are aware have a diverter that directs all of the flow to one head or the other.”

NAHB’s e-release (and the NAHB letter to DOE regarding the rule, supplied by NAHB to BuildingGreen) goes on to express the same legitimate concerns expressed in the trade letter above. NAHB should have stuck to that line; the unfortunate title and quote lands them squarely under a compliant showerhead, fully dressed.

A bit of good news on WaterSense

Meanwhile, the U.S. Environmental Protection Agency’s (EPA’s) WaterSense® program is merrily proceeding on its way to market its WaterSense labeled product and new homes, using its specification for water-efficient showerheads and shower compartments—a specification achieved by consensus. And it is not luck but hard and intelligent work that resulted in specification language that holds water and aligns well with the DOE draft rule, ASHRAE 189.1, and the IAPMO Green Building Supplement.
 

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Comments

1 This is only marginally relat posted by Buzz on 07/07/2010 at 02:58 pm

This is only marginally related, but want to note I recently installed a Delta RP51032 Water Efficient Shower Head, and want to highly recommend it. 1.5 gpm and feels like 2-3 times that. Also fully enclosed the shower, which besides feeling like a steam shower, dramatically raises the air temperature thus lowering the required water temp for the same comfort level. Some ideas actually work.

2 The Responsible Bathroom Wate posted by Grethcen Monette on 07/08/2010 at 04:36 am

The Responsible Bathroom Water Conservation Tour, sponsored by American Standard®, will bring its water-conservation message cities all across the county. The Responsible Bathroom Water Conservation Tour will feature both economic and ecological points in a 44-foot-long, walk-through mobile showroom and calculations of how much water and money consumers can save with efficient bathroom products. Water shortages will hit 36 states in the U.S. by 2013. Many communities are already experiencing water shortages, and this emerging topic will grow in importance with each passing year. At the same time, 78% of consumers are looking for ways to reduce their household utility bills, including water bills. Buying and building green saves money. Based on an average four-person household, using water-saving bathroom products could amount to an annual savings of $293 in water costs and 48,326 gallons of water. Visit www.theresponsiblebathroomtour.com to see when the mobile showroom is coming to your town.

3 Bill, The issue of water use posted by Alex Wilson on 07/26/2010 at 11:07 am

Bill, The issue of water use by thermal-electric plants (coal, nuclear, gas) is a very important one, but the water-use figure you quote is misleading. The vast majority of that water used for cooling electric turbines is returned to the source (be it a river or lake or estuary). The key issue is the EVAPORATIVE loss from cooling power plants. Evaporative losses are significant, but I think they're less than 5% of the total water use by these plants.

4 Thanks, Bill, for putting thi posted by Tony Marshallsay on 07/26/2010 at 08:32 am

Thanks, Bill, for putting this into perspective. Knee-jerk reactions against the introduction of water-saving regulations by any type of government, under the banner of infringement of individual liberty, aren't going to change the facts: if we don't start saving fresh water worldwide by all means, there will be real water wars instead of the present complaints of water poaching at all levels of society (See a recent BBC World News program on agriculture in Pakistan which used water from rivers with headwaters in India). But don't just look at personal water use - use the Web to see just how much water is used to produce our "Western" food, much of which is wasted; and remember that water tariffs are already encouraging industries to look at ways of reducing the huge amounts they use - take "zero blowdown", for example. This system is reducing the fresh water demand of many of the large air-conditioning plants in the USA which depend upon cooling towers that together suck up and evaporate millions, more likely billions of gallons daily. It helps but, if the water availability drops drastically, there will eventually have to be a choice between keeping cool or surviving... Of course, these plants could change to air-cooled equipment; but that is less efficient, so needs more electricity for the same cooling power, more fuel burn at the power station, and more CO2 to contribute to heating up the atmosphere... By the way, Las Vegas doesn't only ban artificial lakes and control watering: it has also actively encouraged the use of indigenous plants for gardens instead of water-hungry grass lawns which can demand 20 liters per square meter (4.4 US gal per square yard) per day in summer. And in Australia, during the recent long drought, two-minute showers were the norm in affected areas.

5 Not sure if this is off topic posted by Bill Swanson on 07/26/2010 at 10:46 am

Not sure if this is off topic but I looked up water use in the US by category and Thermoelectric power generation uses 49% of the total water consumed, per USGS website 2005 numbers. A quick look on the EIA website 2005 numbers, divide annual water use by annual coal/nuclear energy produced and I get 26 gallons of water for every 1 kwh of energy produced. I've never seen anyone express energy in gallons of water before.

6 It's difficult to find inform posted by Bill Swanson on 07/27/2010 at 04:42 am

It's difficult to find information on what's in power plant discharge water. I don't think it's readily reusable as fresh source water. Maybe for industrial use or irrigation. I found an article talking about lead, arsenic and barium contained in coal plant discharge water. One of the side effects of clean air.http://www.nytimes.com/2009/10/13/us/13water.html No idea what's might be in nuclear plant discharge water.

7 The comments debating regulat posted by Chris Liddle on 09/13/2010 at 11:28 am

The comments debating regulations for shower-head design. These limitations are interesting after reading the water and energy posting. if it really takes 1800 gallons to produce a one pound steak a couple can feel virtuous about a long shower in their double shower after a vegetarian meal!

I am curious if the actual energy and water use patterns of these elaborate bathrooms has been studied. Perhaps these fancy fixtures are rarely used. Certainly the trend is for larger footprints expanding from perhaps 5'x 7' bath units 30 years ago to 100SF or more today. The functions and desired fixtures of these spaces have also expanded. Double shower heads may turn out to be like double sinks in Master Baths, they don't use more water do they? I would guess that jetted bathtubs probably use more water and energy.

8 Since when is the gov't so co posted by John on 07/09/2010 at 05:23 am

Since when is the gov't so concerned about how I shower in my house? And what makes them think I shower alone? I need 4 shower heads; one for each of us. Next thing you know, they will be limiting the temperature I can set my A/C.

P.S. Working around government over regulation to pursue happiness is the American way.

Live Free, Shower Wet

9 California just issued it's n posted by Jim Gunshinan on 07/09/2010 at 02:08 pm

California just issued it's new Green Building Standards to begin on 2011. Here's a part of it:

4.303.2 Multiple showerheads serving one shower. When single shower fixtures are served by more than one showerhead, the combined flow rate of all the showerheads shall not exceed the maximum flow rates specified in the 20% reduction column contained in Table 4.303.2 or the shower shall be designed to only allow one showerhead to be in operation at a time.

According to Table 4.303.2, the limit for showerheads, single or multiple combined, is 2.0 gallons/minute. Haven't yet heard much of a response from builders...

10 John: You need to lighten up. posted by Major on 07/09/2010 at 09:20 am

John: You need to lighten up. The ‘government’ is not really concerned with how you shower. The government is comprised of mostly well-meaning individuals like you and me. These people also take showers, eat meat, take medicine, and drive on interstate highways (just to point out a few things affected by government standards). A lot of us want the government to have a role in setting standards so we know how a product performs with respect to metrics such as safety, efficiency, consumption, etc. If you want to use 40 gallons to shower, eat meat processed by your uncle, ingest medicine made by a neighbor, or drive on substandard roads, you are free to do that. There is usually a way around a standard, and I hope it costs you a lot because the small price we have for having standards far outweighs the cost of having no standard. For example, I like knowing that my USB drive will fit anybody else’s USB and I don’t need to have 4 conductors hanging off my devices to be twisted together. I like knowing that all my 110-volt electronics will work on Europe’s 220-volt system with a simple adaptor plug. I like knowing that if I want to exceed the shower standard, I can, but the standard is telling me that I’m exceeding a consensus. Most of all, I Iike knowing that when I’m driving, I’m pretty sure each oncoming car is not in my lane. Standards aren’t bad. I don’t work for any level of government and am not employed by any standards-setting organization; I’m just a schmuck who is also a realist.

11 I can see both sides of the a posted by Indiana GC on 07/15/2010 at 11:28 am

I can see both sides of the argument, but where does it end? Water rationing? You will be allotted 5 minutes or 12.5 gallons per day per shower. Buying others water credits for those who enjoy a leisurely shower. Sometimes it' seems as though we can't get out of our own way. It's laughable and tragic all at the same time.

12 Jim, no need to get all into posted by Bill Swanson on 07/22/2010 at 05:01 am

Jim, no need to get all into the scary speech with "Zealots" talk. You can make your point without being weird.

Pure personal freedom is anarchy. If that's not something you want then government means there is some limits on what you can do. What side of the road you can drive on, or not able to trespass onto someone else's property. We can talk about how far we're willing to allow the government to limit our freedom but calling this an unwarranted intrusion on freedom is silly.

At least 36 States are facing water shortages. This appears like a reasonable cause to limit water usage. So let's try to talk with law makers about what are reasonable limits and what are unreasonable limits. If your opinion is no limits then you're removing yourself from the discussion. And as water shortages increase we may need to reconsider what is an unreasonable limit. Maybe backyard pools will be taxed or banned all together. Las Vegas has already banned new construction of artificial lakes in housing developments. Also controls what day of the week people can water their lawns.

Americans average 150 gallons of water a day. In the UK the average is 40 gallons per day. I think we have some ability to reduce our water usage.

Do we bury our heads in the sand and wait until water doesn't flow out of our faucet before we address the problem? An ounce of prevention is worth a pound of cure. Let's work on a solution rather than ignoring the problem exists.

13 This is clearly not about pub posted by Jim on 07/21/2010 at 04:44 pm

This is clearly not about public safety nor is it about any meaningful public policy goal - the numbers are just too small to matter. This is government overstepping its bounds and doing it in an unlawful way. Why is it acceptable for one citizen to fill and heat a hot tub or pool for recreational use while another is denied the right to the shower he/she desires? Zealots who think they have the right to determine what others should be "allowed" to do are a danger to this country. Where does it stop? They pick on showers in the smoke filled room because they can. It is a sign of what they would do if the citizens of this country allow them to. This is an un_warranted intrusion into personal freedom and must be stopped.

14 It’s not as if you are going posted by Farrell Mackennon on 12/16/2013 at 11:16 pm

It’s not as if you are going to get busted for using too much water is it? How are they going to be able to check such a thing unless they come and visit you whilst you’re having a shower! There is no point talking about anarchy and so forth and Bill Swanson is right, there is a water shortage and we need to act on it now. People seem to think they turn on the tap and water magically appears with no thought as to where it’s coming from and how much of it there is. As a plumber I am shocked all the time about the amount of water householders’ use and how little they seem to know about water conservation.


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