California Urban Water Conservation Council Developing a Framework for an Alliance for Water Efficiency Issues & Options December 31, 2005 Report to the U.S. Environmental Protection Agency Alliance for Water Efficiency: Issues & Options DRAFT Report to the U.S. Environmental Protection Agency TTAABBLLEE OOFF CCOONNTTEENNTTSS Introduction ........................................................................................3 History of Water Efficiency ................................................................................ 3 Efficiency Trends and Issues............................................................................... 8 • Plumbing Standards............................................................................................8 • Plumbing Codes.................................................................................................9 • Product Labeling .............................................................................................11 • Green Building................................................................................................12 • Waterwiser....................................................................................................14 Why a National Water Efficiency Organization?........................................................18 • The Need for a National Platform.........................................................................18 • EPA Grant......................................................................................................19 • Project Tasks..................................................................................................20 Research on Efficiency Organization Structures...........................................21 Water Efficiency Organizations...........................................................................21 Energy efficiency Organizations..........................................................................27 Green Building and Other Relevant Organizations ....................................................31 Observations on Organizational Structure and Mission ...............................................32 Stakeholder Input ................................................................................35 Stakeholder Recruitment..................................................................................35 Workshops and Survey Results............................................................................36 Regional Workshops ........................................................................................37 Regional Workshop and Web Survey Results Summary................................................38 Conclusions and Recommendations......................................................................42 Focus Group Results........................................................................................44 Key Focus Group Findings .................................................................................45 Additional Observations....................................................................................45 Findings on Core Mission...................................................................................47 Findings on Function .......................................................................................47 California Urban Water Conservation Council 1 Alliance for Water Efficiency: Issues & Options DRAFT Report to the U.S. Environmental Protection Agency “Sister” Organization Interviews.........................................................................55 Structure and Governance for A National Organization..................................59 Choosing the Structure.....................................................................................59 Choosing the Name.........................................................................................60 Choosing the Mission Statement..........................................................................62 Choosing the Location......................................................................................63 Choosing the Board of Directors..........................................................................65 Recruiting Membership ....................................................................................66 Making Decisions............................................................................................67 Recommendations for Organization Functions.............................................69 1. Clearinghouse/Network ...............................................................................70 2. Plumbing and Standards...............................................................................77 3. Product Investigation, Testing, and Classification................................................79 4. Green Building Coordination..........................................................................81 5. Training for Conservation Professionals ............................................................83 6. Consumer Education...................................................................................85 7. Market Transformation and Labeling................................................................87 8. Advocacy and Legislative Action.....................................................................88 Recommendations for a Five Year Plan and Budget ......................................91 Appendix 1. Acknowledgements 2. Project Contract 3. Project Budget and Expenditures 4. Web Site Pages 5. Stakeholder Lists 6. Workshop and Survey Report 7. Focus Group Summary 8. Legal Analysis 9. Stakeholder Research Funding List 2 December 31, 2005 Alliance for Water Efficiency: Issues & Options DRAFT Report to the U.S. Environmental Protection Agency IINNTTRROODDUUCCTTIIOONN History of Water Efficiency During the last half of the twentieth century, robust economic growth and population expansion led US cities and towns to triple the amount of water withdrawn from natural sources such as rivers, lakes, and groundwater aquifers for public water supplies. From 1950 to 1980, the rate of these withdrawals increased more rapidly than population growth, resulting in substantially higher per capita consumption. Since 1980, however, the US has enjoyed stable to slightly declining per capita consumption of public supplies. These last two decades have seen urban water use become more efficient. Water use efficiency is no accident, and the scope and pace of efficiency improvements are the result of both economic and social factors as well as public policy. As the cost of public water and wastewater infrastructure has increasingly shifted back to states and localities, virtually every state in the nation has a stake in seeing water used more efficiently. Important federal goals –- including the provision of safe drinking water, the maintenance of economic competitiveness, and the protection of endangered species -- are also advanced by cost-effective improvements in water use efficiency. Efficiency in Response to Drought Although conditions during the Dust Bowl years of the 1930s remain the drought of record for many parts of the country, the last 50 years have seen severe multi-year droughts reoccur in many states. Northeastern states were struck by severe drought in 1964-65. The rapid depletion of water supplies for major urban centers was especially worrisome, and resulted in massive public education appeals to reduce water consumption. Unwashed New York City transit buses served as rolling billboards for the water conservation message. Such curtailment of water use, however, does not necessarily lead to long-term gains in water use efficiency. California experienced severe drought conditions during 1976-77. In addition to utility appeals for consumer conservation, this drought encouraged the reconsideration of the water consumption of household plumbing products. At the urging of water utilities, the American Society of Mechanical Engineers established a performance standard of 3.5 gallons per flush for a so-called “water saver” toilet in 1978. Over the next decade, this metric was incorporated into most state plumbing codes, gradually eliminating from the market the earlier designs using 5 to 7 gallons per flush. California also acted at this time to set a flow rate standard for California Urban Water Conservation Council 3 Alliance for Water Efficiency: Issues & Options DRAFT Report to the U.S. Environmental Protection Agency showerheads of 2.75 gallons per minute, in the interest of saving both energy and water. Technology did not remain static, however. Sensing an emerging demand for water-saving products, by the mid 1980s several US plumbing manufacturers introduced new models of toilets designed to operate with 6 liters, or 1.6 gallons, per flush. These products were designed to compete for efficiency-oriented customers in a market niche once occupied solely by European imports. Serious drought returned during 1987-93. Beginning on the West Coast, drought spread across much of the eastern half of the US by 1988. Severe drought conditions persisted in California and the Southeast well into the early 1990s. In 1988, Massachusetts became the first state to adopt a further tightening of water use standards for plumbing products, including a 1.6 gallon per flush standard for toilets, and this action was quickly followed by Connecticut, New York, California, Georgia, Texas, and a dozen other states. Facing a balkanized national market, US plumbing manufacturers and distributors joined with water utilities and environmental groups in supporting uniform national standards for new toilets, urinals, showerheads, faucets, and faucet aerators as part of the Energy Policy Act of 1992. Most of these standards took effect by 1994. Some members of the House of Representatives later advocated a repeal of these standards, but in April of 2000 a repeal bill was rejected by the Energy & Commerce Committee. An ad hoc coalition of water utilities, environmental groups, and plumbing manufacturers -- essentially the same coalition that supported enactment of the original standards –- worked diligently together for at least four years to help turn back this threat to water efficiency gains. Water Efficiency Co-Benefits with Energy Efficiency Oil supply disruptions and price spikes during the 1970s and 80s encouraged greater attention to the benefits of energy efficiency. One result was the enactment of the National Appliance Energy Conservation Act in 1987, which set specific energy efficiency standards for most major household appliances, as well as a framework for revising standards further. Residential dishwashers and residential clothes washers, which together account for about 25% of residential indoor water use, were both included in this program. A large portion of the energy use of clothes washers and dishwashers is derived from their use of hot water. Consequently, improvements in their water efficiency can contribute to reductions in energy consumption. In the case of new dishwashers, water consumption for all machines shipped from 1993 to 2004 declined in rough proportion to reductions in energy consumption. In the case of clothes washers, however, there are more paths to energy efficiency than simply water efficiency, and 4 December 31, 2005 Alliance for Water Efficiency: Issues & Options DRAFT Report to the U.S. Environmental Protection Agency early energy efficiency standards left many models on the market with little improvement in water efficiency. More recently, however, significantly improved energy efficiency standards were adopted in 2000 and scheduled to take effect in stages in 2004 and 2007. These standards, which were anticipated by the industry as early as 1994, are encouraging a resurgence of interest in horizontal axis washers and the development of more efficient agitation for top-loading vertical axis washers. Significant water savings will be achieved by most washers meeting the 2007 standards. The Energy Star program of voluntary labeling of energy efficient products has provided an additional incentive for manufacturers to produce products that are significantly more efficient than meeting the minimum standards. As of this writing, the Department of Energy has already approved incorporation of water efficiency criteria for Energy Star clothes washers, and is still actively considering eligibility criteria for Energy Star dishwashers. If approved, highly water efficient dishwashers are likely to join efficient clothes washers in gaining additional market share in the near future. Regulatory Drivers for Broader Efficiency Programs As water-efficient technology has improved and become more widely available, environmental problems exacerbated by high levels of water consumption or wastewater discharge have caught the attention of regulatory agencies. The water quality and wastewater treatment objectives of the Clean Water Act have been linked across the country to improved water use efficiency, and these linkages have led to pioneering water efficiency programs that have received national attention. Examples of these efforts are the cities of New York, San Diego, Los Angeles and San Jose: cities where wastewater treatment and water quality crises were resolved through implementation of water efficiency programs. During the postwar period, New York City saw three decades of steady growth in water consumption. By 1990, five of the city’s 14 wastewater treatment plants were exceeding the discharge volumes specified in state permits. New York State began to insist that proven water efficiency measures be written into permit extensions and consent decrees. The result has been an ambitious series of measures, including the elimination of unmetered service connections, the adoption of plumbing efficiency standards, an increased program for utility distribution system leak detection and repair, the installation of 30,000 hydrant locks, and a $300 million customer rebate program responsible for replacing 1.3 million inefficient toilets with efficient new models. From its peak in 1988 through 2003, New York City’s per capita water consumption has declined by 34% and its total water consumption by 26%. Wastewater discharges have been similarly reduced. California Urban Water Conservation Council 5 Alliance for Water Efficiency: Issues & Options DRAFT Report to the U.S. Environmental Protection Agency Wastewater treatment issues also lead to early water conservation programs in California, including San Jose, San Diego, and Los Angeles. The need to reduce excessive discharges led San Jose to pioneering work with residential water audits and plumbing retrofit kits in the mid 1980s. Los Angeles faced similar regulatory concerns over excessive discharges at the city-run Hyperion Wastewater Treatment Plant, one of the largest in the United States. In addition, a long-running challenge to the amount of water taken by the city from the Mono Lake basin was resolved by state regulators in 1995, increasing the need for the city to make more efficient use of its remaining water supplies. San Diego faced litigation to reduce ocean discharge of partially treated wastewater. Both cities developed comprehensive programs involving conservation pricing, separate metering for large landscape irrigation, and substantial customer rebates for water efficient products. San Diego undertook a complete plumbing retrofit of all city-owned facilities, from neighborhood centers to Qualcomm (Jack Murphy) Stadium. State regulatory proceedings concerning water quality in California’s Bay-Delta System led directly to a negotiated agreement on water conservation between major water utilities and environmental groups in 1991. The resulting “Memorandum of Understanding Regarding Urban Water Conservation in California” contains an enumerated list of Best Management Practices that all signatory water agencies -– now numbering over 200 –- agree to implement to the extent cost-effective on the utility system. Over $100 million per year is currently being spent by signatory agencies to implement these cost-effective BMPs. Elsewhere, the imperatives of interstate river basin allocations have encouraged local water efficiency programs in Virginia, Georgia, Illinois, Nevada, and Utah. The Delaware River Basin Commission, an interstate compact commission, was an early adopter of water conservation requirements for water suppliers under its jurisdiction in Delaware, New Jersey, New York, and Pennsylvania. Infrastructure Needs Encourage Greater Investments in Efficiency Perhaps the most forceful factor to emerge in recent years to encourage an expansion in water use efficiency is the growing awareness of the cost of maintaining the current level of water consumption. In 1997, the first national assessment of investment needs for drinking water infrastructure, along with an updated wastewater investment needs survey, were presented to Congress by the EPA. Taken together, these two reports identified measures costing nearly $280 billion that would be needed to protect public health and accommodate growth over the next 20 years. A significant portion of this investment -– over $200 billion of it –- would be for 6 December 31, 2005 Alliance for Water Efficiency: Issues & Options DRAFT Report to the U.S. Environmental Protection Agency facilities and equipment where the volume of water or wastewater flow affects their required size and cost.1* Subsequent needs surveys and additional analyses have validated these findings. In 2002, EPA’s landmark Gap Analysis report, using less limiting –- and more realistic –- criteria than previous needs surveys, found that drinking water and wastewater utilities are expected to face capital requirements of some $274 billion and $388 billion, respectively, through 2019. According to the EPA, the gap between necessary investments and current levels of revenue may reach $102 billion and $122 billion respectively. EPA has recognized that reductions in water demand can lead to the deferral or downsizing of water and wastewater capital projects. In a widely noticed speech to the water industry in January 2003, then Assistant Administrator Tracy Mehan referred to water efficiency as one of the “four pillars” of sustainable water infrastructure. Mehan spoke approvingly of cities that had reduced their water use by as much as 20% and not yet exhausted all their options. New policies have been put in place that underscore the importance of water use efficiency for managing infrastructure needs. In 2000, the Office of Water issued policy guidance clarifying that funds from the Clean Water State Revolving Funds may be used for water efficiency measures, including investments on the customer’s side of the water meter, as well as reasonable administrative costs. In 2003, this policy was reaffirmed and extended to the Drinking Water State Revolving Fund. Together, these two funds are the main source of ongoing capital assistance to the nation’s water and wastewater utilities. 1 For drinking water utilities, capital improvements pertaining to transmission, treatment, storage, and source waters are positively related to water demand, either average demand, peak demand, or both. For wastewater utilities, expenditures for secondary treatment, advanced treatment, interceptor sewers, and combined sewer overflow are positively related to the volume of wastewater flows. These relationships are not linear, but reduced demands will tend to reduce the capital costs of these types of works. California Urban Water Conservation Council 7 Alliance for Water Efficiency: Issues & Options DRAFT Report to the U.S. Environmental Protection Agency Efficiency Trends and Issues Plumbing Standards Plumbing Standards are a key avenue to advancing water efficiency in plumbing fixtures. The National Energy Policy Act sets maximum flow standards for showerheads, faucets, urinals, and toilets, but how those standards are manifested in fixtures is a function of standard setting. Since 1994, water utilities are increasingly becoming more aware of and involved in this standard setting process, but overall the water efficiency community needs a better understanding of how and why these standards function if they are to have an impact on improving water efficiency in the affected fixtures. The standards are developed and administered in a complex process. The American Society of Mechanical Engineers (ASME) and the International Association of Plumbing and Mechanical Officials (IAPMO) are both accredited by the American National Standards Institute (ANSI) to develop U.S. standards for plumbing fixtures and fittings. Within these organizations, the ASME A112 and IAPMO Z124 committees are developing and maintaining standards related to toilets, urinals, showerheads, faucets, pre-rinse spray valves, and other fixtures and fittings used in indoor plumbing systems. Standards committees and project teams are comprised of a variety of stakeholder interests, and are required by ANSI to maintain a “balance” of those interests. As such, these groups include representatives of manufacturers, laboratories, government, private sector consultants, and others. Unfortunately, with the exception of California’s water conservation interests, the water utility sector nationally has generally not been able to represent itself at the “standards table,” thus leaving these discussions largely to the manufacturers themselves. With more proactive involvement of water conservation interests, plumbing fixture standards could evolve toward more efficient products. Examples include reducing the urinal flush volume maximum from 1.0-gallons to 0.5-gallons, modifying the standard to enable the introduction of 1.0-liter flushing urinals, and refining the standard for pre-rinse spray valves. If implemented, each of these actions could significantly affect indoor water consumption throughout the country. In order to achieve such successes, however, the water conservation community would need to significantly increase its role in the national standards setting process. There are numerous committees that develop plumbing fixture standards, such as the following: 8 December 31, 2005 Alliance for Water Efficiency: Issues & Options DRAFT Report to the U.S. Environmental Protection Agency • ASME/ANSI A112.19.2 - Vitreous China Plumbing Fixtures • ASME/ANSI A112.19.5 - Trim For Water Closet Bowls, Tanks, and Urinals • ASME/ANSI A112.19.14 - Dual Flush for 6-liter Water Closets • ASME/ANSI A112.4.7 - Point of Use and Branch Water Sub-Metering Systems • ASME/ANSI A112.19.19 – Vitreous China Non-Water Urinals • ASME/ANSI A112.18.1 – Plumbing Supply Fittings • IAPMO/ANSI Z124 - Plastic Plumbing Fixtures Plumbing Codes In addition to Plumbing Standards, Plumbing and Building Codes play an important role in governing water efficient products. Codes are promulgated by code authorities and adopted by jurisdictions in order to protect the health and safety of the citizens. Whereas the national standards approved by the American National Standards Institute are voluntary consensus-based standards, the codes (which may or may not adopt the national standards by reference) are mandatory within the jurisdiction that adopts them. Several areas are of current interest to water-efficiency practitioners. For example, research is underway to investigate hot water distribution systems within residential dwellings. The ultimate goal is to amend the building codes to require that certain innovative design and construction practices be used in new residences in order to reduce the amount of energy lost (and water lost) currently being experienced with existing construction practices. A second area of current interest is that of non-water urinals, where language and technical provisions effectively prohibit their installation in many municipalities and areas. The process of amending plumbing codes to achieve resource efficiencies is laborious, usually contentious, and in need of support from the water stakeholders. Representation by the water utility interests in the plumbing code development process is necessary to ensure that water efficiency is considered a priority and to offset a trade reluctance to make any change that does not deal only with the health or safety of citizenry. Examples of past debates during the codes process include amendments that would allow for non-water consuming urinals, or that would provide for changes to construction practices relating to hot water piping in residential dwellings. Becoming engaged in the code development process is a necessary first step to addressing some of the inherent inefficiencies in existing water delivery systems and the code language itself. Like the standards process, the codes process is complex. There once were five different plumbing code development organizations in the U.S.; mergers have thankfully reduced this to only two organizations. The International Association of California Urban Water Conservation Council 9