New Water Conservation for Shower heads
By Skip Walker
Based On Articles From Peter Yost, Green Building Adviser and Mike Mazga, PM Engineer
If implemented, a proposed a rule clarification from the Department of Energy would alter the way most in the bath plumbing fixture industry defines a “showerhead”. This new definition would potentially eliminate multi-head shower installations. In the proposal, the DOE “reinterprets” the definition of a showerhead to include any size, placement, or number of sprays provided they all come from one inlet. Under this new interpretation, the DOE “will find a showerhead non-compliant with the 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.” The re-definition would potentially allow only a single showerhead using no more than 2.5 gallons per minute of water per showering compartment — a move that would effectively ban multiple outlet shower systems.
According to a statement from DOE spokesperson Christina Kielich.“ DOE has received several complaints alleging that certain showerhead products exceed the federal water conservation standard,” “In the course of investigating these complaints, DOE discovered some confusion as to how the Department’s definition of ‘showerhead’ for water conservation purposes applied to new showerhead designs being marketed under names such as waterfalls, shower towers, rain heads, and shower systems. ... We note that DOE’s draft interpretation is not a rule change, but a clarification of the definition in our current regulation. It makes clear DOE’s view of how the standard for showerheads should be applied to that definition.”
Defining a “showerhead” would seem to be a simple thing. The Department of Energy (DOE) is discovering that nothing is simple when it comes to getting people wet.
Low Flow Showerhead History
Showers are the single largest water consuming fixture in most homes. 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 the regulations was to save water and the associated energy used to heat water.
The plumbing manufacturers became very creative in how they designed systems around the regulations. 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). There are rainfall shower systems with many individual nozzles, each nozzle may deliver up to 2.5 gpm. And then there are “waterfalls,” which aren’t really “showerheads” and therefore aren’t even subject to the requirement (see photos for examples of each). Some of these systems can use 10, 20 gallons of water per minute and more. This is just for one person. While the number of installation for these non-compliant plumbing fixtures is believed to be relatively low. However, they represent an important, high-end and high profit product for plumbing manufacturers.
The DOE quietly issued a draft interpretive ruling earlier this year that essentially made these systems illegal. The new 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 non-compliant 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.”
If the proposed change is adopted, the days of “multi-spray” and “waterfall” are essentially over.
Both Side of the Issue Are Unhappy.
The plumbing manufacturers dislike the rule changes because they take away an important profit center. Oddly, the water conservation community are upset with the DOE showerhead rule as well. Since the DOE is considering this an “interpretive” change, there is no required input period for public comment.
This 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).“
Because the DOE did not need to treat this rule as a “substantive” rule change, they can simply implement the new definition. A substantive change would have required an 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.
Water conservationists are upset for the same reason. The water conservation groups feel that the 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.”
A Property Inspectors Perspective
As general property inspectors, we are not required to perform complex calculations related to water heater sizing, etc. Personally though, when I am inspecting a property, I look at the water heater size in relation to the fixtures. This is a non-scientific, seat of the pants broad view. If I see a 40 or 50 gallon water heater and the property has multiple baths, some of which have multi-head showers or a jetted tub – I will probably note that the water heater may be too small to service potential demand under all conditions. Ditto for smaller tankless units. My assumption has always been that if the individual fixture components looked newer, they would conforming to the 2.5 GPM requirement. What I now realize is that the manufacturers have been skirting the rules. This means that water heaters “properly” sized using the CPC 2007 Table 5.1 could still be significantly undersized.
Both energy and water costs will continue to climb as our population increases. Understanding how older systems impact the resource consumption of the property will become more and more important as time goes on. It is clear that the government is finally beginning to make the efficient use of energy and other basic resources a priority. It should be expected that we will see tightening of all related regulations over the coming years.
About the author:
Skip Walker lives in the SF Bay Area and has performed over 2,600 paid inspections since becoming a CREIA member in 2003. Skip is both a CREIA Master Inspector and an ASHI Certified Inspector. Skip is an ICC Certified Residential Combination Building Inspector and a F.I.R.E. Certified Inspector. Skip is the past education chair for the Silicon Valley ASHI/CREIA Chapter. He is also CREIA’s State Secretary & Region Three Director. He also holds a California Real Estate Appraisal Trainee License. Skip may be reached at
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