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lotter on DSK11XQN23PROD with PROPOSALS1

Federal Register / Vol. 86, No. 138 / Thursday, July 22, 2021 / Proposed Rules number of spray units a single product might have and this interpretation undermined the very purpose of the statute. ASAP, No. 0086 at p.2 Hare also suggested that the aggregate flow rate would be too high to achieve water savings, thereby subverting the purported reason for the existence of the regulation. Hare, No. 0012
Other comments that DOE received on the August 2020 NOPR similarly discuss the impacts of the proposal on water and energy consumption. Numerous commenters stated that the proposal would increase water and energy consumption. California Investor Owned Utilities CA IOUs, Public Meeting Transcript at p. 13; Consumer Federation of America CFA, No.
0029; CFA, Public Meeting Transcript at p.14; Environment America,7 No. 0069
at p.1 Commenters specified that the proposal would waste water and energy because more energy would be needed to heat and pump the additional water.
Godwin, No. 0042; Hall, No. 0048;
Shaw, No. 0059; Gurley, No. 35 The Green Builder Coalition highlighted that the increased water flow and usage would increase energy usage from the municipal side used to pump and treat the increased water demands. Green Builder Coalition, Public Meeting Transcript at p.35
Commenters also addressed the current water shortages the country is facing. Numerous stakeholders commented that 40 of the 50 states are already confronting water shortages and that the proposal would increase consumption of drinking water, causing a severe impact on water supplies across the country. Walnut Valley Water District WVWD, No. 0051 at p.2;
Alliance for Water Efficiency, et al.8
AWE, et al., No. 0079 at p.3; Santa Clara Valley Water District Valley Water, No. 0076 at p.1; Bay Area Water Supply & Conservation Agency BAWSCA, No. 0050 at p.3 Lish explained that the Southwest was suffering a drought and that event after event illustrated the importance of reducing energy consumption that produces GHG emissions. Lish, No.
0057 Cohen also commented that the proposed changes would allow wasteful showers in a wide variety of configurations and increase consumption of drinking water at a time that wide regions of the country are 7 The Environment America comment received 10,184 signatories.
8 The AWE stakeholders submitted two versions of their stakeholder letter. The first version is comment No. 0072; the second letter, which includes additional signatures, is the version referenced throughout this document.

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already facing severe shortages. Cohen, No. 0036
Regarding water consumption, the CA
IOUs projected that a single-shower household shifting to a three-spray component product could increase the overall hot water use for that household by as much as 80%. CA IOUs, No. 0084
at p.6 Further, the CA IOUs estimated that if 10% of current showerheads were converted to three-spray component products, national residential hot water use, the second largest component of residential site energy consumption, could increase by as much as eight percent. CA IOUs, No. 0084 at p. 6
Similarly, Gary Klein Associates GKA stated that switching to a 2headed showering device increases hot water use by 40%, while switching to a 3-headed device increases it by 80%.
GKA, No. 0063 at p.11 Tucson Water also noted that changing the definition of showerhead effectively allowed multiple showerheads in the same stall, disregarding the existing federal standard of 2.5 gpm per shower and potentially doubling, or more, the amount of water used per shower.
Tuscan Water, No. 0053 at p. 1 And numerous commenters estimated that increasing the current federal legal standard of 2.5 gpm for the entire shower could result in a national water increase of 161 billion gallons in a single year. Valley Water, No. 0076 at p. 1; WVWD, No. 0051 at p.2; BAWSCA, No. 0050 at p.3; AWE, et al., No. 0079
at p.2
Texas Water Development Board TWDB stated that a change in the definition of showerhead would most likely lead to a reduction in the anticipated water savings and an increase in the states future municipal water demands. If these water savings are not achieved through conservation, future water demands will likely require additional, and more expensive, water management strategies and projects.
TWDB, No. 0074 at p.2
Commenters also discussed the impact of increased water consumption on energy use. Commenters estimated that for each 1 gpm increase in showerhead flow rate, national annual domestic water use would increase by 55 billion gallons and national annual energy use for that added hot water would increase by 25,000 billion Btu.
WVWD, No. 0051 at p.3; BAWSCA, No.
0050 at p.4; AWE, et al., No. 0079 at p.3
This use would, in turn, increase annual water and energy bills for American consumers by an estimated $1.14
billion. WVWD, No. 0051 at p.3;
BAWSCA, No. 0050 at p.4; AWE, et al., No. 0079 at p.3; Davis, No. 0064 at p.1
The Public Service Commission of
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Wisconsin PSC of Wisconsin stated that showerheads affect a customers energy use as showers represent the number one use of hot water inside the home and a reduction in shower water efficiency would require customers to use additional energy to heat water, increasing customers energy use and resulting energy bills. PSC of Wisconsin, No. 0061 at p.2
NPCC estimated that the Northwest currently has about 10 million showerheads and increasing the water use per shower by a factor of two or more would have a significant impact on the consumption of electricity, natural gas, and water, which would result in increased power supply needs.
NPCC, No. 0060 at p.2 NPCC stated the impacts of the proposed rule include increased electricity or natural gas consumption by the consumer, increased water use by the consumer, decreased utility by the consumer, increased burden and cost on the water utility, increased burden and cost on wastewater treatment facilities, possible changes to plumbing, and needs for larger water heater storage tanks. NPCC, No. 0060 at p.2 Similarly, the Sierra Club and Earthjustice commented that the proposal would result in greater consumption of hot and cold water, increasing fossil fuel and electricity consumption, and the accompanying emissions of air pollutants that harm the health and welfare of its members.
Sierra Club and Earthjustice, No. 0085
at p.1
The Los Angeles Department of Water and Power LADWP discussed how the proposed rulemaking would allow for devices that increase consumption of water, resulting in a greater need for energy, which in turn would generate more GHGs that would not be produced with fixtures that use less water.
LADWP stated this increase would be due to the embedded energy and GHG
impacts in treating, pumping, and moving water hundreds of miles across the state for delivery to LADWP and other suppliers. LADWP, No. 0066 at pp.23 Shaw also noted that an increase in the amount of energy used to heat water would increase the amount of carbon emitted into the atmosphere, exacerbating global warming. Shaw, No. 0059 The City of Santa Rosa Water Department Santa Rosa Water commented that loosening low flow standards would likely increase energy consumption and associated GHGs, which are a contributing factor to climate induced drought. Santa Rosa Water, No. 0037 at p.2 Additional stakeholders commented that adopting the thenproposed showerhead definition
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