URGENT! Department of Energy definition of Showerheads which may affect your future bathroom dreams, ideas and designs!
Curb Appeal Renovations completely agrees with the following statements and wants you to be aware of what is going on currently within the Department of Energy as the deadline for comment is June 18th.
Kohler, one of the largest plumbing manufacturers, is opposing actions being taken by the Department of Energy (DOE) proposing to define a showerhead. Along with the Plumbing Manufacturers Institute (PMI) and independently, Kohler will respond within the open comment period ending on Friday, June 18th. PMI’s response is contesting both the language and methodology by which the DOE is trying to redefine a showerhead. The language of the ruling is ambiguous, confusing and can be interpreted in a number of ways. The DOE states: “The Department interprets EPCA, its implementing regulations, and its test procedures to mean that a showerhead is any plumbing fitting1 that is designed to direct water onto a bather. The Department believes Congress intended to include all manner of showerheads when it set the maximum water use allowed under EPCA. Neither the definitions nor the test procedures cited above treat a showerhead differently based upon the shape, size, placement, or number of sprays or openings that it may have.
Accordingly, 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.”
1 The Standard defines a fitting as a “device designed to control and/or guide the flow of water.”
The DOE is acting without consultation with the industry or affected consumer groups, to make illegal the installation of shower systems that serve an important function in addressing legitimate, often medicinal and therapeutic needs. On a basic fundamental, philosophical level, Kohler firmly believes that the Department of Energy’s new ruling is an unnecessary, ineffectual and unwarranted intrusion by the federal government into the lives of families and individuals; some of whom have special needs for products that would be eliminated if this showerhead re-definition occurs. The American people should have the right to choose a shower system that best suits their personal hygiene requirements, and needs.
You can do your part to help stop this unnecessary government action by visiting the DOE website to learn more on the proposal and comment on how this proposal will negatively impact your life, the business of people you know and the industry as a whole. Deadline for comment is June 18th, 2010.
Comments and suggestions should be provided in WordPerfect, Microsoft Word, PDF, or text file format by sending an email to Showerhead_Guidance_Comments@hq.doe.gov. Please act now.