What a difference a decade makes. Ten years ago plumbing industry interests clashed with those of environmentalists and water authorities in mandating 1.6 gpf toilets and other ultra-low-flow (ULF) plumbing products on a state-by-state basis. Manufacturers eventually were compelled to support federal legislation in order to avoid the confusion and expense of complying with a hodge-podge of state and local ULF laws. Now they have joined forces once again in fighting off a legislative initiative to rescind the national ULF mandates in effect for the last eight years.
As most of you know, Rep. Joseph Knollenberg (R-Mich.), claiming widespread consumer dissatisfaction with 1.6 gpf toilets, has introduced H.R. 859, which would repeal the plumbing products provisions of the 1992 Energy Policy Conservation Act (EPAct). The Knollenberg bill has more than 60 co-sponsors and at this writing is in the House Commerce Committee waiting for a hearing and floor action.
In response, the Plumbing Manufacturers Institute (PMI) and a consortium of water utilities and environmental groups funded a study called "Saving Water, Saving Dollars" (SWSD). The report documents interior water savings in excess of 15 percent from installation of 1.6 gpf toilets alone. When combined with other low-flow plumbing products and more efficient clothes washing machines, SWSD claims more than 30 percent water savings, thanks to the application of EPAct's water conservation provisions.
Most pointedly, SWSD takes issue with claims of widespread consumer dissatisfaction. "Anecdotal accounts of poor performance have been widely reported," says the study. "However, more systematic analyses of toilet performance and customer satisfaction leave little doubt that most 1.6 gpf toilets are performing to their owners' satisfaction." Their findings include:
- Austin. A survey of 250 participants in the Texas capital's program to provide free 1.6 gpf toilets to residents of traditionally low income zip codes found that 95 percent of them were either satisfied or very satisfied with their new toilets.
- Denver. A Denver water utility found 87 percent of participants in a 1.6 gpf toilet rebate program were satisfied with their new fixtures, while only 9 percent said they were not.
- San Diego. Annual samplings of some 1,000 consumers receiving rebates show that year after year 93 percent to 94 percent say they are "satisfied" or "very satisfied" with their 1.6 gpf units.
- Tampa. Regarding double flushing, bowl clogging, bowl cleanliness and mechanical problems, between 84 percent and 95 percent of 1.6 gpf owners in different categories reported that their new toilets performed as well or better than the water-hogging units that were replaced.
- Los Angeles. A Wirthlin Group customer satisfaction survey of more than 7,000 home owners and managers recorded the overall satisfaction level at 7.6 on a scale of 1 to 10, with 10 being "very satisfied." Of those responding, 31 percent said that they never double flush their new ULF toilets, while 33 percent said they never double flushed the toilet they replaced.
- Metropolitan Water District of Southern California. Studying 10 brands, a survey found satisfaction levels ranging from 3.6 to 4.46 on a 1 to 5 scale, with eight out of the 10 brands receiving ratings above 4.
- New York City. The nation's most ambitious toilet rebate program also featured the largest follow-up survey-some 60,000 random samplings. Response rates ranged from 73 percent for plumbers to 52 percent for building owners/managers, 29 percent for single-family homeowners and 15 percent for apartment residents. Plumbers were found to be most satisfied (4.1 on a 5-point scale), ranging downward to apartment dwellers at 2.9.
- American Water Works Association. A 1997 study recording more than 130,000 flushes in 584 residences in six cities found only modest increases in double flushing.
Disclaimers aside ...Though I support its aims, it should be noted that SWSD is a political document rather than pure scholarship. The report was authored by an organization called Potomac Resources, Inc., headed by Edward Osann, who as then head of the National Wildlife Federation was one of the chief lobbyists for ULF product laws back in the late 1980s and early '90s.
I think claims of 90 percent-plus satisfaction with 1.6 gpf units must be taken with a grain of salt. A close examination of the survey reveals methodology bound to bring about favorable results (such as focusing on low-income users whose main concern was saving money). Anecdotal or not, there have been more than sporadic complaints about 1.6 gpf performance over the years. Ask any plumber.
That being said, I'll reiterate some of the points I made while chastising Rep. Knollenberg in this column last October.
Performance shortcomings with ULF toilets are largely in the past. Performance has never been a problem with the pressure-assisted ULF toilets, and the gravity units keep getting better. The best 1.6 gpf units now being made are just as good or better flushers than the old 3.5 gpf toilets.
Some brands and models work better than others of course. SWSD acknowledges this. But the marketplace is the best way to sort out the good from the bad. It would be folly to repeal the federal law at this stage, especially because many states and local jurisdictions would undoubtedly keep their ULF mandates in place.
When the ULF plumbing product provisions went into effect in 1992, 48 percent of the U.S. population lived in states that already required installation of 1.6 gpf toilets. In addition, various municipalities followed suit with local regulations. Mostly these were states and communities with problematic water supplies, making conservation a high priority. Even if EPAct got repealed, they would likely keep their ULF regulations on the books. This would turn the clock back to the 1980s, re-creating a patchwork of state and local laws that would drive up costs and sow confusion among manufacturers, code authorities, plumbing engineers and everyone else in the industry. Plus, it would waste precious water, as well as squander hard-won advances in plumbing technology gained through trial and error.
And for what, besides winning a few votes for Knollenberg at re-election time? Are suppliers and contractors supposed to throw away all the millions of ULF units now in inventory? Rip out all the 1.6 closets installed within the last five years? And what if the winds shift once again and people decide that conserving water is important enough to put up with imperfect potties? The plumbing industry has more important things to spend time and money on than this half-baked attempt to throw a monkey wrench into the wheels of progress.
A copy of "Saving Water, Saving Dollars" can be obtained for $15, plus $5 shipping and handling, from the American Council for an Energy-Efficient Economy, 202-429-0063. Fax: 202-429-0193. Or e-mail them at: firstname.lastname@example.org