A coalition of 13 trade and interest organizations has endorsed the following letter in opposition to a DOE interpretive ruling that would effectively limit the use of multiple showerhead systems.
The Honorable Dr. Steven Chu
Secretary of Energy
Subject: DOE/EERE Proposal to Change Definition of
Showerhead - Docket No.
In May, the U.S. Department of Energy’s (DOE) Office of Energy Efficiency and Renewable Energy provided notice that it was soliciting comments on the agency’s draft interpretative rule to significantly change the definition of ‘‘showerhead” (Federal Register-5/19/10 - Volume 75, Number 96, Page 27926).
After careful review,
we believe that that the DOE proposal
would impact the use of various types of showering systems in homes
across America, including hand-held showers, body sprays, and shower
systems. Many of these products are also
used in hospitals, nursing homes, schools, and other therapeutic and medical
facilities. Additionally, restrictions
on these types of shower systems would have a significant impact on plumbing
manufacturers, contractors, installers, and retailers across the country. Especially hard hit would be consumers,
particularly seniors and members of the disability community who rely on these
types of shower systems as a functional necessity.
We are most concerned about the process the agency is relying upon to
implement this proposal. We believe that
a change of this magnitude should NOT be exempt from the notice and comment
requirements of the Administrative Procedures Act as DOE has asserted. With only a 30-day comment period, DOE’s
rule would negate the standard definition of a showerhead that has existed for
Lastly, it will
eliminate the opportunity for consumers to have a choice in determining what
type of showering system best suits their individual needs. These showering systems have been available
to consumers for over 40 years.
We are committed to the
efficient and sustainable use of water; however, given the adverse impact that
the agency proposal will have on the American public, we strongly urge DOE to reexamine its
decision to redefine by fiat its showerhead rule. Instead, we believe DOE should provide for a
fair, full, and transparent process as the agency moves forward on this
look forward to your response on this important matter.
of People with Disabilities (AAPD)
American Supply Association
Buying Group Services, Inc.
Canadian Institute of Plumbing and Heating
Decorative Plumbing and Hardware
Elite Brand Sales and Marketing
Forte Buying Group
Association of Plumbing and Mechanical Officials (IAPMO)
NAHB / National Council of the Housing
Kitchen and Bath Buying Group, Inc.
Plumbing-Heating-Cooling Contractors –
Plumbing Manufacturers Institute
The Home Depot
cc: Assistant Secretary
PMI, IAPMO, 11 Other Groups Challenge Showerhead Ruling
June 21, 2010