Smart Controller Rulemaking Under Review by the California Energy Commission and EPA WaterSense.
APRIL 27, 2009, SAN DIEGO, CALIFORNIA -- Both EPA WaterSense and the California Energy Commission are busy considering rules on outdoor irrigation water efficiency so as to define standards, test methods, labeling requirements, and the certification process.
These new rules will require landscape irrigation equipment, including smart controllers, to pass certain standards as well as satisfy evaluation criteria for certification. EPA has yet to publish specifications or evaluation criteria and has only announced a product certification system that is very complex. The EPA product certification system is focused on typical product testing procedures versus how water management should be conducted.
Recently, the Director of California Department of Water Resources, Lester Snow, told Gary Gelinas, CEO of Water2Save, that "it is time for real water savings". DWR understands the need to measure and verify metered data before and after each installation so that the amount of water savings actually achieved is documented.
The California Energy Commission scoping process does include a review of comments prepared by Water2Save. These comments state that savings performance information should be shown on each and every label placed on outdoor irrigation equipment. Other comments were that installation of smart controllers and other water efficiency equipment needs to include professional audits of historical and after installation water use, identification of water meters relative to each smart controller, continuous monitoring of savings from consumption tracking, and reporting and verification of anticipated savings.
The mission of the California Energy Commission has primary been towards rulemaking for appliance efficiency regulations. The mission includes regulations: for all appliances that use a significant amount of energy or water; that are feasible, and must reduce energy or water demand growth; and that are cost-effective to consumers over the life cycle of the appliance. Unfortunately, outdoor irrigation water management requires much more than appliance regulations to achieve significant water savings. Water2Save continues to bring important comments to the California Energy Commission during this rulemaking process.
The use of the Smart Water Application Technologies (SWAT) testing for certification and labeling is under consideration. However, from information published by SWAT, its testing program is not designed to determine if smart controllers can save water in the real world. The stated purpose of SWAT testing is to determine if a smart controller can calculate an evapotranspiration formula correctly and is not designed to measure water savings achieved from installing smart controllers.
Irrigation efficiency equipment labeling should provide the public with critical savings measurements similar to that provided under EnergyStar labels. In the event irrigation efficiency equipment is purchased under the assumption that such a device saves water and then no savings are realized, the result would be that the label failed to inform the public of the fact that savings is not guaranteed.
All labeling by either EPA or the California Energy Commission must be fully transparent to the public so that those that purchase irrigation efficiency equipment will know if savings will be realized and how much savings can be expected after installation.