Dennis Wilson, CPDWe want to thank Mary Flynt-Phelps with American Standard for alerting all to this new law in Texas. You will find attached to this bulletin an Adobe PDF file that contains an Internet news release announcing and summarizing Texas House Bill 2667, followed by the bill itself.The intent of the bill focuses on “Water Conservation.” Enactment of measures like this, at the State level rather than by Federal mandate is the correct approach as each State is different in its composition of available resources and needs. However, one does have to question the required use of High Efficiency Toilets and Urinals as the appropriate vehicle. In discussions via e-mail by sitting Board of Directors members of the DFW Chapter of ASPE, there was much consternation over the issues that fall out from this legislation.Education Chairman Mike Danielson tells us, “The mandate of 1.28 gpf on the Water Closet is not a good idea. Carry will be an issue. Even the manufacturers will tell you that you need to have at least one high volume flush fixture (minimum of 1.6 gpf) to help maintain the effluent carry down the sewer line.”This is an issue. Compounding the issue is the question of where is the guarantee that this higher GPF fixture will be utilized with enough frequency to assist in the effluent carry and scouring of the pipe, avoiding maintenance headaches. Further to the point…V.P. Technical and Master Plumber Larry Bartlett speaking from a wealth of practical experience and has the following comments to share. “As the review agent for most of our projects, I see an ever increasing problem with lowering “all” fixtures to extreme low flow (Step II @ 1.28gal). As previously mentioned, the need to have at least one fixture on the high side of the battery to remain at 1.6gal has proven to reduce maintenance issues. We have tried using all Step II, Low Flow Fixtures and have issues with the pipe not self scouring itself and solids quickly building up to produce a clog or restriction. Therefore, we see the mandate of all fixtures to this Low Flow (1.28gal), as being a maintenance issue which would increase the overall cost to operate the facility.”Ah, but there are three sides to every coin and the design/maintenance issues are just one side. Side Two of our coin is Product Sales. Until 2014 when this law culminates its staged compliance requirements with the vaunted “100% compliance”, the consumer/property owner/building owner still has a choice in what they can require to be installed. Sounds great, yes? Well here comes the clinker. The manufacturers of the high efficiency toilets and urinals are required to report sales to prove up the averages. So what is foreseeable is that when sales are out of balance, the higher gpf fixtures suddenly become unavailable until the State mandated sales quota’s balance out. This could cause construction delays, last second redesign and so on. Is there a “Spot Market” for china?I had said that there are three sides to every coin. So, before your blood pressure increases further and you work up a lather, here is Side Three…the edge.The Edge, the Politics, the “CYA” dance performed by our elected officials. Yes, you need to read the legislation and at least twice if this were a school homework assignment. It was on my third pass that the one key word in this Bill that was nagging at me finally jumped out and smacked me. This word throughout the legislation is the word ”average.”With respect to the toilets for example, which are the big maintenance concern for us designer types, go to the legislation and jump over to Page 5, Lines 2 through 8. We are not talking installation of 1.0 gpf High Efficiency Toilets here but installation of a dual flush unit where the flush volume is a user selection and where the math of two reduced flushes at 1.0 gpf and one full flush at 1.6 gpf averages to just under 1.28 gpf. Which flush volume will the “end user” select? So, all this said, is it a big deal? The answer is that oxymoronic “yes and no” thing. Yes it is a big deal in that our State is providing/requiring some steerage to get us to where we need to be on this whole water conservation thing but without being heavy handed about it. Remember too that although Texas has more reservoirs and surface water than any other State, Texas is still mostly a vast arid desert.The “Sales” aspect is probably the greatest hurdle initially and may suffer the most noticeable impact with the proviso that all costs are passed on to the consumer.On the design side, the issues are maybe not so difficult to overcome. LEED is one component already pushing us down the path and the smart conscientious design polishes it up nicely.House Bill 2667 is not solely focused on toilets and urinals. You will find a number of other fixture types affected as well.Two other key items to note:First, on pages 9 and 10 of the Bill, you will find requirements for non-water supplied urinals. The Bill requires a water supply to be stubbed up in the chase and ready for installation of a water-using urinal should the owner desire to change out fixture types. Didn’t see that one coming.Finally, on page 11, the Bill sets requirements on owners of rental property and multi-use facilities which requires the removal and replacement of all 3.5gpf fixtures with the lower gpf fixtures prescribed in the Bill.It all becomes Law on September 1, 2009. Enjoy the read.
A.S.P.ECPD REIMBURSEMENT PROGRAM ASPE is informing all plumbing engineers / designers that there are available funds for individuals who are taking the C.P.D. exam. In order to receive reimbursement, you must submit to DFW ASPE for reimbursement. Once participants pass the C.P.D. exam, ASPE will reimburse the cost of the exam back to you or to your employer. Our VP Membership must confirm with ASPE Society the successful completion of the CPD exam and verify membership. ASPE is encouraging all plumbing engineer designers to take advantage of this opportunity to be certified plumbing designers in your field of study. The reimbursement of funds ends December 2010. CRITERIA: 1)You must have been a DFW member in good standing at the time the exam was taken. 2)You must be a DFW ASPE member in good standing at the time reimbursement is requested. For more information contact: President of ASPE DFW CHAPTER – Bryan Hutton Vice President of Membership – Nathan Johannes, P.E
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