On Tap from DOE: Cold Showers and Wasted Water

The Trump administration just sent decades of progress on water and energy efficiency for U.S. showers down the drain with a radically irresponsible and illegal rule for showerheads. By cynically changing the way a showerhead is defined, the Department of Energy (DOE) would allow the sale of new models that use virtually unlimited amounts of water, setting up consumers for higher utility bills and frequent cold showers.

Credit: Shutterstock/VisualArtStudio

What’s worse, DOE apparently developed the new rule in response to a series of baseless claims from President Trump, typically offered as applause lines during his election rally speeches. Despite a steady stream of complaints from Mr. Trump about showerheads that don't deliver any water, the reality is that consumers are able to find thousands of water-efficient showerheads for sale in today’s market that deliver an ample spray and a satisfying shower experience. 

And of course, removing limits on shower water flow will also increase the amount of energy used to heat the water—which also means increasing the amount of pollution from a gas water heater onsite or at the power plant supplying an electric one. With roughly 200 million showers taken every day in the U.S., the financial and environmental impact could become significant—and especially harm low-income Americans and communities of color that already experience significantly higher burdens when it comes to water and energy bills and energy-related pollution.

DOE issued the new rule today even though the Alliance for Water Efficiency and dozens of water and wastewater utilities objected to the showerhead definition change, estimating it could increase national water use by 161 billion gallons per year. The water waste enabled by this rule would result not only in higher utility bills but more natural gas use for hot water, an attendant increase in greenhouse gas emissions, and worsened drinking water reliability during drought—environmental impacts DOE ignored in its proposal to change the rule.

(Separately, DOE today also issued a rule that would carve out new categories of clothes washers and dryers for which no efficiency standards would apply. See our commentary here on this ill-conceived proposal.)

The details

Under the previous efficiency standard, last amended in 2013, a “showerhead” was defined as “a component or set of components distributed in commerce for attachment to a single supply fitting," including hand-held showerheads. This language makes it clear that during the procedure used to test the water efficiency of a given showerhead model, the total number of nozzles that can simultaneously run from one pipe are subject to the maximum flow rate of 2.5 gallons per minute—a limit that has been in place since 1994.

DOE today revised the definition of a showerhead so that multiple nozzles attached to a single water supply would each be considered a separate showerhead, allowing each nozzle to use 2.5 gallons per minute, even if they operate simultaneously. Since there is no limit on the number of spray nozzles a single product might have, the new rule permits unrestricted flow. That lets showerheads, as newly defined, use double, triple, or even quadruple the maximum amount of energy and water allowed for the last 25 years.

This is totally unnecessary. Top-rated showerheads on the consumer review website Wirecutter, for example, actually use less water per minute than allowed by federal standards—an "upgrade" pick from Moen uses 1.75 gallons per minute, for example.

Allowing inefficient products on the market will lead to levels of water use that outpace what most homes’ hot water heaters can deliver. An analysis from independent expert Gary Klein found that a household with a 40- or 50-gallon storage water heater (the most common sizes) would run out of hot water in 5.5 minutes and 6.9 minutes, respectively, with a three-spray product that would be permitted to use 7.5 gallons per minute under the new rule. And since the average shower is 8 minutes, the second consecutive shower in a household with even a two-spray device would be a cold one.

This rule represents yet another attempt by Trump's DOE to dismantle, rather than strengthen, a national energy efficiency standards program that saves the average U.S. household $500 a year on utility bills. NRDC, joined by consumer and low-income advocates as well as a number of states, recently sued the agency over its inaction on 25 standards that would save households and businesses at least $22 billion annually on their utility bills. Lawsuits also have been filed over DOE’s rollbacks of light bulb standards, changes to its efficiency standards process that will slow down—and create hurdles to—future standards, and its failure to finalize four standards issued under the Obama administration. 

The failure to assess these impacts, as required by the National Environmental Policy Act, is just one reason DOE's proposal is illegal. The change would also violate the agency’s recently revised Process Rule as well as the appliance standards law’s anti-backsliding provision. This increase would impose costs on water and wastewater utilities to meet the increased demand under the new rule. Similarly, energy utilities would also have to commit extra resources. Even a small share of consumers opting for these new highly consumptive showering products would impose costs on all utility customers, since the costs of increased water, wastewater, and energy capacity are generally shared across all customers.

Showerhead manufacturers and plumbing distributors, which have spent the past two decades complying with the standards, also objected to the rule change, mindful of the confusion it will create in the market. No one but President Trump and his enablers, it seems, is interested in unleashing a flood of wasteful showerhead products. Hopefully, the incoming administration will quickly thwart this rule and reverse the agency’s needless attacks on energy and water efficiency.

About the Authors

Ed Osann

Director, National Water Use Efficiency, Water Initiatives, Healthy People & Thriving Communities Program

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