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New Water Efficiency Rules Under Review by California Energy Commission
Posted: Tuesday, April 28, 2009 4:52 PM

California Energy Commission (CEC) has opened docket number 09-AAER-1A, Phase 2 of the 2009 Rulemaking on Irrigation Efficiency Regulations proceeding, to establish performance standards and labeling requirements for landscape irrigation equipment (such as smart controllers) as required by the Water Conservation in Landscaping Act of 2006.

See link to comments made on the issue CEC faces given its mission to establish the performance standards and labeling requirements for smart controllers.

CEC is reviewing the use of SWAT to test and evaluate if a smart controller can satisfy certain standards. From information published by SWAT, its tests are not designed to determine if smart controllers can save water in the real world.  The stated purpose of SWAT testing is to determine if the smart controller can calculate an evapotranspiration formula correctly. SWAT openly admits that its bench tests were not designed to test for water savings.

Using SWAT as a testing and certification organization for labeling smart controllers would not provide the public with the information they need when making decisions on purchasing such equipment.   If no savings are realized then such labels may, in fact, mislead the public.

SWAT has tested certain smart controllers with scores of 100% and 0% excess usage. Such smart controllers with the 100% score have been found to save no water or actually use more water than that used prior to installation.  Any scores or claims made by SWAT do not reflect if a smart controller will save water or not.

Water utilities offer fixed rebates for the purchase of smart controllers with no requirement for savings verification. Such financial rebates or vouchers are paid even when no water savings are realized.

CEC may take into consideration a component for water saving performance and savings verification in its labeling requirements.  Such a savings performance component would include: auditing of historical usage, identifying meters relative to each smart controller, continuous monitoring, consumption tracking, savings reporting, and performance verification each and every time a smart controller is installed. In order to determine if water savings is being realized, a baseline is needed to be established so that historical consumption “after” installation can be compared to “before” installation which has been the “standard” in tracking energy savings realized from the implementation of energy efficiency solutions.

Smart controllers do not fall under the definition of an appliance.  An irrigation system along with the controller is, in fact, a control system in the same way that an energy management system is not an appliance.  An appliance consumes energy and or water when in operation.  Smart controllers are operated and programmed where water usage will vary and depends upon numerous and complex variables.

Recently, the Director of California Department of Water Resources, Lester Snow said that "it is time for real water savings", which supports the need to measure and verify metered data so that the amount of water savings actually achieved after installation of a smart controller is documented.

Posted: Friday, May 22, 2009 7:32 PM

We received a message this week from the California Energy Commission that the issue of “Drought Ordinances Rendering Water Smart Technologies Ineffective” was raised at the first workshop on April 1, 2009.  The CEC has scheduled a second workshop on June 2, 2009 to review this specific issue as well as others under consideration by the Commissioners.

Since no reply to this post has been offered to-date….. we were wondering what are the opinions of A4WE members on the direction that the CEC should be going with regard to issuing standards and labeling requirements of smart controllers?

Posted: Monday, September 14, 2009 4:48 PM

California Energy Commission (CEC) docket number 09-AAER-1A has ordered the suspension of the 2008 Appliance Efficiency Rulemaking Proceeding for Landscape Irrigation Efficiency Standards.

The CEC stated in their annoucement that "Sufficient information on costs, actual performance, and methods to verify savings is lacking. In addition, recent studies have shown that the use of industry-preferred controllers, or "Smart Controllers", frequently increases water use as well as energy consumption. The only industry accepted test methods available for controllers do not test for water conservation, but rather measure the efficiency of applying adequate amounts of water supplies to landscapes."

This statement reflects the findings that SWAT testing is not about certification based on saving water but on testing the ability of a smart controller to perform the ET equations correctly.