Write us a letter at PMmag@enteract.com or visit our feedback page.

Be Careful Of Averages

I run the Water Conservation Office for the city of Phoenix. We were the ones who initiated the research on aging 1.6-gpf toilets that was done by Gary Woodard and Jim Henderson and reported in PM ("Aging Low Flows," March 2001). That work was sponsored by Phoenix and the U.S. Bureau of Reclamation. We chose to study the Tucson rebate program for two reasons: Phoenix had not (it appears wisely so) engaged in a toilet replacement rebate program. Dr. Woodard had done an earlier demographic study of rebate participation in Tucson, also funded by Phoenix, and had the database readily available. Why reinvent the wheel?

I scoped out the study and commissioned it because of concern over the long-term performance reliability of the 6-liter toilets. This concern grew out of frustration with the ASME A112.19.6 committee on toilet performance standards, and concerns about whether we could bank on reductions in toilet water use based on what appeared to be rather iffy short cuts taken by manufacturers in producing toilets that comply with that standard. At one time, I was the water industry's representative on that ASME panel; my name is on the committee list for the 1990 publication of that standard.

I read your cover story on the results of the study. Generally, I found it to be a very good recap of what Woodard and Henderson found.

I am, however, concerned with your first sentence of the second paragraph: "On average all the low-flow toilets put in service seven years ago used almost 2 gallons to flush . . ." That's not technically accurate. That would be similar to stating: "On average, all the persons working in the Phoenix Water Conservation office are 49 years old." Three of us who are 53 or older would be happy to be 49 again, but our youngest member, only 22, would not be too happy. In fact, our mean age, if we leave the kid out, is closer to 53. Have to watch how "average" is used.

As you point out, 26.5 percent of the toilets in the study had high flush volumes. The 26.5 percent that had high flush volumes used sufficient water to drive the average for all 170 toilets to 1.98 gallons.

It does mean, however, that water planners have to assume that, on average, their estimates of water savings from toilet replacements will be off by about 25 percent, and they need to make appropriate adjustments to future water demand forecasts.

One of the criticisms of this study is that it did not look at performance of newer models of the 1.6-gallon toilet. That's quite true. Since the study was to see how well toilets aged, and how age impacted the performance, we cannot study today's generation of product for another five to seven years. If current products hold up better, then we will see improvement. If not, we'll see similar results and will have lost five to seven years potential water savings.

That may be acceptable to the manufacturers, but it is not to the water industry, and is why we are pressing for more uniformity of product so even the worst dolt cannot subvert the performance of his 1.6-gpf toilet by replacing an OEM flapper with a generic one.

For those making water demand forecasts, this is a multimillion-dollar question. A recent General Accounting Office study of the impact of water-efficient plumbing fixtures on future water demand and wastewater flows estimated that somewhere between $165.7 million and $231.2 million can be saved by reducing or deferring planned investment in expanded drinking water treatment and storage capacity by 2020. And that's only for the 16 localities analyzed by an on-going study in the West, and reported to GAO investigators.

If we cannot rely on that demand reduction, water agencies have to do one of two things: Build for a higher demand and potentially have excess capacity, or bank on lower demand and risk running short of water.

Tom Babcock
Water Conservation Office
Phoenix Water Services Department
Phoenix, Ariz.

NSPC Is A Third Code

As the publisher of the National Standard Plumbing Code (NSPC), we were very surprised that Julius Ballanco considered there to be only two model plumbing codes left in the industry, neither of which were the NSPC ("2001 - A Code Odyssey," February 2001). Granted, Mr. Ballanco mentions the NSPC in the article, but only in a negative way.

The Plumbing-Heating-Cooling Contractors - National Association begs to differ with this perception. Since its founding as the National Association of Master Plumbers in 1883, PHCC has maintained a serious interest in plumbing standards, codes and good plumbing design practices. The NSPC, supported by PHCC in various forms since 1933, provides practices and performance criteria for the protection of health and safety through proper design of plumbing systems.

Currently, the NSPC has been adopted by New Jersey, Maryland and South Dakota, as well as many other local jurisdictions. Also, the U.S. Army Corps of Engineers uses the NSPC. With all this in mind, we object to Mr. Ballanco's description that the NSPC is "not much of a code."

Also, the article's allegation that only five people vote on what is in the code is not true. The NSPC Committee consists of 10 representatives of plumbing contractors, engineers and inspectors. Not only do members of the NSPC Committee have input into any code change, but so do other industry representatives, the public, proponents of code changes, and representatives of all walks of the industry who attend an annual code hearing. Plus, anybody can respond to requests for public comment that are distributed prior to the hearing. We definitely do not believe we are "out of touch."

In fact, the next code meeting is Aug. 17, in Falls Church, Va. As always, we will be requesting responses to proposed code changes beforehand. I would encourage anyone interested in this code to attend the hearing and let his or her voice be heard. Or call PHCC at 800/533-7694 for more information about the NSPC.

Mike Kastner
President, PHCC-NA
Falls Church, Va.

White Collar Past
Blue Collar Future

I received my very first issue of PM the other day fully expecting another trade magazine filled with, well, nothing. Imagine my delight when I found a column by Wet Head guru Dan Holohan and a wonderfully perceptive editorial written by Jim Olsztynski ("Blue-Collar Bias," February 2001).

I have a BA in English with a certification to teach, did some graduate work, had a briefcase, beeper and dozens of neckties that went along with "office" positions. That was then. Now, I work for a mechanical contractor, and just got my Master Plumbing License this year. With 10 years of practical experience wearing shirts with both blue and white collars, I believe I have a better than average understanding of Jim's article.

My most favorite thing in the whole world is having the door answered by an unwashed person with no social graces who says, "Would you go 'round and use the back door." I swear I always look for, and one day I will see, a sign that says "Tradesman Entrance." So I go in that way, walk over a carpet covered with stains and cat hair on the way to the basement where the owner will then tell me the pilot is out on his boiler that has spark ignition.

But there are good days. Days when I realize I have the knowledge and ability to troubleshoot and repair anything. Days when I walk through a warren of cubicles (on the way to the roof or basement) and see those legions of "third-rate paper shufflers" and I want to ask them. "Just what exactly, do you do?"

From experience, I know many spend a lot of energy trying to look like they are doing something. I don't have that problem because there is never a shortage of calls that are "difficult, dangerous and indispensable." Thanks for a "word up" to the working man. Looking forward to the next issue.

Rob Lovelace
George H. Bixler Inc.
Hanover, Pa.