KOHLER CO

. KOHLER, WISCONSIN 53044 PHONE 414457-4441



### February 7, 1997

Dear Mr

. McCabq RE: Trough Type Urinals This is a follow-up to our conversation of Febr uuy 5,1997 , regarding the acceptability of trough urinals related to their water use restrictions

. As we diiscussed , in areas that accept their use the applications are normally in buildings where a great number of people use the facilitie s simultaneously, such as stadiums , sports bars, et cetera. Normally these factutes we produced in a variety of sizes from 36" to 72" in length, approximately 18" wide, bowl depth of 7 3/ 4", 8" high back

- with a center outlet for a 1 1/2" trap

. the water supply is dispersed in the urinal by a spreader bar that flushes the back and sides of the fixture. Because of the varied lengths of these fixtures , they resemble a factory wash fountain in that they accommodate more than one user at a time

. The best rule of thumb is one person for every 16 to 18" of urinal length. Standard trough urinals sizes are 36", 48", 60", and 72"_ This relates to. the approximate water usage in the following table:



### 'TROUGH URINAL WATER CONSUMF'TTON Urinal Length 

### 36" 

## 60- 72" Gallons/Flush 

## 2 3 4 4.5 I want to thank you for taking the time to discuss and resolve this ,matter with us. The plumbing fixture under discussion is not used in too many instances today

. However, a request is made occasionally for a football stadium or other high density application where local plumbing codes allow trough urinals. Sincerely,


### r^rL' Sargent ager, Codes and Standards Mr. Mtchaet McCabe 

### Unuited States Department of Energy Washington, D.C.

## Department of Energy Washington, DC 20585 March 24, 1997
Mr. James Sargent Manager , Codes and Standards Kohler Co., 444 Highland Drive Kohler, WI 53044 Dear Mr. Sargent: Thank you for your letter of February 7, 1997, to the Department of Energy (Department) regarding the applicability of water conservation standard for trough-type urinals designed for multiple users. The Energy Policy Act of 1992 amended the Energy Policy and Conservation Act (EPCA), to provide water conservation standards for certain plumbing products, including urinals. EPCA defines the term "urinal" to mean "a plumbing fixture which receives only liquid body waste and, on demand, conveys the waste through a trap seal into a gravity drainage system." EPCA also established a maximum water use of 1.0 gallon per flush (gpf) for urinals when such products are manufactured after January 1, 1994. The Kohler Co. believes that trough-type urinals are a covered product. Kohler states that these fixtures are produced in sizes of 36," 48," 60," and 72" in length, are approximately 18" wide with a bowl depth of 73/4," 8" high back - with a center outlet for a 1'/2" trap, and the water supply is dispersed in the urinal by a spreader bar that flushes the back and sides of the fixture. In addition, Kohler requested that it be allowed to comply with the water conservation standard by prorating the water consumption based on a capacity criterion of 16 inches of urinal length per person. The Department agrees with Kohler's view that these units can be considered as a covered product. The Department believes that any urinal, regardless of the number of users the fixture was designed to accommodate, shall constitute a covered "urinal" subject to the applicable water conservation standard. The Department believes the maximum water consumption, for trough-type urinals, may be prorated based on the number of users it can accommodate at one time. This approach is consistent with a proposal, by the Department for multiple-user spray heads with collectively-controlled orifices, where the maximum water consumption is defined by prorating based on a capacity criterion of 20 inches of rim space per lavatory or individual. (62 FR 7834, February 20, 1997). Although the Department is unaware of any plumbing code applicable to trough-type urinals, the Department believes that Kohler's request to prorate the maximum water consumption based on 16 inches of urinal length per person may be reasonable.

Printed with soy ink on recycled paperThe Department plans to gather information on this issue at the April 1, 1997,

public hearing for plumbing products. Prior to the publication of the Final Rule, the Kohler Co. can distribute and install the above trough-type urinals, provided the maximum water consumption of such products does not exceed 2.3 gpf, 3.0 gpf, 3.8 gpf, and 4.5 gpf, respectively. If you have questions or need additional information please contact Mr. Bill Hui of my staff at (202) 586-9145. Sincerely,

Michael J. McCabe, Director Office of Codes and Standards Building Technology. State and Community Programs Energy Efficiency and Renewable Energy cc: Mr. Jim Neumann Manager, Manufacturing Support Eljer Industries, Inc. Mr. Richard W. Church II Managing Director Plumbing Manufacturers Institute