Comments by Author on the Draft Water-Efficient Single-Family New Home Specification
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Comments by Author on the May 2008 Draft Water-Efficient Single-Family New Home Specification September 2008 Comments by Author on the Draft Water-Efficient Single-Family New Home Specification Commenter Comment Name Alderman, I understand that a change has been proposed in the EPA Water Sense New Homes Specification 4.1.4 for Jeffrey water-efficient new single-family homes: The new proposed draft for Ornamental Water Features reads as follows: "This specification establishes that builders shall not install or facilitate the installation of ornamental water features. Ornamental water features are defined as fountains, ponds, waterfalls, man-made streams and other decorative water related constructions provided solely for aesthetic or beautification purposes. Because these water features serve no functional or practical purpose their water use is not considered efficient." As a registered civil engineer in the state of California, I have designed hundreds of water feature projects over the course of 25 years. My comments regarding the above-proposed new specification draft are as follows: The purpose of water features is not "solely for aesthetic or beautification purposes." (emphasis mine). Your premise is flawed. Aesthetics and beautification are certainly some of the major purposes for water features, as is the case with landscaping in general. Water features also provide the following benefits as well: Provision of Earth Grading/ Earthwork/ Stabilization Options -- in some cases, the installation of a water feature, such as waterfall/ retaining walls, are a superior solution for earth grading and stabilization of land; than soil surface slopes, landscaping, and other methods would provide. Noise abatement -- in many of our projects, water features provide a pleasant, and often necessary, buffer to outside traffic and other unwanted noises. Serenity/ Mental and Physical Health -- a peaceful sanctuary to which people can retreat to escape from their every-day stresses and pressures of life; and to promote reflection, contemplation, etc. Appreciation and Learning/Studying Environment for aquatic ecosystems -- to observe, appreciate, and study fish, amphibians, aquatic plants, and other aquatic life forms and their environments in water features which include them. Promotion of Ecological Awareness and Concerns -- often a direct result of the appreciation and learning/studying aquatic ecosystems, is a person's growing awareness, care, and concern for ecological issues in general; which is a great benefit and need in our society and world. Provision of Hobbies -- this includes the planning and building of the water features, raising of koi, catfish, frogs, water plants, etc. Vast libraries of books, pamphlets, websites, etc., have been written, published, posted, and distributed, with a large and growing population purchasing and utilizing this literature. Provision of a Growing Hobby Economy and Market -- Millions of dollars are now being spent annually at specialty and hardware stores, construction materials yards, aquatic and conventional plant nurseries, etc., for this burgeoning water gardening hobby. Homeowners often want existing water features to be provided on their property upon their purchase. Others like to plan and build them themselves. This is their prerogative. Provision of a Growing Construction Economy and Market -- New Water feature and Pond specialty 2 September 2008 Comments by Author on the Draft Water-Efficient Single-Family New Home Specification Commenter Comment Name contractors are popping up in almost every community throughout the United States, either as contractors who solely install water features, as well as existing landscape, grading, and building contractors, who are expanding into this new, growing, and exciting field. These contractors also bring much-needed business to the same stores, yards, nurseries, suppliers, etc. The number of Engineers, Architects, and Landscape Architects who design water features are also growing significantly; either as professionals who solely design water features (such as Alderman Engineering), as well as existing landscape architects, architects, etc., who are expanding into this field. This is especially important and helpful in view of the current downturn in our economical conditions in general, and of the construction industry in particular. Elevation of Property Values -- The presence of water features/ water gardens elevates the economic values of residential properties. This is especially important and helpful in view of the current downturn in property values throughout the United States, for our citizens and for the land development, construction, and real estate industry in particular. Provision of a Growing Social Network -- There is a large growth of water feature and gardening groups and societies throughout the United States and the world. Many of these groups are local in nature, and many are international. This gives people an avenue to inter-connect with one another, who share the same interests. There are several other purposes and benefits that home water features and water gardens provide, beyond those listed above. The enhancement and improvement of private property for "aesthetic or beautification purposes" alone is important to many homeowners. There is no justification for the Committee to dismiss these considerations and desires by interfering with an edict that "builders shall not install or facilitate the installation of ornamental water features". With gasoline and fuel prices increasing sharply, many people are staying at home, rather than traveling. Many are converting their properties into "aesthetic" and "beautification" oases; or want to purchase private properties that already have beautiful environments; as they desire. It is their God-given right to do so. An edict by your Committee that "builders shall not install or facilitate the installation of ornamental water features" is unconstitutional. It introduces yet another attempt to infringe and encroach upon our God-given rights and liberties. Our Constitution guarantees our freedom and liberties from oppressive, excessive governmental controls, edicts, and interference. The Constitution clearly prevents the EPA, or any governmental agency, from imposing this type of interference. Therefore, the statement: "these water features serve no functional or practical purpose" clearly is incorrect. If the goal “that builders shall not install or facilitate the installation of ornamental water features” were to occur, an entire water feature and gardening hobby, construction, and design industry would be extremely curtailed, if not effectively eliminated altogether. This would occur in the face of our current poor economic 3 September 2008 Comments by Author on the Draft Water-Efficient Single-Family New Home Specification Commenter Comment Name conditions in our nation - particularly in the land development, construction, and real estate industries. The growing residential water feature industry is currently one of the few bright and growing sectors of our economy. It would be extremely foolish to jeopardize that. The assertion that residential water features' and water gardens' "water use is not considered efficient" is also incorrect. Properly designed and installed water features have very effective waterproofing liners, which virtually prevent any appreciable water leakage and losses due to percolation into the soils and geologic formations that are below and adjacent to them. After their initial filling, the "make-up" fill water that is added to properly designed and installed water features is only due to evaporative losses, and to a very minor degree, due to overspray and misting effects. The flowing water that occurs in water features is due to re-circulatory pumping systems, which transport the water volumes that already exist in the water features - and is not due to a constant filling of water from an outside water supply source. The evaporative water losses in water features are actually less than, or close to, water losses that occur due to the evapotranspiration processes that naturally occur in many turfs and plants. The mismanagement and waste of water is a widespread problem, which must be addressed and corrected. There are many inefficiencies and practices which must be streamlined and renovated. In comparison to the widespread poor, water wastefulness practices which are practiced daily, the use and purported mismanagement of water for residential and commercial water features and water gardens is, by comparison, an extremely miniscule consideration. Serious reforms should begin with the current waste of enormous amounts of water, rather than imposing unconstitutional interferences with private homeowners, and the land development, construction, and real estate industries; which currently are already in extreme economic distress. My comments also apply to ornamental "hardscape" water features; which include fountains, ponds, etc., and which do not have any aquatic life forms. It is the prerogative of private homeowners and land developers, contractors, etc., as to what type of water features that they want to construct and/ or own. I am aware that the overall goal and mission of the EPA Water Sense New Homes Program is to conserve and save water. This is an important goal in view of the increasing scarcity of usable, potable, fresh water in our nation and world. However, in your pursuit of this commendable goal, your approach is extremely myopic. This proposed