RE: Docket # 17-AAER-10 (Irrigation Controllers)
On behalf of the approximately 1,300 member companies of the Irrigation Association, we are pleased to provide additional information to the California Energy Commission (CEC) as the commission undertakes regulatory actions with respect to irrigation controllers. We appreciate the commission’s engagement with industry and other stakeholders in recent months and offer the following comments to contribute to a workable regulatory framework.
We seek to improve any final regulation and to advance workable solutions that promote energy and water conservation in the state. These comments were developed with input from across the irrigation channel to market — from irrigation manufacturers, distributors, designers and contractors — as well as water agency officials and other experts in irrigation and water use.
Agricultural irrigation controllers
While some agricultural controllers do have features that distinguish them from landscape controllers, most do not. In our discussions we have identified a few distinguishing characteristics that are applicable to some, but not all, agricultural controllers:
- Some controllers for mechanical-move agricultural irrigation products use 120 volts instead of 24 volts or less used in landscape applications,
- Some controllers for mechanical-move agricultural irrigation products have settings that control the speed and/or direction of the pivot instead of operating valves, and
- Some agricultural controllers are capable of cycles of less than one minute.
However, we note that these distinguishing characteristics are the exception, rather than the rule, and that the physical characteristics of agricultural and landscape controllers are often indistinguishable. Instead, different distribution channels (typically) and end users/use cases distinguish these products from landscape controllers.
The underlying EPA’s WaterSense specification and test methods were developed exclusively for landscape applications, and agricultural applications were intentionally excluded from the scope of EPA’s program. Not explicitly excluding agricultural controllers from the regulation would not only delay implementation of a final regulation because of the dramatic increase in impacted stakeholders, it would result in a number of consequences, including:
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Agricultural irrigation controllers that growers in California currently rely on would be prohibited by the regulation. To our knowledge, no controllers manufactured for the agricultural market are currently designed and/or tested per WaterSense specifications. Further, test method ANSI/ASABE S627.1 OCT2022 requires test zones of landscape plant materials such as turf, ground cover, woody shrubs, and trees and ground cover. The test method does not specify any agricultural crops. Because of this, it is unlikely any agricultural controller would meet the requirements of the specification. This would critically impact growers’ operations and threaten California’s agricultural economy.
- EPA’s WaterSense national water conservation program would be put at risk. WaterSense is a voluntary program that was developed for outdoor landscape applications and intentionally excluded agricultural applications. Agricultural stakeholders were not at the table and have had no input in the underlying specification development. By not excluding agricultural controllers, the CEC would, by necessity, inject agricultural stakeholders into future actions by the EPA with respect to these and other WaterSense specifications. Rather than advance water conservation, this would inject even more challenging dynamics into specification development and review, and it would undermine the program nationwide.
Recommendation:
- Retain the following language from the proposed regulatory language that was included in the Nov. 8, 2023, staff report: “Landscape irrigation equipment” and “Landscape irrigation controllers” (emphasis added).
- Provide clarity that this regulation does not cover “agricultural irrigation equipment/controllers designed and marketed for agricultural use.”
Total packaging requirements
In previous comments and input shared with the CEC, the IA and other stakeholders have noted challenges of a requirement that deviates from the WaterSense specification and requires that controllers and sensors be packaged together. These challenges include electronic and packaging waste, increased distribution costs, logistical challenges throughout the channel to market, and excluding products from manufacturers that do not manufacture both controllers and sensors.
To address this challenge, the IA recommends the CEC consider an approach similar to that taken in Flexible Demand Appliance Standards for Pool Controls (Docket 23-FDAS-01). That standard established definitions for a “connected device” and a “connected ready device” that provide a model for irrigation controllers.
Recommendation:
- The IA recommends the CEC establish a definition for “smart watering capable device” to include an irrigation controller that performs to the WaterSense specification when paired with the relevant sensor or communication device.
We stand ready to engage with CEC staff to further develop this concept and we appreciate the opportunity to provide input on the CEC’s actions to date. Please contact Nathan Bowen (nathanbowen@irrigation.org), IA policy and industry advancement vice president, for additional information.
Sincerely
Nathan Bowen
Policy and Industry Advancement Vice President