I am please to see the draft LEED reference the EPA WaterSense fixture specification, but I have concern -- the current use of WaterSense for urinals and commercial (flushvalve) toilets, does not take into account the manufacturer effort to "Universalize" the fixture and establish flow-rate from the flush-valve volume.

A single urinal that we manufacture, like our Washbrook, will operate effectively at a range of .125gpf - 1.0gpf. This simplifies inventory, eliminates duplication of packaging and technical documents, and allows selection of multiple flush options depending on the facility requirements.

But today, this same urinal exceeds the maximum of WaterSense of .5gpf. The system of Flush-valve and fixture is what should be considered, or only the flush-valve upon which we base the system flush volume.

The WaterSense guideline does not yet address specialty fixtures for children, hospitals, prisons, clinical application.