The draft states that the fixture and fitting replacement and retrofit policy must specify that “all newly installed toilets, urinals, lavatory faucets and showerheads must be WaterSense labeled for label-eligible product types.” Most of the properties that we have worked with are multi-tenant facilities, many with tenants occupying multiple floors. Mandating what fixtures must be installed in tenant spaces is going to be a major challenge for most properties. This being a prerequisite could pose many challenges and issues in the future. Also, if these fixtures are deemed either economically infeasible, or infeasible due to the piping at the building, they should not be forced to use fixtures that are incapable of maintaining proper pressure.
Chris, I've heard the same issue with piping in existing buildings. Sometimes you can only go so low before the building and municipal infrastructure creates limits unless you replace all of the piping.
I wonder if other folks have specific examples of this they could share?