Rescission of Useless Water Pressure Standards

5/9/2025

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Purpose: Rescind or amend water and energy efficiency standards established under the Energy Policy Act of 1992, which are claimed to make appliances (faucets, showers, bathtubs, toilets, clothes washers, dishwashers, etc.) more expensive, less functional, and less reliable.
Regulatory Directives:
- Directs the Secretary of Energy to use all lawful authority to rescind or revert to statutory standards the regulations in 10 C.F.R. sections regarding dishwashers, faucets, showerheads, water closets, and urinals, as well as associated definitions and efficiency standards for residential and commercial washing machines.
- Instructs the Secretary not to enforce any of these regulatory provisions pending their rescission or reversion.
Federal Register Notice: Requires publication of a notice clarifying the waiver of Federal preemption of state regulations related to water use or efficiency for showerheads, faucets, water closets, and urinals.
Legislative Recommendations:
- Directs the Secretary of Energy along with the Deputy Assistant to the President and Director of the Office of Legislative Affairs to jointly recommend actions to Congress.
- Recommendations include rescinding specific statutory provisions and potentially repealing the Energy Policy Act of 1992 in its entirety.
Legal Disclaimer: The memorandum does not create any enforceable rights or benefits for any party.

The rescission of water pressure standards could lead to increased water usage, which may conflict with sustainability goals and environmental initiatives that Vanderbilt University might support or be involved in.
Changes in appliance standards could affect the university’s operational costs if older, less efficient appliances are used, potentially increasing water and energy expenses.
There may be reputational risks if the university is perceived as not aligning with environmental sustainability practices, which could impact student and faculty recruitment, as well as partnerships with environmentally-focused organizations.
The university may need to reassess its sustainability policies and initiatives to ensure they align with the new federal standards and consider the potential impact on campus infrastructure and resource management.

Vanderbilt’s Facilities Management may need to evaluate the impact of these changes on campus infrastructure, particularly in terms of water and energy efficiency in university buildings.
The Vanderbilt Institute for Energy and Environment could see an increased demand for research and expertise in energy policy and sustainability, providing opportunities for collaboration with federal and state agencies.
Environmental Science and Engineering Programs may need to adjust their curriculum to reflect changes in federal energy and water efficiency standards, ensuring students are prepared for the evolving regulatory landscape.

The potential increase in water and energy costs due to less efficient appliances could impact the university’s budget, necessitating adjustments in financial planning and resource allocation.
There may be opportunities for Vanderbilt to secure funding for research and development in energy efficiency and sustainability, particularly through collaborations with federal agencies and environmental organizations.
Changes in federal standards could affect the availability of grants and funding for sustainability initiatives, requiring the university to explore alternative funding sources or partnerships.

Relevance Score: 3 (The memorandum presents moderate risks involving compliance and sustainability considerations.)

Vanderbilt’s Facilities Department should evaluate the potential impact of rescinded water pressure standards on campus infrastructure. This includes assessing whether current appliances and fixtures will need adjustments or replacements to align with new standards, ensuring cost-effectiveness and functionality.
The Office of Sustainability should review the implications of these changes on Vanderbilt’s sustainability goals. This may involve recalibrating water conservation strategies and exploring alternative methods to maintain environmental commitments without federal mandates.
Vanderbilt’s Legal and Compliance Office should monitor any legal developments or state-level responses to the federal rescission of water pressure standards. This will help ensure that the university remains compliant with both federal and state regulations.
The Department of Environmental Engineering could explore research opportunities related to the effects of changing water pressure standards on energy efficiency and appliance performance. This research could contribute to broader discussions on sustainable practices and influence future policy recommendations.

The rescission of water pressure standards presents an opportunity for Vanderbilt’s School of Engineering to innovate in the design of more efficient and cost-effective water appliances. By leading research and development in this area, the university can position itself as a pioneer in sustainable engineering solutions.
Vanderbilt’s Public Policy Studies Program can engage in policy analysis to assess the broader implications of deregulation on consumer costs and environmental impact. This analysis can inform public discourse and guide future legislative efforts.
The university can leverage these changes to enhance its partnerships with industry leaders in water and energy efficiency, fostering collaborations that drive innovation and practical applications of research findings.

Relevance Score: 3 (Some adjustments are needed to processes or procedures due to potential impacts on infrastructure and sustainability goals.)

Average Relevance Score: 3.2

Recommendations to Congress must be submitted within 60 days from May 9, 2025.

Relevance Score: 3

Department of Energy (DOE): Tasked with rescinding or amending specified water and energy efficiency standards and issuing a Federal Register notice, making it central to the memorandum’s directives.
Department of the Interior: Listed as a recipient of the memorandum, indicating its involvement or oversight in related regulatory matters.
Office of Legislative Affairs (Executive Office of the President): Represented by the Deputy Assistant to the President and Director, who is instructed to collaborate on recommendations, aligning legislative and executive priorities.
National Energy Dominance Council: Its Chair is designated to facilitate the joint submission of recommendations to Congress, implicating this council in shaping energy policy responses.

Relevance Score: 2 (A small number of Federal Agencies are impacted by the directive.)

Secretary of Energy – Directed to review, rescind, or amend existing water and energy usage standards, issue a Federal Register notice regarding the waiver, and refrain from enforcing current regulatory provisions pending revision.
Secretary of the Interior – Included in the memorandum’s addressees, indicating a role in oversight or coordination, though specific directives were not detailed.
Deputy Assistant to the President and Director of the Office of Legislative Affairs – Tasked with jointly preparing and submitting recommendations to the President regarding legislative changes to energy and water efficiency statutes.

Relevance Score: 5 (Directives affect Cabinet-level officials and key White House appointees, indicating high strategic impact.)