Declaration of Charles Wodrich in Support of Supplemental Comments of the Plumbing Manufacturers Institute Regarding the Economic Impacts of the Proposed Definition of “Showerhead," Docket No. EERE-2010-BT-NOA-0016.
Charles Woodrich was tasked with evaluating the costs associated with changing the definition of "showerhead." Based on Woodrich's data, the total cost of changing the definition would result in $108,700,000. The revenues generated annually by products that could be affected by the proposed definition of “showerhead” would total $303,300,000. If tub/shower combos and diverter valves are excluded from the combined
revenues above, the total would be reduced by approximately $80,000,000, to $223,300,000. The combined one-time costs and recurring costs reported to W&W were $412,000,000.