Water Sense
WaterSense® Pool Covers Notice of Intent (NOI)
Public Meeting Summary
WaterSense® Pool Covers Notice of Intent (NOI)
Public Meeting Summary
November 15, 2018, 1:00 to 3:00 p.m. Eastern, Webinar
Meeting Summary
Stephanie Tanner, the U.S. Environmental Protection Agency (EPA) WaterSense program's
Lead Engineer, welcomed everyone to the meeting, clarified how to use the webinar software,
and reviewed the meeting agenda and purpose for the audience. The purpose of the webinar
was to introduce a new group of stakeholders to the WaterSense program and review the
WaterSense Notice of Intent (NOI) to Develop a Specification for Pool Covers. The PowerPoint
slides from this presentation can be reviewed on the WaterSense website at
www.epa.gov/watersense/pool-covers.
After reviewing the meeting agenda, Ms. Tanner polled attendees on what types of
organizations they represent to give presenters a sense of the audience. The results are shown
in Figure 1. A full list of the attendees and a list of presenters are presented in Appendix A.
Who Do You Represent?
¦ Pool and/or Pool Cover Manufacturer/Retailer
¦ Water and/or Energy Utility
¦ Pool Installation/Service Professional
¦ Certifying Body
¦ Other
Figure 1. Poll Question #1
The presentation discussion and participant questions and comments are summarized below.
1. Introduction
Ms. Tanner provided an overview of WaterSense, a voluntary program that labels water-
efficient, high-performing products, including the program's history and the typical WaterSense
specification development process. WaterSense interacts with industry and other stakeholders,
such as standards committees and utilities, during this process. She noted the criteria the
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Water Sense
WaterSense® Pool Covers Notice of Intent (NOI)
Public Meeting Summary
program uses for product evaluation and labeling. Through 2017, WaterSense has helped save
2.7 trillion gallons of water and $63.8 billion in water and energy bills.
2. Pool Covers Background
Tessa Roscoe (Eastern Research Group, Inc. [ERG]) described the background research
WaterSense has conducted on pool covers and how they can reduce water waste. She
described the types of pool covers and control mechanisms presently on the market, as well as
the many aspects of pool covers that influence consumer purchasing decisions. Ms. Roscoe
polled the audience about which types of products the manufacturers in attendance
represented. The results are shown in Figure 2.
What Type of Pool Cover Do You Manufacture?
94%
¦ Automatic cover(s) ¦ Manual cover(s)
¦ Both automatic and manual covers Liquid cover(s)
¦ Not a Manufacturer
Figure 2. Poll Question #2
Ms. Roscoe reviewed the existing standards, codes, and test methodologies for pool covers
that WaterSense identified, as well as the existing studies and data available describing the
complex relationship between pool cover use and water savings. EPA's initial pool cover
research also included information on the product market and pool and housing construction
trends.
Given the complicated nature of calculating realized water savings resulting from pool cover
use, WaterSense used the available data to construct simple estimates of evaporative pool
water loss from an average residential in-ground pool under two differing climate scenarios,
shown in Table 2. These water losses were then converted to energy losses, representing a
heated pool of the same size, shown in Table 3.
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Water Sense
WaterSense® Pool Covers Notice of Intent (NOI)
Public Meeting Summary
Table 2. Individual Pool Water Loss
Pool Size
Pool Size
Annual Pan
Evaporation Rate
Annual Water
Loss to
Evaporation
Annual Cost of
Water Loss1
Feet2
Inches2
Inches/year
Gallons/year
--
500
72,000
40
12,000
$130
500
72,000
100
31,000
$340
Table 3. Energy Costs from Individual Pool Water Loss
Pool Size
Pool Size
Annual Energy
Loss
Annual Cost of
Electricity
Energy Loss2
Annual Energy
Loss
Annual Cost of
Natural Gas
Energy Loss3
Feet2
Inches2
Kilowatt-Hour
/year4
--
Thousand Cubic
Feet/year5
--
500
72,000
32,000
$4,000
110
$1,000
500
72,000
81,000
$10,000
270
$2,700
Ms. Roscoe noted that there are many potential positive and negative impacts that use of a
pool cover can have on a complete pool system. She reviewed the outstanding questions and
data gaps included in the NOI related to the technical aspects of this product category.
Participant Questions
"Will drowning prevention and water safety characteristics of pool covers be part of the EPA
WaterSense certification determination, and if so, are comments welcome from drowning
prevention and water safety stakeholders?" Ms. Tanner responded that it has not yet been
determined whether EPA will require ASTM safety certification as a requirement for pool cover
labeling; however, WaterSense would welcome comments from any stakeholders that felt they
had any safety-related comments.
"To submit comments, is there a specific process? Instructions?" Ms. Tanner noted that all
comments and information can be sent to watersense-products@erg.com.
1 Assumes $11.02 per thousand gallons of water and wastewater, from: American Waterworks
Association (AWWA), and Raftelis Financial Consultants, Inc., 2017. 2016 Water and Wastewater Rate
Survey.
2 Assumes $0.13 per kilowatt-hour of energy, from: U.S. Energy Information Administration (EIA), 2016.
"Short-Term Energy Outlook." www.eia.aov/outlooks/steo/
3 Assumes $10.06 per thousand cubic feet of energy, from: EIA 2016, op. cit.
4 EPA estimates the energy lost through evaporation and that is required to reheat pool make-up water is
equal to 2.61 kilowatt-hour of electricity per gallon.
5 EPA estimates the energy lost through evaporation and that is required to reheat pool make-up water is
equal to 0.008 thousand cubic feet of natural gas per gallon.
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EPA
WaterSense® Pool Covers Notice of Intent (NOI)
Public Meeting Summary
Water Sense
3. Pool Covers NOI: Scope
Ms. Roscoe reviewed the definitions and terminology available in the existing standards,
codes, and test methods, which influenced the definition EPA has crafted for pool covers for
the purposes of a draft specification. She noted two products that EPA is currently considering
excluding from WaterSense labeling eligibility: winter pool covers and companion products,
such as reels or rollers. She reviewed the first two of the outstanding questions and data gaps
included in the NOI related to the scope of a draft specification, then addressed audience
questions on those topics.
Participant Questions
"Does the statistic on above ground pools shown on a previous slide include storable
aboveground pools?" Ms. Tanner responded that the breakdown of that statistic was presently
unknown.
"Will there be an evaluation of whether pool covers affect the chemical breakdown of the pool
and result in more chemicals that need to be added or have some other impact?" Ms. Tanner
explained that EPA always attempts to include in its draft specification development process
any research on the negative or unanticipated consequences of use of products. EPA would
welcome information on this topic.
"As we are not sure what outside data you may already be aware of or used, should we send all
data we have and can find?" Ms. Tanner noted that the NOI, available on the WaterSense
webpage for pool covers (www.epa.qov/watersense/pool-covers), includes a reference section
of all the studies consulted to date in EPA's research. She noted EPA would welcome any
contributions that are not already on this list.
"How long will the EPA be collecting comments from stakeholders? Is there an end date for
receiving public comments?" Ms. Tanner explained that there is no hard deadline for comment
submissions, but comments submitted within three months of this public meeting likely had the
best chance of promptly informing EPA's decisions on whether and how to move forward with a
draft specification. However, she noted, if a crucial piece of information came in later than this
date, it would certainly be considered.
"Is WaterSense planning on working with ENERGY STAR on this specification?" Ms. Tanner
explained that while these two programs do collaborate, they do not currently offer joint labeling
of products, and therefore a WaterSense specification for pool covers would not include
ENERGY STAR certification.
"Does WaterSense consider the deterioration rates of materials used, health and safety of the
chemicals and health effects of pool covers, and possible takeback by manufacturers?" Ms.
Tanner responded that EPA would examine each of these items during research and explained
that EPA often looks at durability of savings over time.
"What about takeback? Solid waste and end-of-life of product?" Ms. Tanner explained that a
WaterSense specification is not a lifecycle specification in the sense of the product's physical
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Water Sense
WaterSense® Pool Covers Notice of Intent (NOI)
Public Meeting Summary
lifecycle and impacts, but rather only examines the durability of water savings over a product's
prescribed useful lifespan.
Ms. Roscoe reviewed the final outstanding question related to specification scope that EPA
identified in its NOI. She polled the audience on whether the definition suggested by
WaterSense ("a cover which can be placed over the water area of a swimming pool and is
intended for use during the open swim season") is effective in identifying the scope of a
WaterSense specification. Results of the poll are shown in Figure 3.
Is the WaterSense definition of a pool cover
sufficient in effectively identifying the scope of a
WaterSense specification?
¦ Yes "No ¦ Need More Information
Figure 3. Poll Question #3
4. Pool Covers NOI: Water Efficiency
Ms. Roscoe described the known water efficiency test method currently used for pool covers in
Australia's Smart WaterMark program. She noted that WaterSense is considering establishing
water efficiency criteria that would require pool covers to reduce evaporation by at least 80
percent, in comparison to an open vessel. She reviewed the outstanding questions and data
gaps EPA has included in the NOI regarding pool cover water efficiency. Ms. Roscoe then
polled the audience to ask if the 80 percent efficiency criterion was reasonable for a
WaterSense specification. Poll results are shown in Figure 4.
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EPA
WaterSense® Pool Covers Notice of Intent (NOI)
Public Meeting Summary
Water Sense
Is the proposed 80 percent efficiency threshold a
reasonable criterion to establish for a
WaterSense specification?
32 °A
3%
65%
¦ Yes "No ¦ Need More Information
Figure 4. Poll Question #4
5. Pool Covers NOI: Performance and Product Testing
Ms. Roscoe discussed ASTM F1346 safety standard for pool covers, as well as lifecycle testing
as a potential component of a draft specification. Most notably, lifecycle testing would require
the definition of a pool cover lifespan. She also reviewed the outstanding questions and data
gaps EPA has regarding pool cover performance and testing.
6. Pool Covers NOI: Product Marking, Documentation, and Marketing
Ms. Roscoe described the current codes and standards stipulating pool cover labeling and
marking requirements and noted that no codes or standard currently require labeling or marking
for water efficiency or water savings associated with pool covers. She also reviewed EPA's
outstanding question regarding pool cover marking, documentation, and marketing.
7. Pool Covers NOI: Stakeholder Engagement
Ms. Roscoe described EPA's stakeholder input process during the development of a
specification and noted that many utilities across the United States, offer rebates related to
pools and pool covers. She reviewed EPA's outstanding question on how to engage
stakeholders in this new product category.
Participant Questions
"Any idea what the evapotranspiration (ET) rate is for pools?" Ms. Roscoe noted that the
evaporation rate is what is more pertinent for pools, and that it would vary based on the location
of the individual pool.
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EPA
WaterSense® Pool Covers Notice of Intent (NOI)
Public Meeting Summary
Water Sense
"It seems you will need standards for each climate area. Pan evaporation and length of season
vary widely. Is this practical?" Ms. Tanner explained that EPA would attempt to determine one
(or more) climates representative of the areas where pools are most densely located to help
pool owners determine what water savings use of a pool cover could expect for their pool. She
noted that EPA does not intend to make product testing onerous on the part of manufacturers.
"One of the big issues I have encountered firsthand is the pool maintenance staff seem to
believe that pool covers are detrimental to maintaining the pool. Will there be outreach to the
pool maintenance professionals? I'm in Northern California, but I suspect this is an issue
elsewhere as well." Ms. Tanner explained that EPA typically engages an entire industry on
water efficiency issues related to the product, as they are the subject experts. She also noted
that this subject will be addressed in the later sections of this presentation, but briefly described
the different products that EPA has produced for its systems approach to water savings (e.g.,
design guides, service professionals' certification).
"How can an industry representative volunteer for the standards development committee?" Ms.
Tanner explained that these committees have their owner membership requirements and
procedures but are generally open to industry stakeholders. More information may be available
later in the specification development process, once EPA has identified standard organizations
with which to engage on developing or modifying test methods.
8. Opportunities Within the WaterSense Systems Approach
Ms. Tanner gave an overview of the history of EPA's WaterSense system approach, and how it
builds upon WaterSense's traditional product-centered approach. She used EPA's WaterSense
activities in the landscape and irrigation industry as an example of a systems approach to
product labeling, how influencers can impact water use within a product category, and noted the
typical strategies EPA uses to improve water efficiency through a multi-pronged approach.
She described the influencers EPA has identified for pool systems, particularly pool covers,
other pool equipment, and design and maintenance professionals. She listed the potential
technical resources and programming EPA could initiate to bolster pool system water efficiency.
Ms. Tanner summarized outstanding questions and data gaps EPA has regarding the
development of these resources. She then polled the audience to gauge interest in alternative
resources to support water efficiency in pools. Results of the poll are shown in Figure 5.
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EPA
WaterSense® Pool Covers Notice of Intent (NOI)
Public Meeting Summary
Water Sense
Would you be interested in any of the following, beyond a
specification for pool cover? Select all that Apply.
70%
60%
50%
40%
30%
: I I I - I
0% m
9. Next Steps
Ms. Tanner directed the audience to the WaterSense NOI to Develop a Specification for Pool
Covers on the WaterSense webpage for pool covers (www.epa.qov/watersense/pool-covers)
and noted that background materials for all WaterSense labeled products, including NOIs,
comment-response documents, and draft specification materials, are available on the
WaterSense website for reference or for new stakeholders to gain a better understanding of the
specification development process. She requested that those attending the webinar submit their
comments, both positive and negative, or any additional pertinent information to watersense-
products@erq.com. Other questions regarding the WaterSense program can be directed via
email to the WaterSense Helpline (watersense@epa.gov) or by calling (866) WTR-SENS (987-
7367). Ms. Tanner announced that WaterSense intends to make the comments received on the
NOI for pool covers public.
Participant Questions
As follow up to a previous question regarding the ET rate for pools, it was noted that local
ordinances in his area requires landscape professionals to calculate the ET number for water
features within a landscape. The Model Water Efficient Landscape Ordinance (MWELO) in
California generally requires water features (such as pools) to be characterized with a high ET
value (0.7 to 1.0). Ms. Tanner noted that EPA makes a concerted effort to harmonize its
specifications with national codes and standards and advocates for the adoption of its test
methods in national, regional, and local codes and standards. EPA works collaboratively with
codes and standards committees to achieve this goal.
"Did you mention if this webinar will be available online? I'd like to access some of your data
that way." Ms. Tanner explained that the presentation slides and a meeting summary will be
Water-efficienct pool WaterSense
systems design guide specification for pool
filters
Certification or training Not interested in any
material for pool of the above
professionals
Need more
information
Figure 5. Poll Question #5
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Water Sense
WaterSense® Pool Covers Notice of Intent (NOI)
Public Meeting Summary
posted on the WaterSense website. Comments received will also be batch posted to the
website over time.
Ms. Tanner adjourned the meeting by encouraging those with outstanding question to contact
the WaterSense Helpline at watersense@epa.gov or (866) WTR-SENS (987-7367).
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Water Sense
WaterSense® Pool Covers Notice of Intent (NOI)
Public Meeting Summary
Appendix A: Meeting Participants
Attendee
Organization
Jacob Adili
UL LLC
Chadarut Anan
The Regional Municipality of York (Ontario, Canada)
Theresa Bellish
NSF International
Veronica Blette
U.S. Environmental Protection Agency (EPA)
Tom Bohner
Solar Safe Pool Covers, LLC
Doug Brune
U.S. EPA, Region 7
Greg Bundesen
Sacramento Suburban Water District (California)
Adam Carpenter
American Water Works Association (AWWA)
Christina Chicoraske
City of Oklahoma City Utilities (Oklahoma)
Carl Chidlow
Winning Strategies Washington
Cheryl Coltes
Southern Nevada Water Authority (SNWA)
Stephanie Cote
City of Guelph (Ontario, Canada)
Tom Dankel
Aquamatic Pool Covers, Inc.
Shirley Dewi
IAPMO R&T
LaMont Drechsel
CoverPools, of Zodiac Pool Solutions
Jeff Farlow
Pentair Aquatic Systems
Angela Fasano
Coachella Valley Water District (California)
Sean Golden
James River Design, LLC
William Granger
City of Sacramento (California)
Bruce Grogg
TLT Consulting on behalf of Latham Pool Products
Rhonda Gutierrez
Carpinteria Valley Water District (California)
Chavon Halushka
Santa Clarita Valley Water Agency (California)
Jeremy Harris
Region of Peel (Ontario, Canada)
Scott Harris
Las Virgenes Municipal Water District (California)
Morgan Hopkins-Crawley
Aurora Water (Colorado)
Jeff Knopp
Behnke Landscape Architecture
Alan Korn
Abbey's Hope Charitable Foundation
Fred Larsen
Irrigation Association
Laurel Loftin
Athens-Clarke County Water Conservation Office (Georgia)
Patrick J. Martin
Miami Dade Water and Sewer Department (Florida)
Peter Mayer
WaterDM
Heather Macnab
The Regional Municipality of York (Ontario, Canada)
Cary McElhinney
U.S. EPA, Region 5
Sean McNeil
City of Santa Rosa (California)
Qiaoli Meng
ICC Evaluation Service, LLC
David Nance
NSF International
Jennifer Nations
City of College Station (Texas)
Robyn Navarra
Zone 7 Water Agency (California)
Lisa Ohlund
East Orange County Water District (California)
Ed Oquendo
Rucoil, LLC
Cathie Pare
City of Santa Barbara (California)
Regan Ratliff
The Association of Pool and Spa Professionals (APSP)
Cooper Reaves
Contra Costa Water District (California)
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Water Sense
WaterSense® Pool Covers Notice of Intent (NOI)
Public Meeting Summary
Attendee
Organization
Felipe Reyes
Reyes Landscape Construction
Doug Roberts
Sweetwater Authority (California)
Karina Sandique
City of Santa Monica (California)
David Searcy
Medford Water Commission (Oregon)
Michael Shebek
Automatic Pool Covers, Inc.
Jacob Shiba
Elsinore Valley Municipal Water District (California)
Jennifer Shimmin
Coachella Valley Water District (California)
Gary Tilkian
Metropolitan Water District (California)
Jon Vann
IAPMO R&T
Rebecca Winters
Region of Peel (Ontario, Canada)
Ron Wolfarth
Rain Bird Corporation
Jessica Woods
City of Round Rock (Texas)
Presenter
Organization
Stephanie Tanner
U.S. EPA
Tessa Roscoe
Eastern Research Group, Inc. (ERG)
Amanda Forsey
ERG
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