EPA Water Sense Comments on WaterSense® Notice of Intent (NOI) to Develop a Draft Specification for Pool Covers April 4, 2019 ------- WaterSense Comments on WaterSense® Notice of Intent (NOI) to Develop a Draft Specification for Pool Covers Table of Contents Alan Korn, Scott and Katey Taylor, Abbey's Hope Charitable Foundation 2 Dan Hinrichs, Clise Properties 5 Michael J. Shebek, Automatic Pool Covers, Inc 6 Tom Dankel, Aquamatic Cover Systems 8 Jeffrey Hughes, Mary Ann Dickinson, Alliance for Water Efficiency 11 Bruce Grogg, Scott Rajeski, Matt Rowe, Latham Pool Products, Inc 15 LaMont Drechsel, Cover-Pools Inc., A Fluidra Company 17 1 April 4, 2019 ------- EPA Comments on WaterSense® Notice of Intent (NOI) to Develop a Draft Specification for Pool Covers WaterSense Commenter: Alan Korn, Scott and Katey Taylor Affiliation: Abbey's Hope Charitable Foundation Comment Date: February 13, 2019 Email Text: Dear Ms Tanner, Attached above is the comment letter from Abbey's Hope Charitable Foundation regarding the pending WaterSense Program. Alan Korn Executive Director Abbey's Hope Charitable Foundation 202-680-8876 Email Attachment: See pages 3 and 4. 2 April 4, 2019 ------- A* abbey's HOPE SAFER POOLS. SAFER KIDS. February 12, 2019 Ms. Stephanie Tanner Environmental Protection Agency EPA Water Sense Program 1200 Pennsylvania Avenue, NW Washington, DC 20460 Re: WaterSense Notice of Intent Dear Ms. Tanner, Please accept this letter as Abbey's Hope Charitable Foundation's general support for the establishment of a WaterSense Specification for residential pool and spa covers. Abbey's Hope Charitable Foundation, does not have the technical expertise to comment specifically on all the detailed potential energy saving requirements and benefits of the program. We are, however, very interested in making sure safety is considered when crafting the program and in determining which pool and spa covers ultimately get ultimate WaterSense label. As you may know, each year in the United States, approximately 800 children ages 14 and under die from drowning-related incidents. In addition, as many as 20 percent of near-drowning survivors suffer severe, permanent neurological disability. The statistics related to entrapment deaths and injuries, although not as large, are just as alarming. The Consumer Product Safety Commission has reported that over the past 15 years there have been at least 85 reported entrapment incidents that resulted in 12 deaths. Each one of these deaths and injuries was (and is) preventable if adults watch children when they are swimming and the pools and spas themselves are compliant with good safety practices. We unfortunately know that these statistics are not just faceless numbers. In June of 2007, our six-year old daughter Abigail suffered a horrific injury while swimming in a public pool. That injury ultimately took her life. Abbey was playing in a wading pool when she unknowingly sat on a drain that was poorly maintained and unequipped with the appropriate safety devices. The powerful suction of the pool eviscerated Abbey. Her small intestine was ripped from her body. The serious injury was followed by 9 months of medical care, including 16 different surgeries, a triple organ transplant, several infections and most of her sixth year of life in a hospital bed. Despite the best medical care and attention and our constant vigilance and prayers, Abbey died March 20, 2008. Our daughter Abbey's hope was that no child should ever suffer like she did as a result of an improperly maintained pool. In her memory, we established our Foundation. One of our greatest achievements, to date, was helping the United States Congress pass The Virginia Graeme Baker Pool Safety Act (VGB Act) which requires entrapment safety devices on all public pools. The law was signed by President Bush in 2007. This landmark legislation is not, however, a complete solution. The VGB Act does not require the use of barriers like pool and spa covers to be used to protect against unfettered access. To that end, we work every day with 5021 Vernon Aue. Suite 164 uuuuw abbeyshope.org phone (952) 303.5421 e-mail info@abbeyshope.org mail Edina, Minnesota 55436 3 ------- state legislatures and code officials around the country to promote these extra layers of protection. So anything that helps in that promotion is, in our view, a worthwhile effort. A well-planned, well-crafted and well- implemented WaterSense label will most certainly support that goal. Pool and spa covers, when properly deployed, can prevent accidental drownings and entrapments and can provide homeowners with the peace of mind that their pool or spa will not pose a risk to family members and unknown visitors. We do believe, however, that the WaterSense moniker should be reserved (or at least preference given to) pool and spa covers that meet the specifications of ASTM F1346-91. Covers that meet this standard have to pass many tests that help ensure the product is safe. Tests like a static load test (to make sure the cover can support the weight of a child), a perimeter deflection test (to make sure there are no large openings around the cover that can provide access to a child) and a surface drainage test (that safe guards against dangerous amounts of water collecting on the cover's surface). The ASTM standard also requires appropriate consumer labeling and consumer education about safe use and potential dangers. An unsafe cover, on the other hand, is an ineffective cover. The EPA should want the ultimate WaterSense label to be used only on the safest products. We stand ready, willing and able to help the EPA in any fashion as this important program is developed. If you have any questions or need additional assistance, please feel free to contact our Executive Director Alan Korn by phone at 202-680-8876 or by e-mail at alankorn@msn.com. Sincerely, Scott Taylor Chairman & Founder Katey Taylor President & Founder Cc: Alan Korn, Executive Director 4 ------- EPA Comments on WaterSense® Notice of Intent (NOI) to Develop a Draft Specification for Pool Covers WaterSense Commenter: Dan Hinrichs Affiliation: Clise Properties Comment Date: February 15, 2019 Email Text: The only equipment we have is a hot tub that is enclosed. I have however managed properties in the past that had them. They are very efficient in saving energy by keeping the heat in the water and not in the air. Dan Hinrichs Director of Engineering Clise Properties/Hotel Division Best Western Executive Inn Loyal Inn La Quinta Inn & Suites 206-459-3945 dhinrichs@clisehotels.com 5 April 4, 2019 ------- EPA Comments on WaterSense® Notice of Intent (NOI) to Develop a Draft Specification for Pool Covers WaterSense Commenter: Michael J. Shebek Affiliation: Automatic Pool Covers, Inc. Comment Date: March 5, 2019 Email Text: Here is my letter for WaterSense. All the best, Michael Michael Shebek | President Automatic Pool Covers, Inc. 17397 Oak Ridge Rd. #100 Westfield, IN 46074 (800) 878-5789 Headquarters Website: APC-Mfq.com Email Attachment: March 4, 2019 To: Stephanie Tanner, CEM, LEED AP BD+C Lead Engineer WaterSense Program Environmental Protection Agency Washington, DC Via electronic mail An automatic pool cover (APC) is a motorized pool cover that operates with a touchpad and/or a key. APC's must meet standard ASTM 1346-91 (2018). This standard is a performance specification for safety covers and labeling requirements for all covers for swimming pools, spas and hot tubs." In general, an APC takes about 45 seconds to open and close, and when closed the pool is inaccessible and the cover must support a minimum of 485 pounds. When the pool and the APC are properly installed it can, and does, hold as much as 10 times that weight. Frequently, I am asked about the lifespan of automatic pool cover vinyl. In my 40 years of being involved in both an installation and service company and now as owner of a manufacturer of APC covers, I have seen the life of the automatic pool cover to be fairly predictable. The expected life of APC vinyl throughout the industry's nearly 60-year history has been between 6-8 years. There are two (2) main factors affecting a cover's lifespan: — The ingredients included in each manufacturer's vinyl recipe. — The pool's region within the US, and whether that region has high or low level Ultraviolet (UV) radiation rays. 6 April 4, 2019 ------- EPA Comments on WaterSense® Notice of Intent (NOI) to Develop a Draft Specification for Pool Covers WaterSense Finally, my company is Automatic Pool Covers, Inc. and we started in 1979 as an installation and service company in Indiana. After 24 years of installing covers, in 2003 with 30 employees, we began manufacturing our own cover systems as well as installing them in Indiana. Then in 2014, the company separated its installation and service employees into a separate company. Today, Automatic Pool Covers, Inc. employs 100 employees, and the service company also now employs over 100 employees. In conclusion, I'd personally like to thank the WaterSense® team for their time and effort to consider the effectiveness of automatic pool covers as a water, energy and child saving device. Sincerely, Michael J. Shebek CEO and Owner Automatic Pool Covers, Inc. 7 April 4, 2019 ------- Comments on WaterSense® Notice of Intent (NOI) to Develop a Draft Specification for Pool Covers Commenter: Tom Dankel Affiliation: Aquamatic Cover Systems Comment Date: March 13, 2019 Email Text: Here it is in pdf. Tom Dankel Aquamatic Cover Systems 200 Mayock Rd Gilroy CA 95020 p. 800.262.4044 x205 f. 408.846.1060 www.aquamatic.com Email Attachment: See pages 9 and 10. EPA 4 WaterSense 8 April 4, 2019 ------- Stephanie Tanner, CEM, LEED AP BD+C 11 March 2019 Lead Engineer WaterSense Program Environmental Protection Agency Washington DC via electronic mail Re: Regarding reasonable ways to mark products Dear Ms. Tanner, We are pleased that the NOI is moving forward, and the positive feedback received so far. We would like to address the questions regarding "marking" the products, and information of same. As everyone recognizes the EnergyStar logo, we are seeing this consumer awareness with the WaterSense logo, therefore, we think that the logo be added to the existing label that all ASTM F1346-91 covers al- ready have. Additionally, I would suggest adding the logo to the motors/drive units, and at the control switch. This would mean the logo would be visible on three places of the automatic pool cover. At point of sale, we would also add to all brochures (printed and electronic), website, and social media campaigns the WaterSense logo. We would support this with a fact sheet to further educate the consum- er and water districts. Aquamatic is a family business that is now heading into our 40th year, and located in the greater San Fran- cisco Bay Area community of Gilroy. We have just added on 10,000 sq ft, and employ just over 60 people. We have representation in every state in the union through our vast dealer network. While safety was the early driver, the pendulum has swung to consumers regarding environmental responsibility, and with the data we have, the consumer can easily realize the ROI that a covered pool has versus and uncovered pool. This is what is now driving sales and where we see the most growth, based on our direct feedback from consumers, and dealers alike, from not only our domestic market, but worldwide as well. 9 ------- I personally have gotten to know and work with many of your fine staff and the EPA, and would like to thank you and your team for your/their time and resources as we push to achieve a goal that is so very significant. Very truly yours, Tom Dankel VP Aquamatic Cover Systems Aquamatic Cover Systems 200 Mayock Rd. Gilroy CA 95020 10 ------- EPA Comments on WaterSense® Notice of Intent (NOI) to Develop a Draft Specification for Pool Covers WaterSense Commenter: Jeffrey Hughes, Mary Ann Dickinson Affiliation: Alliance for Water Efficiency Comment Date: March 13, 2019 Email Text: Hello, Please accept the attached as public comment on the WaterSense® Notice of Intent to Develop a Draft Specification for Pool Covers. Thank you for the opportunity. Best, -Jeffrey Jeffrey A. Hughes Director of Operations Alliance for Water Efficiency Chicago, Illinois AllianceforWaterEfficiency.org FinancingSustainableWater.org H om e-Water-Works. org 2018, 2017, and 2012 EM WaterSense A Excellence Award Winner JgL for Strategic Collaboration If you are interested in learning more about the Alliance, I encourage you to sign up for our email list. You will get a monthly email with efficiency news and resources, plus a series of emails that provide additional content and tell you a bit more about what being an AWE member means. Email Attachment: See pages 12 through 14. 11 April 4, 2019 ------- ALLIANCE FOR WATER EFFICIENCY WATERSENSE® NOI ON POOL COVERS Public Comment Submission on WaterSense® Notice of Intent (NOI) to Develop a Draft Specification for Pool Covers Commenter Name: Mary Ann Dickinson Commenter Affiliation: Alliance for Water Efficiency Date of Comment Submission: March 13, 2019 Submitted via: watersense-products@erg.com The Alliance for Water Efficiency (AWE) is supportive of WaterSense® seeking to increase the water efficiency of swimming pools. A WaterSense label could indeed be an important distinguishing factor when pool cover purchasing decisions are made. While AWE supports the broader intentions of the effort, AWE is skeptical that labeling this product alone will achieve meaningful water savings. Swimming pools remind us a lot of irrigation systems in that they are frequently complex systems involving many parts, including filters, pumps, fountains, chemicals, and more. When WaterSense chose to address irrigation systems, it understood the complexity inherent in them, and paired product labeling with certification of irrigation professionals to raise the bar of knowledge and understanding in the industry. AWE believes a similar systems approach will be required to make real progress on swimming pool water efficiency, an approach that includes maintenance professionals along with labeled products. AWE would like to see WaterSense develop a strategy to fully address swimming pool management from a water efficiency perspective, and in that approach applying the label to pool covers will be an important component. With these general thoughts in mind, AWE offers the following specific comments. II. Technical Background AWE is not aware of any additional codes or standards or test methods relating to pool covers and water efficiency. The information that we see comes from the utility experience of managing pool cover rebate programs. The Southern Nevada Water Authority (SNWA) has managed a pool cover rebate program for a number of years, and notes that some low-cost bubble covers (which could qualify for the WaterSense label based on the data presented), have an expected life of only 2-3 years in the Nevada climate. Given the quantity of plastic involved with this product category, increased longevity could be a "performance" consideration for WaterSense. AWE also recommends that manufacturers offer a 5 - 8 year (minimum) warranty for their product in order to qualify for any WaterSense label. March 7, 2019 12 ------- ALLIANCE FOR WATER EFFICIENCY WATERSENSE® NOI ON POOL COVERS III. Existing Studies on Water Efficiency of Pool Covers AWE believes that there have been presentations on the impact of pool covers at the WaterSmart Innovations Conference and Exposition starting in 2014, mostly based on research conducted in Southern Nevada. AWE encourages WaterSense staff to go through the 2014 - 2017 conference proceedings to find these presentations, which include information on the frequency of use of pool covers and expected savings. E.g. The Southern Nevada Water Authority's Pool Evaporation Assessment: An Assessment of Evaporative Rates from Single Family Residential Swimming Pools, 2013 [PDF1 Beyond this research, AWE is not aware of any studies on the impact of pool covers, and believes that additional research may be warranted before a WaterSense specification is developed. IV. Product Market The cost of pool covers that might qualify for the WaterSense label range from $300 - $10,000 or more. If only the most expensive covers are included in the specification, then WaterSense-labeled covers may never find their way into above-ground backyard pools - which might just be the true "underserved" segment of this market. AWE is concerned that neither the pool cover makers nor the pool industry itself is self-aware enough to respond to a WaterSense label. Awareness about the increased importance of water efficiency in the operation and management of swimming pools is needed. This relates to the need to address pool efficiency from a systems-approach. There is the also issue of making pools themselves "cover ready" and "cover friendly". Many pools are simply not designed with a cover in mind, and that needs to change as part of the market transformation WaterSense is working towards. V. Scope AWE believes WaterSense has an acceptable definition of pool covers, and is not aware of any companion products worthy of inclusion. VI. Water Efficiency AWE believes the 80% evaporation reduction is a reasonable criterion for WaterSense to adopt. The issue of water features (fountains, waterfalls, water slides, and other decorative features) that are integrated into pool systems and the surface area they represent must be considered. VII. Performance and Product Testing AWE believes that safety and product longevity must be considered. ASTM F1346-91 may be a venue to incorporate this consideration. March 7, 2019 13 ------- ALLIANCE FOR WATER EFFICIENCY WATERSENSE® NOI ON POOL COVERS Consideration for safety should also be made, if that is an appropriate item to include in the specification. VIII. Product Marking, Documentation, and Marketing AWE believes this product could be labeled on the packaging, on the product itself, and in promotional materials related to the product. WaterSense should have detailed information supporting the label on its own website. IX. Stakeholder Engagement To be successful, AWE believes that WaterSense needs to engage the broader swimming pool industry in the effort to develop water-efficient swimming pools. Simply labeling pool covers will not be enough. X. Additional Considerations for Promoting Water-Efficient Pool Design and Operation Swimming pools are similar to irrigation systems in that they are frequently complex systems involving many parts, including filters, pumps, fountains, chemicals, and more. When WaterSense chose to address irrigation systems it understood the complexity inherent in these systems, and paired product labeling with certification of irrigation professionals to raise the bar of knowledge and understanding in the industry. AWE believes a similar systems approach will be required to make real progress on swimming pool water efficiency, an approach that includes maintenance professionals along with labeled products. AWE would like to see WaterSense develop a strategy to fully address swimming pool management from a water efficiency perspective, and creating a WaterSense label for pool covers will be an important component. XI. Final Comments AWE encourages WaterSense staff to speak directly with Toby Bickmore of the Southern Nevada Water Authority and Gary Tilkian of the Metropolitan Water District of Southern California about their program management experiences with pools covers and related products. March 7, 2019 14 ------- A Comments ori WaterSerise® epa Notice of Intent (NOI) to Develop a Draft WatCT" SCTISC Specification for Pool Covers Commenter: Bruce Grogg, Scott Rajeski, Matt Rowe Affiliation: Latham Pool Products, Inc Comment Date: March 20, 2019 Email Text: Please see the attached letter being submitted by the Latham team for the EPA. Thanks Bruce Bruce Grogg President Stone Edge Surfaces A Division of Turley International resources, LLC 4322 South 80th Street Mesa, AZ 85212 P: 844-786-6333 (844-STONEEDGE) C & T: 801-891-9131 E: Bruce@stoneedqesurfaces.com 6 b om\ El DG E SURFACES WeKOf^1 S'jdc Coicrcic Ov«flayj One of the Largest Manufacturers of Concrete Overlay & Decorative Concrete Products in the US Download the NEW Job Estimator Pro™ APP from iPhone or Google Play Store or go to www. jobestimatorpro. com for more exciting info!! A Dn-xdori Turley international Resources cVJet 'dge coN*fymp ¦rtcnm&ioMtes °* > Email Attachment: See pages 16 and 17. 15 April 4, 2019 ------- ATHAN behind e very pool Date 3/15/19 As the former CEO of Pool Cover Specialists, and current Consultant for Latham Pool Products, pool water evaporation is an issue we've been continually confronted with. On average, through evaporation, swimming pools can lose approximately % to V* inches of water each day. These numbers are variable and depend on factors such as, but not limited to, wind intensity across the surface of the water, humidity, the time of year, and sunlight. The sum of the daily loss of water to evaporation equates to an estimated 2 to 4 inches of water loss per week for average sized pools, or about 10,000 to 25,000+ gallons of lost water per year per pool. Evaporation can be so extreme in some areas that many pool owners think they have a leak and will invest in leak detection services or reach out to the pool builder, repair services, and even the manufacturer for help. Evaporation is the source of the greatest loss of water for almost every swimming pool in the US. Luckily, there is a simple and straightforward solution. The addition of a pool cover will reduce, immediately, evaporation by 30% to 50% (as per the DOE) or up to 90% (as per the 2016 Cal Poly Study). Logically, use of the pool cover is the key component in the reduction of evaporation. The ability to easily remove and replace a cover over a pool, or the "Convenience Factor," has been shown to be a strong indicator and has been closely correlated with pool owners' utilization of a pool cover. Understanding the consequence evaporation has on the loss of pool water begins to shed light on the gravity of the situation. Following these simple steps, pool owners can determine how significant their water loss is: Identify and make note of a specific location around the pool Measure the distance from the underside of the pool coping to the surface of the water Make note of the date and time the measurement was taken Avoid the addition of any water or use of the pool for a one-week period At the conclusion of the week, and at the same location as the initial measurement, measure the distance from the underside of the pool coping to the surface of the water The results can be converted into gallons lost per week. 16 ------- Employing a hypothetical situation, a 20' wide x 40' long pool, with a surface area of 800 sq. ft. (surface area is L x W) is considered. Measurements, taken from the underside of the pool coping to the water surface, were 9", the second measurement taken a week later at 11". - Assuming the level dropped 2" (ll"-9"=2") or 2/12 = .166 ft. - VOLUME OF WATER LOST: 20' x 40' x .166' = 133.33 cubic feet There is 7.48 gallons of water per cu ft. AMOUNT OF WATER LOST: 133.33 cubic feet x 7.48 gallons per cubic feet = 997.3 gallons per week Based on studies performed by the Department of Energy and Cal Poly, given the example above, taking advantage of a pool cover could potentially save between 300 to 897 gallons of evaporated water per week. To better put these numbers in perspective, a pool cover could ultimately prevent 15,600 to 46,644 gallons of water from vaporizing into thin air each year. Surprisingly, a significant number of automatic pool cover sales come from individuals who have existing covers for their pools. While well intentioned, the existing covers were too cumbersome and inconvenient to utilize on a regular basis. Without the level of convenience afforded by an auto cover (push-button operation that permits a pool owner to extend or retract a cover in seconds), it was just not feasible for the pool owners' other cover to be used on a daily basis as a water saving, energy saving, or life saving device. Despite wanting to be environmentally-responsible pool owners, most found that removing and replacing a manual style cover requires more than 1 person and "time" they didn't have. Ultimately, there is simply no other way to save water on a swimming pool without installing and employing a pool cover. Manual covers will never provide the convenience of an automatic pool cover, and consequently manual covers will never be exploited to their full potential. As a result, concerning pools, when preserving water, energy, and lives are at the forefront of importance we are sincere advocates for automatic covers over manual covers (i.e., tie-down covers, solar blankets, bubble covers, etc.) receiving a WaterSence designation. Thank you for your time and consideration in this matter. Sincerely SWe tfnoyy Scott "JRcije&ki Watt IRowe Bruce Grogg Consultant for: Latham Pool Products, Inc. Scott Rajeski CEO Latham Pool Products, Inc. Matt Rowe VP, Auto Covers Operations/EHS Latham Pool Products, Inc. lathampool.com | 787 Watervliet Shaker Road | Latham, NY 12110 | 800-833-3800 17 ------- EPA Comments on WaterSense® Notice of Intent (NOI) to Develop a Draft Specification for Pool Covers WaterSense Commenter: LaMont Drechsel Affiliation: Cover-Pools Inc., A Fluidra Company Comment Date: March 22, 2019 Email Attachment: 3/20/2019 Dear EPA WaterSense program management: We are writing concerning the draft specification NOI released September 20th, 2018 for Pool Covers. In the NOI, EPA proposes the question about WaterSense requiring safety standards such as ASTM F1346-91 as a safety performance criteria for the specification. As a manufacturer in the pool cover industry, who is committed to ensuring that we provide quality products for our users, as well as products that help maintain a safe, enjoyable recreational bathing environment for them, we unequivocally say "YES, safety standards should be considered when promoting a product for recreational pool use that also helps save water, like a pool cover does." Most localities/jurisdictions enforce installation codes which require pool covers to be certified as complying with the requirements of standards such as ASTM 1346-91. This is often enforced in order to comply with many local pool permitting and construction requirements. Local Authorities Having Jurisdiction (AHJs) generally require documented proof to demonstrate that the cover manufacturer has taken the necessary steps to ensure that their pool cover is designed, manufactured and certified as being in compliance with the applicable requirements of relevant standards, such as ASTM F1346- 91. Generally, the AHJs and the pool construction and installation codes which they are required to enforce, are looking for layers of redundant protection for the user. A pool cover which has been certified by a Nationally Recognized Testing Laboratory (NRTL), such as Underwriters Laboratories (UL) or Intertek (ETL), as meeting the applicable requirements of the ASTM F346-91 standard, along with some other device, such as a fence to prevent unauthorized access to the swimming pool area, helps to ensure a compliant construction. This approach has been shown to be a proven method to prevent drowning and save lives. If these current requirements to comply with relevant safety standards such as ASTM F1346-91 were relaxed or removed, it would be a step backwards for the safety of the user and could contribute towards an increase in entrapment and drowning incidents, something which we all have worked very hard to decrease and eliminate. Safety is of the upmost importance to the automatic pool cover industry and we thank you for your time and consideration. Sincerely, LaMont Drechsel VP, General Manager Cover-Pools Inc. A Fluidra Company. 18 April 4, 2019 ------- |