Water Sense
Comments on WaterSense® Notice of Intent (NOI)
to Develop a Draft Specification for Pool Covers
May 16, 2019

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	18
Tim Fielder, Latham Pool Products, Inc	19
Doug Bennett, Southern Nevada Water Authority (SNWA)	26
Regan Ratliff, Pool & Hot Tub Alliance	27
Mark Smith, Latham Pool Products, Inc	31
Rob Viergutz, Coverstar Central	32
John St. Clair, Jr., Coverstar Central	33
Margaret Riggs, Aquality Construction	34
May 16, 2019

Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Pool Covers
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
Email Attachment:
See pages 3 and 4.
May 16, 2019

abbey's HOPE
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,
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

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.
Scott Taylor
Chairman & Founder
Katey Taylor
President & Founder
Cc: Alan Korn, Executive Director

Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Pool Covers
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
May 16, 2019

Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Pool Covers
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 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.
May 16, 2019

Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Pool Covers
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.
Michael J. Shebek
CEO and Owner
Automatic Pool Covers, Inc.
May 16, 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
Email Attachment:
See pages 9 and 10.
May 16, 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.

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
Very truly yours,
Tom Dankel VP
Aquamatic Cover Systems
Aquamatic Cover Systems
200 Mayock Rd. Gilroy CA 95020

Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Pool Covers
Commenter: Jeffrey Hughes, Mary Ann Dickinson
Affiliation: Alliance for Water Efficiency
Comment Date: March 13, 2019
Email Text:
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.
Jeffrey A. Hughes
Director of Operations
Alliance for Water Efficiency
Chicago, Illinois
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.
May 16, 2019

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

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

Consideration for safety should also be made, if that is an appropriate item to include in the
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

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.
Bruce Grogg
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

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
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Email Attachment:
See pages 16 and 17.
May 16, 2019

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
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
The results can be converted into gallons lost per week.

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.
SWe tfnoyy Scott "JRcije&ki Watt IRowe
Bruce Grogg
Consultant for:
Latham Pool Products, Inc.
Scott Rajeski
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

Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Pool Covers
Commenter: LaMont Drechsel
Affiliation: Cover-Pools Inc., A Fluidra Company
Comment Date: March 22, 2019
Email Attachment:
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.
LaMont Drechsel
VP, General Manager
Cover-Pools Inc.
A Fluidra Company.
May 16, 2019

Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Pool Covers
Commenter: Tim Fielder
Affiliation: Latham Pool Products, Inc
Comment Date: April 10, 2019	
Email Text:
My name is Tim Fielder. I am the Product Development Manager at Plastipack Ltd. I
wanted to contact in regards to your considerations to building a Swimming pool cover
specification for the preservation of water resources. I noticed in the minutes of your
meeting you mention a gap in your data on how to access the performance of pool
covers. The pool industry has little testing, but we believe it is a useful and important
education tool for pool owners. This is an area that Plastipack as a company have a
wealth of experience and were wondering if our information and involvement would be a
use to you in this endeavour?
First, allow me to introduce ourselves:
Plastipack Ltd are a manufacturer of energy and resource saving products. Focused on
the preservation of water resources, reduction of energy and chemical consumption
through sustainable solutions. Providing high quality performance materials to specialist
fabricators we operate as a niche manufacturer of sustainable floating solutions for the
swimming pool, industrial and agricultural markets. The company service our fabricators
through the bulk supply of roll form materials to be welded and shaped into covering
solutions for the end users. Supplying a global market, 90% of our materials are
exported with the majority sold into mainland Europe. Plastipack devote our time to the
support of a global network of niche businesses, the ongoing improvement of our
products, processes and educating both fabricators and end users on the importance of
persevering resources and reducing the environmental and economic impacts of their
Our materials are designed to:
•	Preserve vital water resources through evaporation control.
•	Reduce energy and chemical consumption.
•	Provide the longest possible functional life.
•	Return the cost of investment in the savings provided within the lifespan of the
•	To be recycled at the end of their useful life.
This includes products designed specifically for the pool market for:
•	Providing the optimal solar heating possible.
•	Inhibiting algae growth without losses to solar performance.
•	Maintain a cool swimming temperature in hot areas without the use of
evaporative fountains.
For the industrial/ Agricultural markets:
•	Evaporation control
•	Heat retention
May 16, 2019

Comments ori WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Pool Covers
•	Heat reflection
•	Water Clarification
As a global supplier we are familiar with standard requirements such as the Australian
SMART water mark and have a great deal of experience testing pool cover performance
to develop such materials to their full potential. This includes a $130,000 investment in
the development of a bespoke swimming pool cover testing facility developed in
partnership with the University of Surreys Advanced technology Institute for the
evaluation of temperature, chemical, algae inhibition and of course evaporation control.
The facility was designed to monitor the pool environmental and the solar and
environmental conditions that impact performance This has led to the development of
covering technologies that have been recognised by the institute of physics for their
performance and service they provide. I have attached some images and a case study
example of our testing for your interest.
As part of our company's goal to educate pool users on the importance of preserving the
resources consumed in the use and maintenance of a pool and as the leading industry
innovators in energy and resource saving materials for the pool industry. We would be
very interested in assisting in any way we can in the development of standards and best
practices for the Water Sense goal of reducing consumption within the pool industry.
I hope this will be of interest to you and look forward to hearing from you.
Kind regards
Tim Fielder
Tim Fielder
Product Development Manager, Plastipack Ltd
T; +44 (0) 1424 851659 | F: +44 (0) 1424 853 909 |
E: tim.fielder@plastipack.co.uk
www.plastipack.co.uk || www.qeobubble.co.uk | www.vapourguard.com
Plastipack Ltd are
JQP Business Innoi
2018 for thcgrour
EnergyGuard'* Sel
Transmission mat*
Award 2018
to increase si
inhibit algae
IOP Institute of Physics
Plastipack Ltd are Winners of the
IOP Business Innovation Award
2018 for the grou ndbre&king
EnecgyGuard" Selective
Transmission material
An award winning solution
to increase solar gains and
inhibit algae
Email Attachment (Photos):
See page 21.
Email Attachment (Case Study):
See pages 22 through 25.
May 16, 2019

Comments ori WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Pool Covers
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1100 AM 03:151
19/07/16 19/071
Data Analysis Code - Plastipack Limited - University of Surrey - Knowledge Transfer Partnership (KTP)
May 16, 2019

© Plastipack Ltd
Selective Transmission
EnergyGuard™ Specific benefits:
Increases water temperature by up to 7°C
Go Algae growth is inhibited
Go Reduces filtration times by up to 50%
Go Reduces chemical consumption by up to 60%
GO Reduces energy consumption by up to 60%
Go Can be used as a winter cover
General cover benefits:
Go Available with GeoBubble™ technology
GO Eliminates water evaporation by 98% +
Go Reduces debris contamination
GO Saves money and shrinks your carbon footprint
Go 6 year pro rata manufacturer's warranty
The new EnergyGuard™ selective transmission patent applied for* swimming pool material presents the highest possible
savings in respect of reduced maintenance costs and offers solar gains without the threat of algae, all from a single pool
cover, making it the most advanced and blanket/cover yet.
Swimming pool cover materials can be traditionally
divided into three categories, each with different solar
performance and benefits:
•Opaque materials absorb solar energy,
blocking out light inhibiting algae growth and
transferring this energy into the top surface of
the pool water where it heats the water through
•High transmission materials allow the
maximum amount of the sun's energy to
penetrate, directly heating the water itself.
•Reflective materials redirect solar radiation
away from the water to produce a cooling
The midnight-blue colour of the New EnergyGuard™
selective transmission material absorbs the wave-
lengths that ordinarily promote algae's photosynthesis,
instead converting these wavelengths into heat through
conduction. The cover also directly transmits other
wavelengths into the pool water where they heat the
water directly. This means that all available wave-
lengths of solar energy are efficiently harnessed to heat
the pool while keeping the pool algae free at the same
time. This remarkable technical innovation creates a
high performance material capable of raising water
temperatures naturally by up to 5°C in the UK and an
estimated 7°C in warmer climates, reducing both
chemical consumption by 60% and energy consump-
tion by 60%, all in an algae-free environment. As such,
the new EnergyGuard™ selective transmission material
marks a significant breakthrough and a new era in
thermal pool covers / solar blankets.
'Patent applied for No: GB1509903.9

^ *¦ _ (*'
\ rl •- '

What is GeoBubble™ technology?
The GeoBubble™ material has a geometric bubble shape
developed specifically for swimming pool covers,
increasing the material's longevity and boosting overall
Traditional bubble designs exhibit excessive thinning at the
corners resulting in a far more vulnerable mateiral suscepti-
ble to premature degradation.
The smoother shape of the patented* GeoBubble ™
technology eliminates these weak points with a material
50% thicker at its thinnest point than those using the
traditional bubble designs. With the inclusion of a larger air
cell profile and addition of a structural arch to withstand air
expansion and prevent bubble collapse, combined with
Plastipack's UV anti-oxidising additive packages, the
material's lifespan has been increased by over 25%
"Patent No: PCT/2010/001851

In July 2013, a pool covered with the new EnergyGuard™
selective transmission material was compared simultaneously
1.	an uncovered control pool
2.	a pool covered with Plastipack's high
transmission Sol+Guard™ material
3.	a pool covered with the previous iteration of the
opaque high absorption EnergyGuard™
swimming pool cover material.
The four test pools were unheated outdoor pools, all 3.66m in
diameter with a water depth of 0.565m, situated in the South
East of the United Kingdom.
Temperature gain
Figure 1 shows that the new EnergyGuard™ selective
transmission cover had a dramatically increased heating
performance compared to the test pool covered with the
previous iteration of the EnergyGuard™
material. These increase of heating efficiency reaches
levels close to that of the high transmission Sol+Guard™
material, a translucent material designed for maximum
heat gain.
The new EnergyGuard™ increased performance can be
explained by the selective transmission properties of the
material filtering light to heat the water. By absorbing the
wavelengths responsible for photosynthesis, both the
new and previous iteration of the EnergyGuard™
material pass the associated heat to the rest of the pool.
However the new EnergyGuard™ material has the further
ability to transmit infrared wavelengths non-essential to
photosynthesis and very efficiently absorbed by the
water to contribute to a direct heat gain.
The purpose of the test was to record temperature variances
in each pool, from the build-up to the point at which the
temperature differences were constant. Figure 1 below
represents a day to night reading at the midpoint of testing.
Figure 1. Average pool temperatures 09/07/2013 to 10/07/2013
New EnergyGuard1
control pool
Time (24 hours)

Figure 2: Chemical usage compared as a percentage to an
uncovered pool

B? 60 -
Uncovered control
covered pool

Laboratory testing and development
Algae inhibition
Plastipack produced sample films with different pigments,
exhibiting unique optical properties absorbing the light
required for photosynthesis but transmitting the wavelengths
key to heating water. The heating potential of the covers were
then investigated through FEA (finite element analysis) as
shown in figure 4, laboratory experiments using a solar
simulator and product field testing as shown on figure 1.
Figure 4. Finite element anaylsis of swimming pool
cover material
Old EnergyGuard™
0 0
D*plh (m)
Turin (tj
New EnergyGuard™ Selective Transmission
Plastipack tested the films on their ability to inhibit algae
growth. Beakers containing gelatine balls of algae (Chlorophy-
ta Scenedesmus Quadruicauda) were covered with the
sample materials and exposed to a controlled light source.
The algae's respiration was then monitored by analysing the
pH of the water in which they were suspended.
The material's ability to inhibit algae growth was later
confirmed at field test facility where the controls were repeat-
ed and the water was tested in a natural environment during
the UK's spring season.
inhibits algae
Retains heat
Increases pool


Tim ft (s)
D*frih (m)

Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Pool Covers
Commenter: Doug Bennett
Affiliation: Southern Nevada Water Authority (SNWA)
Comment Date: April 18, 2019	
Email Text:
Dear WaterSense,
On behalf of the Southern Nevada Water Authority (SNWA) and our member agencies,
we would like to submit comment on the Notice of Intent to label pool covers. SNWA is
the regional wholesaler to the Las Vegas, Nevada metropolitan region. Our member
agencies serve approximately 2.3 million people.
The SNWA has offered a rebate on swimming pool covers since 2005. During that
period, we have incentivized purchase of more than 44,000 products and issued more
than $2 million in rebates.
The research cited in the NOI, as well as research conducted by SNWA have
demonstrated meaningful savings in both water and energy for this class of products. At
this time, SNWA does not require pool covers to meet specific technical thresholds. For
example, there are no requirements for UV resistance, chemical resistance, material
thickness, or other characteristics that may influence the durability and longevity of the
cover. The program design, however, has an expectation that the product should last
approximately three years. We suspect consumers also have limited knowledge to allow
them to determine the quality, effectiveness and longevity of various pool covers.
Whereas longevity of the product is a major consideration in its ability to conserve water,
we believe this criterion must be included in any labeling scheme. Some rebate
recipients report their product has functionally failed after a single season, while other
consumers can manager to keep a floating cover for up to three seasons.
We believe this class of products is appropriate for WaterSense labeling and encourage
the development of minimum standards.
Doug Bennett
Conservation Manager
Southern Nevada Water Authority
May 16, 2019

Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Pool Covers
Commenter: Regan Ratliff
Affiliation: Pool & Hot Tub Alliance
Comment Date: April 29, 2019
Email Text:
Good morning,
I would like to submit the attached comment in regards to the EPA WaterSense NOI.
Please reach out with any questions or concerns.
Thank you,

Regan Ratliff
Government Relations Associate
rratliff@phta.org | 703.838.0083 ext. 165
Pool & Hot Tub Alliance
2111 Eisenhower Ave., Ste. 500 4775 Granby Circle
Alexandria, VA 22314	Colorado Springs, CO 80919
Formerly The Association of Pool & Spa Professionals/National Swimming
Pool Foundation
Email Attachment:
See pages 28 through 30.
May 16, 2019

2111 Eisenhower Ave., Ste 500
Alexandria, VA 22314
April 29, 2019
Submitted Via Email To: Tanner.Stephanie@epa.gov
Stephanie Tanner, CEM, LEED, AP BD+C
Lead Engineer
WaterSense Program
Environmental Protection Agency
Washington, DC
Re: WaterSense NOI to Develop a Draft Specification for Pool Covers
Dear Ms. Tanner,
On behalf of the Pool and Hot Tub Alliance (PHTA), formerly the Association of Pool and Spa
Professionals (APSP) and the National Swimming Pool Foundation (NSPF), we would like to
submit the following public comment in response to the EPA WaterSense Notice of Intent
published on September 20, 2018.
PHTA strongly supports a WaterSense specification for automatic pool covers that meet the
ASTM F1346-91 Standard Performance Specification for Safety Covers and Labeling
Requirements for All Covers for Swimming Pools, Spas and Hot Tubs.
In 2012 the PHTA partnered with the International Code Council (ICC) to create the first ever
national code for swimming pools and spas, the International Swimming Pool and Spa Code
(ISPSC). The ISPSC is a comprehensive pool and spa code that is the only code to address all
aspects of pool & spa design and construction addressing quality, safety and energy and
conservation. The ISPSC has been developed and is updated under the rigorous ICC
government consensus process; to date the ISPSC has been adopted in 20 states and over
170 local jurisdictions (see Addendum A).
Through the adoption of the ISPSC, states and localities require standards for pool barrier
safety (Section 305). Section 305.1 of the ISPSC provides for ASTM F1346-91 pool safety
covers as a means of meeting barrier protection provisions. ASTM certified covers are required
to have a locking mechanism (key or key pad), which prevents unauthorized entry into the pool.
Leaving aside the dramatic water and energy savings for a moment; having a pool cover, which
meets ASTM standards, should be promoted as a Federal priority to all current and future home
The ISPSC also touches on energy conservation requirements; this includes section 303.1.3,
which requires a pool or spa vapor retardant cover be provided if certain types of pool or spa

heating are installed. This is required to control and reduce energy consumption, but an
additional benefit is minimizing water evaporation loss. However, whereas the pool barrier
requirements are more permanent and require a final inspection to ensure they are in place, the
vapor retardant requirement is much more difficult to enforce. By creating a WaterSense
specification for automatic pool covers there is more incentive for the consumer to use them as
a means for energy conservation and safety.
As stated in Energy Saver, a Department of Energy consumer resource on saving energy and
using renewable energy technologies at home, pool covers minimize evaporation from both
indoor and outdoor pools and conserve water by reducing the amount of make-up water
needed by 30-50%.
We understand that if certain pool covers receive the WaterSense moniker, this will improve
consumer awareness regarding the energy and water saving capabilities of this technology.
Understanding that drowning prevention is not part of the WaterSense mandate, we would still
argue that consumers should be encouraged to only consider technologies that save water,
energy, and perhaps the most precious resource, human life.
As outlined in this letter and on behalf of the many pool and spa professionals represented by
PHTA, we thank the WaterSense Program for the consideration of developing a WaterSense
specification for automatic pool covers.
Jennifer Hatfield
PHTA Government Affairs Director
About Us
The Pool & Hot Tub Alliance was formed in 2019, combining the Association of Pool & Spa
Professionals (APSP) and the National Swimming Pool Foundation (NSPF). With the mission to
"Celebrate the Water," PHTA facilitates the expansion of swimming, water safety and related
research and outreach activities aimed at introducing more people to swimming, making
swimming environments safer and keeping pools open to serve communities.
APSP, now the PHTA, is the world's oldest and largest association representing swimming
pool, hot tub, and spa manufacturers, distributors, manufacturers' agents, designers, builders,
installers, suppliers, retailers, and service professionals. Dedicated to the growth and
development of its members' businesses and to promoting the enjoyment and safety of pools
2111 Eisenhower Avenue • Suite 500 • Alexandria, VA 22314 • www.APSP.org

and spas, PHTA offers a range of services, from professional development to advancing key
legislation and regulation at the federal and local levels, to consumer outreach and public
safety. PHTA is the only industry organization recognized by the American National Standards
Institute to develop and promote national standards for pools, hot tubs, and spas.
PHTA is also the co-developer, along with the International Code Council (ICC), of the
International Swimming Pool and Spa Code (ISPSC) which has been adopted in all or parts of
over 20 states. PHTA is also represented on and participates in various other standards-
making organizations promulgating standards including the ICC, International Association of
Plumbing and Mechanical Officials (IAPMO), American Society of Testing and Materials (ASTM
F1346-91), and the National Electrical Code®. In addition, the PHTA provides educational
programs and monitors the accredited continuing education requirements for various licensing
programs for aquatics professionals. For more information, visit APSP.org or NSFP.org.
2111 Eisenhower Avenue • Suite 500 • Alexandria, VA 22314 • www.APSP.org

Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Pool Covers
Commenter: Mark Smith
Affiliation: Latham Pool Products, Inc.
Comment Date: April 30, 2019	
Email Text:
You would think that as an employee of a pool cover company, I'm always trying to sell
pool covers. And you would be right. But the true test is that I recommend to my family
and friends who are thinking about building a pool to always include an automatic pool
cover. The first reason is the level of safety they provide, especially when they have
young children. But a very close second is the savings on water and chemicals. It's very
common after working with a new autocover dealer to get stories about how surprising
those savings are, and what a great deal it is for the pool owners. I hope that with a
Water Sense designation, it will help more dealers, pool builders, and home owners
adopt automatic pool covers. Not only will it keep families safe, it will help keep our
limited resources secure, and allow those families to enjoy a great recreation choice in
an environmentally responsible way.
Mark Smith
Product Manager - Automatic Safety Covers
801-373-4777 EXT 6173
Fax# 801-772-2300
May 16, 2019

Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Pool Covers
Commenter: Rob Viergutz
Affiliation: Coverstar Central
Comment Date: May 1, 2019
Email Text:
Good morning. I wanted to say that the water savings of an automatic cover is very very
important to our green efforts.
I have been selling, installing, and training with people for 30 years. When a cover is
closed across the pool, there is almost no evaporation.
Working on an indoor pool in the winter was a big surprise.
When the pool was open the steam was so thick you can't see a person standing on the
other end of a 75' pool. Once the cover was closed, it only took about 40 seconds for the
air to clear. That's when I realized how much the cover helped.
The southwest has water problems now. Using an automatic pool cover can only help.
Just wanted to put in my two cents.
May 16, 2019

Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Pool Covers
Commenter: John St. Clair, Jr.
Affiliation: Coverstar Central
Comment Date: May 3, 2019
Email Text:
I wanted to provide supporting feedback to you on how much we value our automatic
pool cover. While I am involved in the swimming pool industry, I would like to share my
personal experience with the automatic pool cover on our pool. Using our cover, has
saved us thousands of dollars over the years we have owned our pool. We've seen
savings from reduced water evaporation, which in turn has reduce the loss of heat &
chemicals from our pool. Due to ease of use, our automatic cover was the best option for
us. While it can be an expensive option initially, based on use of the pool cover over
time, it really has save water, time which over time has saved us money.
Bottom line we love our automatic pool cover!
John St. Clair, Jr
May 16, 2019

Comments on WaterSense®
Notice of Intent (NOI) to Develop a Draft
Specification for Pool Covers
Commenter: Margaret Riggs
Affiliation: Aquality Construction
Comment Date: May 8, 2019
Email Text:
As a swimming pool construction company in a cold weather climate, a pool cover is an
essential component to our pool projects. The City of Boulder, CO as well as Boulder
County requires covers on all pools. Reasons include energy savings primarily the water
and chemical savings but also the safety features of an automatic pool cover. Almost all
residential swimming pools that Aquality Construction designs and builds will have an
automatic cover.
Margaret Riggs
Aquality Construction
3050 Industrial Ln. #100
Broomfield, CO 80020
303-469-2229 Fax 303-469-2221
May 16, 2019