California’s swimming pool industry has been reeling following adoption by the California Energy Commission of a new Title 20 set of regulation which requires two-speed or variable speed pool circulation system motors, along with appropriate control devices, on all new pool construction.  The Commission and its contract consultant hired to draft the regulations – Pacific Gas and Electric Company – largely failed to consult the industry when preparing the regulations.  After their adoption and becoming public, a great number of faults were seen which made sections of the original requirements largely unenforceable. 

SPEC and APSP’s Technical Committee were successful in having implementation of the regulations delayed while needed changes were negotiated between PG&E and the Technical Committee and then taken back to the Commission for adoption.  These regulations still remain a work in progress, even though they are, for the most part, in force today.

To provide a forum in which industry members could be informed and question knowledgeable sources, SPEC arranged to conduct a two hour seminar at the recent Western Pool and Spa Show in Long Beach titled, “Multi-Speed Pool Motor Mandate – A Debate.”  Questioning the state’s action was SPEC President and CEO Donald Burns. Providing articulate responses was Gary Fernstrom, PG&E’s lead engineer on the pool regulation’s development project.

Following is a review of the discussion that took place.  Many audience questions were also asked and answered which could not be included in this summery.  However, the text will provide answers to most, if not all, of the industry’s questions.

Burns:  Prior to January 1, 2006 , there were no Federal or State regulations governing swimming pool pumping energy efficiency.  This market was working perfect well on its own responding to consumer demand.  Why was it prudent or necessary for Government to intervene in private sector commerce that had been undisturbed and working well for decades.

·             California has 1.5 million private residential in-ground swimming pools, which if  operated simultaneously would demand the output of 6 entire power plants.  The opportunity exists to reduce this need to 2 plants, saving the cost and air quality impacts of 4 entire power plants with very little negative impact on pool owners. 

·             There was no definition of swimming pool pumping energy efficiency, or no test to determine it.  Since the pool industry had not developed a definition and performance testing, it was an appropriate role for government to establish a test for energy efficiency and a requirement that the results reported.

·             While more efficient 1-speed and extremely efficient 2-speed equipment was available in the market place, it was rarely used.  Similarly, since efficient equipment selection practices were not being followed, it was an appropriate opportunity to regulate given the low-costs and high benefits.

Burns:  PG&E was the proponent and advocate for pushing these regulations through.  What business does it have even doing this?  One would thing that PG&E would want to sell more electricity, not less?

·             PG&E has been ordered by the California Public Utilities Commission to make energy efficiency first in the “loading order”, which means the resource of first choice so long as it is less costly than new power plant capacity and energy.

·             To comply with this order, which is in the interest of all utility customers, PG&E operates a number of voluntary efficiency programs, where information, education, and rebates may be provided for good efficiency improvement opportunities, such as for swimming pool pumping.

·             To supplement its voluntary programs, PG&E advocated with the California Energy Commission and the U.S. Department of Energy for energy efficiency standards that eliminate the least efficient products from the market. 

·             This effectively offers a “carrot and stick” approach.  PG&E only advocates for standards for highly cost-effective opportunities that do not take away service and convenience provided to customers. 

Burns:  These regulations and the related hearing processes were a surprise and disruptive to the industry.  Why wasn't this communicated so that industry could have meaningful interaction during the discussion and decision making process?

·             Communication is always an issue with efficiency regulations, as it seems there is always someone who didn’t know what was happening.  PG&E has tried to widely communicate what it is doing and solicit input from swimming pool professionals, but honestly, it has taken some time to become involved in the industry and learn which representatives to involve.  PG&E now works closely with the APSP, SPEC , Pool and Spa News, many local tradesperson’s group chapters, and pool equipment wholesalers.

·             Admittedly, even with PG&E’s sincere best effort to communicate, efforts to improve swimming pool efficiency got off to a rough start.  Hopefully most would agree that its better now, but when did we ever see everyone in this industry agreeing about anything?

Burns:  There is a lot of confusion and misinformation in the industry about the efficiency regulations.  What are they and how are they being communicated to achieve full understanding and reach a wide audience?

·             This is a wide ranging issue. 

·             The regulations apply differently to manufacturers and sellers of pool pumping products.

·             Manufacturers must test, report to the CEC for listing, and label residential swimming pool pumps and motors in a specific way.  Pumps (products including both the pump and motor) and motors (pool pump motors) must be tested, their efficiency reported.  Motors must be labeled with their total HP (the product of nameplate HP times Service Factor), and pumps must be labeled separately with their HP.

·             Sellers of these products (manufacturer, distributor, wholesaler, retailer, and contractor) must assure that residential swimming pool filtration pumps be of 2, multi, or variable speed if 1 Total HP or over, and in all cases motors may not be of split phase or standard efficiency cap-start, induction run design (2-speed motors may be of cap-start, induction-run design on low-speed operation).

·             These regulations are widely discussed and covered in the trade press, but they can be found on the California Energy Commission web site (www.energy.ca.gov) on the Appliance Standards link.  Anyone in doubt may also call the CEC at 916-xxx-xxxx.  PG&E has also been working with the CEC on developing a customer communication letter for contractors to carry and reference when discussion pump replacement or repair.  This is expected to be available latter this summer.

Burns:  Who has to comply?

·             Anyone offering residential pool pump equipment manufactured for sale in California .

Burns:  What are the consequences for not complying?

·             It is a violation of California state law to not comply, and the California Energy may take “appropriate action” against those found out of compliance.  More likely though, contractors found to have installed pool pump equipment illegally would be subject to potential non-payment for work, customer initiated legal action, or action by the Contractors State Licensing Board.

Burns:  I've heard that some companies have been telling contractors that replacement motors are covered by these regulations.  I find nothing in the CEC ’s regulations that requires this. 

·             Replacement pool pump motors are not currently required to comply, according to CEC attorneys.  While it was our intention to cover them, they were inadvertently left out of the Scope of the Regulations; therefore they are temporarily not covered.  PG&E, APSP, and some individual stakeholders are currently working with the CEC to correct this.  It will require a vote by the Commission.  The estimated time frame is 6 to 18 months, depending on what priority the CEC gives it and the extent to which it might be opposed.

Burns:  Do these regulations apply to above ground equipment?

·             No, the regulations apply to residential, private, in-ground pools only.  Thought is being given to requiring improved efficiency for above ground filtration pumping efficiency.

Burns:  Do these regulations apply to non filtrations pumps, such as booster and fountain pumps?

·             No, residential filtration pumps only.

Burns:  Do these regulations apply to products for commercial pools?

·             No, residential, private, in-ground pools only.  Commercial pools are required by the health code to maintain a 6 hour turnover when the pools are open and available for use; therefore, reduced speed pumping is not an option.  When commercial pools are closed and not available for use; however, reduced speed pumping is an option and can save very significantly on operating cost.

Burns:  Are time switches and controls sold in the state required to be 2 speed?  If so, why is a two speed control needed for a single speed single pump under 1 HP?

·             This should probably be an exception to the regulation, but presently is not.  The intent of the control regulation is to assure that two speed or variable speed pumps are not installed without the control capability to operate on lower speeds as the default filtration pumping speed.

Burns:   One big problem is with the 2-speed requirement.  For a very old pool with small plumbing, the smallest 2-speed pump available may overpower it.  What can be done in this situation?

·             This issue was raised early on in the rulemaking process by SPEC .  That’s why pumps of less than 1 HP were exempted from the 2-speed requirement.  It should be noted that wherever HP is referred to here, it is Total HP (the product of the nameplate HP times the Service Factor, so a full rated ¾ HP pump with a service factor of 1.65 would exceed 1 HP and would not be exempted.

Burns:  Filters don't work properly with low speed pumping.  The water doesn't fill the filter enclosure evenly?

·             Water flow in filters tends to distribute and balance itself according the resistance presented by the membrane.  Filter manufacturers confirm that filtration performance of DE and Cartridge filters improves with reduced flow.  Filter container vessels will completely fill with water when all air is exhausted as it should be for safety.

Burns:  Operating on low-speed, most automatic pool cleaners do not work.  What can be done about this?

·          Cleaners requiring booster pumps can operate with filtration pumps operating at reduced speed, as low speed filtration pump flows are typically 30 to 35 GPM and this is adequate for booster pump suction requirements.  Some filtration pump powered suction and pressure side cleaners do not work well on low pump speed and flow, but 3 remedies are available:  1) Pump a few hours at high speed to accomplish cleaning and the remainder of needed filtration hours at low speed, 2) Replace the cleaners with models that do work well at lower flows, and balance the pool system to assure an adequate portion of the flow come through the cleaner when it is working, and 3) Install a robotic cleaner.

Burns:  Skimmers do not work properly on low speed, what can be done about this?

·             It is true that many skimmers do not work well on low speed, low flow pumping.  The pump speed can be increased for short periods during the day to provide intermittent as opposed to continuous skimming.  Also, during skimming cycles, maximum water flow can be diverted to the skimmers from main drains, etc.  With variable speed pumps, flow can be set to best match the needs of skimmers and other functions such as cleaning, water features, spas, and solar thermal pool heater collectors.

Burns:  Operating on low-speed, pumps will not pump water up to solar thermal pool heater collectors on rooftops.  Of what value is 2-speed in that case?

Fernstrom:

·             Most 2-speed pumps will pump water 20 feet up to a collector.  The problem here isn’t so much that the pumps won’t lift the water, but that the Total Dynamic Head resistance the collectors present to the flow of water is such that 2-speed pumps running on low speed won’t produce adequate flow through the tiny openings in the collectors.  The solution here is to use a solar thermal pool heating collector that presents little TDH resistance to water and allows for generous flow, or use a variable speed pump where the pump power and flow can be precisely matched to the needs of the collectors.

Burns:  To work properly, 2-speed motors must have compatible controllers.  That adds to the cost, making it too expensive for most pool owners to choose.  One contractor told me yesterday that he just bid a replacement job and the cost for an appropriate controller and the necessary change in wiring from 110 to 220 volts.  Such costs will obviously prove a disincentive to proper pool maintenance

·             It is true that the cost of new residential filtration pump installation, replacement, or repair will go up with this regulation, but value in operating cost savings to pool owners and the overall ben efit to the State vastly outweighs the added initial cost.  That’s why the California Energy Commission adopted these appliance efficiency regulations which PG&E proposed and advocated for.  

Burns:  These pumps won't prime on low speed.  What can be done about that?

·           This is a Title 24 Building Standards related question.  The issue is that if 3, 2 inch returns come back to the pump suction and all rise through valves to the pump suction manifold, it is possible that pumps might have trouble priming on low speed.  The ability of these pumps to prime is a function of the lift needed, and the cross sectional area of the water to be lifted.  There are 2 remedies:  Many of these pumps are set up to prime on high speed, which eases this problem.  The other alternative is to install the valves horizontally, manifold them, and come up through a single riser to lower the water surface cross sectional area. 

Burns:  Pool safety regulations require pool suction velocity to be below 6 feet per second.  If a variable speed pump is installed, how can one be sure that it won't inadvertently be reprogrammed to operate at a HP such as to exceed the maximum suction velocity?

·            Maximum speed can be set on all the variable speed pump products.  It is not reasonable to expect that the manufacturers of these products can protect against all inappropriate control outcomes by untrained personnel.  This is similar to suggesting that cruise controls on cars be limited to 65 miles per hour, so drivers won’t set them to run the car at a speed in excess of the speed limit!

Burns:  The proposed building efficiency standards for residential pools require the use of sweep elbows.  Does this really make any sense considering that eyeballs are required at the pool returns?

·           Well, no.  If you’re going to effectively put a fire nozzle at the end of the returns to the pool, dramatically raising the TDH resistance to the flow of water at that point, then sweep ells in the piping leading up to the eyeballs make little sense.  Good pool design doesn’t require so much restriction in the eyeballs that sweep ells don’t matter.  In properly designed pools, the value of the energy savings associated with sweep ells has been shown to be cost-effective.

Burns:  The proposed building standard requires 6 pipe diameters of straight pipe leading up to the pump suction inlet.  I’ve been told repeatedly that this is not necessary given that all pool pumps have strainer baskets which serve to reduce turbulence at the pump suction?

·             6 pipe diameters leading up to the suction side of the pump, where pumps have leaf traps, is probably not required, as the leaf trap itself serves to smooth turbulence that may result from sharp ben ds near the pump suction; however, pump manufacturers continue to recommend this practice and the energy regulations are not likely to be in conflict with manufacturer’s product installation recommendations.

Burns:  The motor efficiency of the current 2-speed motors running on low speed is down around 40%.  How can you call that energy efficiency and mandate it in standards?

·             Low motor efficiency is a fact for current 2 speed motors running on low speed.  This was a big surprise to me at one time when I was first getting involved with pool pumping energy efficiency.  Even the motor is less efficient, there is so much less work being done in the hydraulic system when pumping at half speed, that the overall system is little over twice as efficient, even with the motor performance considered.  Energy savings from current 2-speed pumps running on low speed are about 55% to 66%. 

·             A.O. Smith has recently introduced a high efficiency 2-speed motor which features cap-start, cap-run design on both high and low speeds.  This motor has significantly better low-speed efficiency performance and is well worth the extra cost.  New variable speed products hold up their efficiency very well at low speeds.  For example the Pentair Variable Speed pump has a 92% efficient motor on both high and low speeds.  This is remarkable!

I’ve just finished reading a 16-page research study on child drowning which was released at the end of April.  Commissioned by a group called the National Safe Kids Campaign, the study was released to coincide with “National Safe Kids Week” May 1 through May 8, a weeklong nationwide public education campaign.

Before I even went to the campaign’s website – www.safekids.org – to download the study and read the press release issued in connection with it, I tried to imagine exactly what conclusions the group would draw, based on their research.

You must understand that as the editor of this publication, I am primarily concerned with drownings as they relate to swimming pools.  I am primarily concerned with drownings of children below age 8; and I believe that the ultimate “layer of protection” when it comes to drowning prevention is constant and vigilant adult supervision. 

My guess was that the group would conclude that supervision is inadequate as a drowning-prevention tool and that only by erecting isolation fencing, installing alarms and securing covers would we have any impact at drowning prevention. 

With this thought in mind, I called up the press release online.  The headline read “New research shows nearly 9 out of 10 children who drowned were being supervised.”

Somehow, I was not surprised.

The first paragraph of the release stated, “New research revealed today by the National Safe Kids Campaign and Johnson  & Johnson shows that 88 percent of children who drowned were under the supervision of another person, usually a family member.”

But for me, the next sentence was far more telling. “Supervision,” it stated, “was defined as being in the care of another individual, not necessarily in their direct line of sight.”

So let’s see if I’ve got it right – if you are in charge of a child, but you’re not actually watching him, you’re still “supervising” him, according to this study!

And if that child happens to drown, but you’re not actually watching him, you’re still “supervising” him, so we can only conclude that “supervision” alone is not an adequate drowning-prevention measure.

The second paragraph was just as telling.  “While better quality supervision is critical,” it stated, “the study also found that many adults were not properly fencing pools, requiring use of personal flotation devices (PFDs) or teaching their children how to swim.”

Once again, I was not surprised.

“Even when parents say there are supervising,” a passage further down in the release states, “many are participating in a variety of distracting behaviors including talking to others (38 percent), eating (17 percent), and talking on the phone (11 percent).”

In other words, 84 percent of the parents who said they were supervising – weren’t.

As for the pool environment itself, the release states, “While 98 percent of pool- or spa- owning parents report that they have taken adequate steps to ensure children’s safety, most have not made the necessary environmental changes.”

“Nearly two-thirds (61 percent) of pool or spa-owning parents do not have isolation fencing around their pools or spas, and 43 percent have no self-closing and self latching gate.”

And then they throw in the following statement: “Installation and proper use of four-sided isolation fencing could prevent 50-90 percent of residential pool drownings.”

So rather than relying solely on the press release, I decided to go to the study itself to see exactly what the researchers found.  By way of background, the study looked into a total of 496 “unintentional drowning-related deaths” of children ages 14 and under in 17 states from January 2000 to December 2001.

I found it interesting that neither California, Florida, nor Texas were included in the study, even though they have the highest pool populations in the union.

Of all drownings reviewed, 39 percent occurred in pools, the study states.  So of 496 drownings, 193 occurred in pools over a 2-year period.  Now, understanding that this organization zealously calls for isolation fencing around every pool, I ask you to read the following paragraph, which appears on page 8 of the study:

“Where barriers to pools were examined in connection with pool drownings, 38 percent occurred at pools known to have perimeter fencing and 29 percent occurred at pools known to have isolation fencing (a fence completely separating the pool area from the house and the rest of the property).  Only 5 percent of cases occurred at pools known to be without any barriers at all.”

So let me see if I got that right – more that 5 times as many drownings occurred in pools equipped with isolation fencing as occurred at pools without any barriers at all!  I’d sure like to ask them about that one!

I don’t want to come across as a smart aleck when talking about something as seriously tragic as the drowning death of a child.  But there is something about the conclusions publicized and reached in connection with this study that smacks of “I’ve made up my mind; don’t confuse me with the facts!”

What this study is talking about is fewer than 100 drowning deaths each year of children in swimming pools.  That hardly constitutes an epidemic.

Then, they claim that nearly all of the children were supervised at the time the drowning occurred, but their definition of  “supervision” seems to indicated that a lot of it was not supervision at all.

Then, they claim (citing unnamed “studies” – not their own) that the vast majority of pool drownings can be prevented by isolation fencing, when their own figures indicate that drownings will still occur despite the presence of such fencing.

I reiterate my original position.  When it comes to drowning prevention, I believe that there is nothing out there more effective than constant and vigilant adult supervision.

Know where children are at all times.  When they are supposed to be near the pool, make sure that there is at least one adult – undistracted by anything around him or her – whose sole job it is to keep an eye on the kids.

You can teach children how to swim, and you can install as many barriers as you wish around a pool.  But the only way you are going to prevent children from drowning is to keep an eye on them at all times.