SWIMMING POOL & SPA ASSOCIATIONOF NSW LIMITED

AB.N 50 076 560 391

32/350 LIVERPOOL ROADASHFIELD NSW 2131

PO BOX 154, ASHFIELD NSW 1800PHONE: (02) 9747 6644

FACSIMILE: (02) 97447916TOLL FREE: 1800802482

Water Conservation OfficeACTEW CORPORATIONGPO BOX 366CANBERRA ACT 2601

10Jun.11Email: waterconservation@actew.com.au

Dear Sir I Madam:

RE: REVIEW OF PERMANENT WATER CONSERVATION MEASURES& TEMPORARY WATER RESTRICTIONS

The Swimming Pool & Spa Association of NSW (SPASA NSW) would like to thank youfor the opportunity to comment on the Review of Permanent Water ConservationMeasures & Temporary Water Restrictions.

The Swimming Pool & Spa Association of NSW (SPASA NSW) is the peak body withinNSW and the ACT's pool and spa industry, representing hundreds of Australianbusinesses. Members of SPASA NSW include leading pool builders, manufacturers,suppliers, retailers, technical servicemen, subcontractors, installers, consultants andother allied trades, all of whom set themselves apart from the rest of the industry bysetting standards of skill, workmanship and ethical business behaviour in the bestinterests of pool and spa owners.

In response to your invitation, the Swimming Pool & Spa Association of NSW hasconsulted extensively with stakeholders within the ACT and requests that ACTEWCorporation give consideration to the following submission:

BACKGROUND

Stage 3 Temporary Water Restrictions were introduced in December 2006. Under thisstage, ACTEW's decision to not permit the filling of pools with potable water causedsignificant financial strain to the swimming pool and spa industry.

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SWIMMING POOL & SPAASSOCIATION OF NSW LIMITED

Due to a potential move to Stage 4 temporary restrictions in 2007, ACTEW conductedconsultation with SPASA NSW where the following concerns were raised:

• Financial implications to the pool industry as a consequence of the policynot allowing potable water to be used to fill pools.

• Attempts to identify alternative sources of water were largely unsuccessful.

• Health concerns with using recycled water Le, hormone contamination.

• Additional cost to customers to source water supply from outside of theACT and concerns that the water quality may be compromised.

• Existing ACT pool owners may not maintain or treat their pools due torestrictions which could prove a health risk.

In 2008, due to the concerns raised above, SPASA NSW approached ACTEW with a proposalfor a 'Water Offset Plan". This plan was centred around the concept that the volume of waterrequired to fill the pool could be conserved or saved through the resident purchasinq,implementing or upgrading certain water efficient measures and devices in and around thehome.

Additionally, from the customers perspective, monies that would ordinarily pay to have watercarted into the ACT, would be better spent on purchasing, implementing or upgrading certainwater saving measures and devices, thus creating a long term benefit. The water offset planwas designed to provide long term benefits to both the consumer and the community. The planwas introduced in November 2008 and is still in place for any resident in the ACT that wishes tofill a pool with potable water.

CURRENT CRITERIA

Under the current scheme of conservation measures, effective from 1 November 2010, thefollowing conditions apply to residential pool filling:

Pools and spas with a capacity of 3,000 litres or more must not be emptied, refilled, or filled forthe first time, unless:

(a) the occupier of the premises has lodged a water offset plan with ACTEW;

(b) ACTEW has approved the water offset plan;

(c) the occupier of the premises complies with the approved water offset plan; and

(d) the pool or spa is fitted with a cover (that covers at least 80 percent of thesurface area of the water) when the pool or spa is not in use.

Pools and spas with a capacity less than 3,000 litres may only be refilled, or filled for the firsttime, using a hand-held hose fitted with a trigger nozzle, a bucket or a watering can.

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SWIMMING POOL & SPAASSOCIATION OF NSW LIMITED

The only mandatory requirement to the exemption is that the pool or spa must be fitted with acover that covers at least 80% of the surface area of the pool or spa when the pool or spa is notin use.

The number of prescribed water saving measures or criteria the resident is required to meet isbased on the size/volume of the pool or spa, as follows:

Pool size estimate Category 1 Category 2 Total criteria required

3,000-12,000 litres 2 ctitetie 1 critenon 3 ctitetia

12,000-40,000 litres 3 ctitetie 1 critetion 4 ctitetia

40,000-100,000 litres 4 ctitetia 1 ctiierion 5 cmetie

MANDATORY

• The swimming pool must be covered when not in use, and must cover at least 80%of the total surface area of the pool.

CATEGORY 1

• Has at least one rainwater tank installed, the water from which is available for use;and/or

• Mulch is used on all garden beds; and/or• Drip irrigation systems are installed on most (that is, more than 50 percent) of the

garden beds; and/or• The swimming pool uses a cartridge filtration system instead of a sand filter; and/or• The swimming pool filter uses a water efficient medium instead of sand for filtration.

A "water efficient medium" includes any filtration device (such as recycled glass orzeolite) able to demonstrate a 20% or greater reduction in water use; and/or

• Dual flush toilets t; and/or• Three star or better water efficient showerheads; and/or• Four star or better water efficient washing machine t

CATEGORY 2• At least one of the occupiers has attended an ACTEW Waterwise Gardening

Workshop and/or• Completed an ACTEW's Waterwise Gardening Quiz online, and/or• At least one of the occupiers has had a GardenSmart Service carried out by the ACT

Government; and/or• Rain/Soil moisture sensors are installed on, and are used in conjunction with, a

garden irrigation system, and/or• Tap aerators are installed on all taps at the property

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SWIMMING POOL & SPAASSOCIATION OF NSW LIMITED

ACTEW FEEDBACK

ACTEW acknowledge that the Water Offset Plan is a notable incentive but then go on to saythat the Water Offset Plan does not appear to be achieving the desired water savings,particularly in higher stages of temporary restrictions.

ACTEW data reports that from November 2008 to November 2010, ACTEW approved 468exemptions for the filling of new pools. Of the exemptions approved, approximately 1-2%needed to implement, purchase or upgrade measures to meet sufficient criteria for an approvalto be granted. ACTEW advise that most of the criteria advised to them was already in place atthe residence, and therefore no additional water savings were made.

SPASA NSW believes that the data reports provided by ACTEW indicating actual savings maynot accurately reflect direct savings as a result of the Water Offset Plan for reasons detailedwithin this paper and also include:

• Timing of Installation of Water Offset Plan Criteria• Homeowner Behavior• The removal of a Garden and installation of pool & hard landscaping (offset)• Exemption - Question Formatting

WATER OFFSET PLAN

SPASA NSW would like to raise factors which may have impacted the potential permanentwater savings achieved through the offset plan:

Legislation and Guidelines

• In the ACT, since 1993, It is mandatory for all new and retrofitted toilet systems (pan &cistern) to be dual-flush - as per ACT Planning and Land Authority (ACTPLA)!Environment & Sustainable Development guidelines and the Water and Sewerage Act2000 (ACT);

• In the ACT, from 31 March 2008, property owners who are building, redeveloping orsignificantly extending their properties need to demonstrate how they meet a new 40%water efficiency target, which applies to all residential, commercial and industrialdevelopments. This includes an option for rainwater tanks to be connected to at leasttoilet, laundry cold water and all external uses (as per ACTPLAI Environment &Sustainable Development guidelines);

Sustainable Conscience Household

The criteria outlined in the Water Offset Plan is now becoming the "norm" in many householdsdue to their growing awareness of the many available sustainable solutions. Consequently,these households are unable to provide further water savings when installing a pool as a directresult of the Water Offset Plan.

::: ~SPASA

SWIMMING POOL &: SPAASSOCIA nON OF NSW LIMITED

Swimming Pool Sale & Contract (Timeline)

As part of the sale and contract process of a swimming pool, consumers are alerted andconditioned from the very start regarding the criteria requirements to fill their swimming pool inthe ACT.

Moreover, it is not uncommon for swimming pools to be contracted well before they are actuallyconstructed. Swimming Pool builders in the ACT are well versed with the Water Offset PanCriteria and go to great lengths to advise consumers at the time of sale of what is required bythem in order to have their pool filled with water. Often the period between the sale of a pooland the point in which an exemption is applied for can be many weeks, months and in rarecases, more than 12 months.

We believe that ACTEW's statistics may not accurately reflect or acknowledge the buildersinitial influence on the customer in the early stages of the pool planning process by ensuringthat the Water Offset Plan Exemption Criteria are in place well in advance of the pool beingready to be filled with water.

Homeowner Behavior

There is little doubt that Influencing human behaviour is very difficult and complex.

Governments seek to regulate or influence the behaviour of individuals and organisationsthrough a range of policy tools, including legislation, regulations and subsidies.

Whilst a homeowner may initially satisfy the Water Offset Plan when installing a swimming poolthere is very little monitoring of the actual ongoing water savings of the related homeownersresidence. The collection of this data is paramount as it would highlight the homeowner'sbehaviour and indicate positive or negative impacts based on the amount of water they use.

SPASA NSW believes that ACTEW together with industry can play a more positive role inmodifying a homeowner's behaviour well after they have satisfied the Water Offset Plan criteria.

Suggestions to improve homeowner sustainability behaviour may include:

• Education is vital to positive action: homeowners need to be better informed to Changebehaviour, and action must be backed up by incentives and recognition schemes.

Engage and empower homeowners, perhaps through better information andaccountability mechanisms to reduce their consumption: indices that mean somethingand are regularly updated.

• More informative "Handover" of swimming pools by the builder at completion stage

•

• Specific Swimming Pool Workshops

~SPASA

SWIMMING POOL & SPAASSOCIATION OF NSW LIMITED

SWIMMMING POOL WATER

It should be noted that when a swimming pool is installed a sizeable garden bed is removed.

SPASA NSW believes this offset needs to be considered in any statistical data. This offsetrequires statistical recognition as clause 2.3.3 of the "ACT Government Water Sensitive UrbanDesign" states: Canberra households use almost half their mains water for gardens.

Moreover, other water utility providers such as "Sydney Water" advise that the water usedoutside people's homes each day would fill 250 Olympic swimming pools! This is equivalent to25 per cent of Sydney's total household water consumption.

Swimming pools are rarely emptied completely after they are first filled, but they may lose somewater through evaporation and/or the homeowner's ongoing compliance with the Water Offsetplan.

Subject to the homeowner's behaviour, the Water Offset Plan Criteria provides sensible watersustainable measures to ensure:

Minimal Pool Water Evaporation due to use of pool coversProper use of Pool Equipment to maintain optimum efficiency and sustainabilityAppropriate use of Water Tanks, Drip Irrigation etcOther water wastage factors

WATER SUSTAINABILlTY "ACKNOWLEDGEMENT SCHEME"

The Water Sustainability message must include some form or consumer education andrecognition.

We all know that using water more efficiently makes sense for consumers, communities, andthe environment. Water-efficiency measures, as part of broader conservation efforts, can helpreduce water and wastewater infrastructure costs and conserve resources for futuregenerations.

SPASA NSW has previously raised the need to promote and acknowledge consumers whoproactively seek to fulfil criteria associated with the current the Water Offset Plan even if theyare mandated.

An "Acknowledgment Scheme" would provide that consumers who satisfy the criteria associatedwith the Water Offset Plan would be issued a display sticker and/or decal to promote theircontribution and commitment to water sustainability.

Under the "Acknowledgement Scheme", homeowners would be encouraged to affix stickersand/or decals on their garbage wheelie bins and/or fence posts to promote the fact that they areresponsible water users. By acknowledging a homeowners contribution, ACTEW couldcapitalise on its own initiatives and further promote the value of sustainable water solutions toother homeowners persuading them to consider and make smarter choices regarding wateruse.

~SPASASWIMMING POOL & SPA

ASSOCIATION OF NSW LIMITED

The "Acknowledgment Scheme" should be seen as a grassroots campaign which aims topromote water sustainability through the residents in the ACT as well as recognise thecontribution that the swimming pool industry make to the community.

SPASA NSW concedes that homeowners in the ACT who apply for pool filling exemptions maynot necessarily implement water saving measures out of choice. These measures are eitheralready installed at the property, or, if they are building a new property, most of these measuresare installed as a legislative requirement for final building approval. In this regard,ACTEW should still acknowledge the homeowners contribution as they are still activelyparticipating in water conservation.

The "Acknowledgement Scheme" aims to help recognise homeowners in the ACT who satisfythe Water Offset Plan criteria and promote behaviour change and adoption of water savingproducts in line with government and water industry needs.

PINNACLE OF SUSTAINABILlTY

SPASA NSW believes that the swimming pool industry has proactively supported and drivenwater sustainable change in the ACT, especially over the last 2.5 years.

In addition, the industry has since implemented all water sustainable means that are available toit at this time whilst continuing to actively keep abreast of emerging water sustainabletechnologies and systems.

Government, Regulators and Industry must recognize that only so much can be achieved at aparticular point in time and we must therefore look to other long term factors to assist with aholistic approach to water sustainability.

NEW CRITERIA - ADDITIONS

SPASA NSW strongly supports the Permanent Water Conservation Measures and Exemptionsin their current form, however, would like ACTEW to include an additional 2 options within the"Category 1" Criterion:

1. Backwash Minimisation System/s (for Media Filters only)

A Backwash Minimisation Systemls can be fitted in both new and old installations. The systemlsprevent excessive backwashing (e.g. oversized media filter, centrifugal I pre-filter device, backwashrecycle system, etc.)

Water Savings Estimate: The water savings can be up to 7000 litres a year through less frequentbackwashing.

2. Pre-Filtration Device (for Media or Cartridge Filters)

A Pre-Filter Device can be fitted to filtration systems in both new and old installations. It is fittedbetween the pump and the filter and separates out solids, thus reducing by more than half the amountof water consumed for cleaning the filtration system.

Water Savings Estimate: The water savings can be up to 4000 litres a year through less frequentbackwashing. Cartridge filters may only need to be cleaned once every oneor two years, depending on their size.

~SPASA

SWIMMING POOL & SPAASSOCIATION OF NSW LIMITED

SPASA NSW believes the addition of the above 2 Criteria would provide additional significantsavings if included within the Water Offset Plan.

CONCLUSION

SPASA NSW remains committed to working with ACTEW to ensure the objectives ofPermanent Water Conservation Measures and Exemptions Criteria remain unaffected.

It is the firm belief of SPASA NSW that matters raised within this paper will help foster improvedwater sustainability outcomes that will continually improve over time with direct benefits flowingto the community, government and to industry.

Should you require clarification on this paper please do not hesitate to contact me on Tel: (02)97476644, Mob: 0404818666 or email sdassakis@spasa.org.au

Yours Sincerel

Spiros OassakisChief Executive Officer