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  • 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.

  • :::: =:=:::::SPASA

    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.

  • :::::: :=::::::SPASA

    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

  • :::: ::=::::SPASA

    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 ve

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