Consultation on proposed changes to powers to restrict non-essential uses of water

This response by the British Swimming Pool Federation is on behalf of our two member organizations; the Swimming Pool and Allied Trades Association representing pool contractors and suppliers, and BISHTA - the spa and hot tub association. We also address an issue affecting another member organization, the Swimming Teachers’ Association, in relation to private non-domestic sector swimming pools.

Summary

Domestic swimming pools and hot tubs consume less water daily than a single household bath

Limiting the use of private swimming pools by water restrictions will divert consumers to use public facilities, which will consume greater quantities of water and energy

A ban on filling new hot tubs will destroy the market for this product

Sensible water conservation measures are already practised in this sector

Hundreds of small and medium size companies in this industry will be seriously affected by bans and Drought Orders

We do not believe a non-essential uses ban should apply to this sector, but could consider a limited restriction for a small minority of wasteful users.

Comparison of daily average water use

Click here to view a table showing a comparison of daily average water use

Should the Secretary of State be given power to extend the prohibition list

We do not believe that extending the prohibition list is going to address the real issue of major water leakage by the water companies, while they make millions in profits from customers who do not have a choice in suppliers.

Before imposing further restrictions on paying customers of the water companies, the companies and OFWAT should make more effort to cut leakage losses, which dwarf the water usage of their customers with pools and spas. (Quote from Edward Leigh Chairman of the Parliamentary Public Accounts Committee “Ofwat has been passive in its regulation of the water industry….nowhere is its limp attitude demonstrated more clearly than in the case of the serious wastage of water by Thames Water.”)

Besides the well-publicised profligate waste of water by Thames Water, Severn Trent Water has recently been fined for failing to meet its leakage targets. The water companies and the Government should work together to increase surface water storage capacity, as well as seriously addressing the potential for moving water from areas where there is a surplus to those where there is a deficit, such as the South East.

The Minister’s announcement of the consultation was widely quoted in the daily press as focusing almost entirely upon the anecdotal illustration of people being prevented from using hosepipes to water flowers while next door neighbours are filling their swimming pool. We object to this blatant prejudice against pools, when there is recent evidence from the Office of National Statistics that swimming is the most popular and beneficial form of sporting exercise in the country, helping in the fight against obesity and contributing to health and safety of the general public.

We believe that this emphasis on pools is based more on envy and prejudice than on evidence of pools wasting substantial volumes of water.

How much water do pools and hot tubs use?

Evidence submitted to the public hearing last year for the application for a Drought Order by Sutton and East Surrey Water showed clearly a serious misapprehension of the true facts about water usage in domestic swimming pools. Much of the case for granting the Order was based upon the anticipated water savings from the categories of use to be covered by the Order. The figures produced by the water company suggested that savings of between 1million litres/day (Mld) and 4Mld could be expected from banning topping up domestic swimming pools in their area – well over half the total savings estimated from implementing the Order, and by far the biggest single category. This was based upon the erroneous assumption that every pool owner in the area would completely drain and then refill his pool twice a year.

In fact, as the evidence we submitted showed, the actual savings from swimming pools under the Order would be less than half the lower of the water company’s estimates at 0.48Mld – and this was without allowing for the substantial reduction in water loss gained from using heat retention covers and other water conservation measures adopted by our members. (We do not know how much water was actually saved by the Drought Order, but suggest that the savings due to swimming pools were nowhere near the water company’s estimates). Swimming pool owners do not routinely empty their pools once, let alone twice, a year. In fact, the only reason for emptying a pool is to carry out repair or maintenance work inside the pool, and even then it is often possible to avoid draining the water by using divers for repair work, or by transferring the water into an inflatable above ground pool for temporary storage while the work is carried out, to be returned when the job is finished. It makes no economic sense for owners to drain water that they have paid to heat and chemically treat unless absolutely necessary.

The volume of an average in-ground domestic swimming pool is about 75,000litres (10m x 5m x 1.5m). Water loss can occur in two ways:

Evaporation and splashing

Backwashing the filter to clean it

Evaporation in an outdoor pool occurs at different rates throughout the year – more in summer than in winter. However, the average over the year is about 3mm a day. Therefore our average size uncovered pool would lose 150 litres a day. But the majority of pools nowadays are fitted with heat retention covers while not in use, which reduce heat loss by at least 80%. Therefore the net loss from evaporation is only around 30 litres a day – less than the water used in a daily 2 minute shower. Indoor pools will have minimal loss from evaporation due to the differential between pool temperature and the higher pool hall ambient temperature. For this reason, we can see no real point in including swimming pools built within domestic residences, since there is very little saving of water to be achieved.

Backwashing is an essential pool hygiene function, which is usually carried out fortnightly, to ensure the pool filtration system continues to work efficiently and remove debris, impurities and dirt from the water. Backwashing the average pool will pump some 500 litres in a 2 minute operation fortnightly, which is equivalent to 36 litres a day.

In total, therefore the average swimming pool uses only 66 litres a day – less than a daily bath, and less than 2 daily showers.

It is often argued that families with pools could use their local public pool in the event of a ban inhibiting their use of their own pool. We should point out that it is recommended in Swimming Pool Water - Treatment and Quality Standards by PWTAG that public swimming pools should add 30 litres of fresh water to the pool circulation for every bather, so a family of four would use 120 litres of fresh water every time they visited the pool, which is almost double the daily usage of their domestic pool, in addition to the carbon footprint of their journey to the pool, which is unlikely to be within walking distance. Given our poor national record for provision of public swimming pools compared with other countries, for many families there is no pool convenient to them without a car or bus journey. The existence of a significant population of private swimming facilities removes some of the pressure on public facilities to meet demand for what is the single most popular form of sporting exercise activity (ONS 2007). Any measure which militates against this is to be deprecated.

Hot tubs

The average hot tub holds about 1,500 litres. Once filled, it is heated, filtered and chemically treated and the water is recycled within the unit, so no effective water loss takes place. Most hot tubs have a fitted heat retaining cover which, when the tub is not in use, limits the evaporation loss in the same way as a swimming pool, but the potential loss of water through evaporation is minimal due to its much smaller volume. BISHTA trade standards recommend that the water in a hot tub is fully changed about every three months for hygiene reasons. This therefore gives an annual water usage of 6,000 litres or 16 litres a day – less than half the water used in a daily 2 minute shower.

Economic Effects

Most of our pool companies have contractual arrangements with their customers to service and maintain their pools on a regular basis. These can provide a significant regular income for members which supports the regular employment of staff in this highly seasonal business. A typical company may have over 100 contracts worth around £2,000 each, as well as other regular summer service income during the season and the sale of chemicals and other consumables. If these contracts are cancelled by clients due to the ban, it could deprive such a company of a quarter of a million pounds income, with the obvious result of staff being laid off. Taken across our membership as a whole, more than 200 companies would be affected, with potential lost revenue to the industry of the order of £50 million and job losses into the hundreds.

The hot tub market has seen rapid growth in recent years, with probably some 600 or more companies involved in the market. A ban on filling new hot tubs on installation would destroy the market totally, as customers are not going to buy a product which they will not be able to use until after the ban is lifted, which on recent evidence is likely to last for several months. Existing products already installed in customers’ homes will also be affected, as hot tub owners will be exposed to a much greater risk of water-borne infection such as legionella if they are unable to make regular water changes. We do not believe it is justifiable to destroy an industry that provides pleasure to the public, as well as well-documented therapeutic benefits to all age groups, to save a minimal amount of water. At the very least, we must insist that initial filling of new purchases of hot tubs should be exempt from the ban, so that customers are not deterred from making purchases for fear of not being able to use them.

Water conservation measures

Last year, during the period of the Drought Order and hosepipe bans, we recommended suitable water conservation measures to our members which they could advise their customers to adopt. These included recycling backwash water, backwashing less frequently, using disposable cartridge filters temporarily to reduce the need to backwash, collecting rainwater to use as top-up water for pools, reducing the heat of the pool water to reduce evaporation, and collecting condensate from air handling units in indoor pool complexes. An outdoor pool will collect rain and dew water in the normal course of events, whether covered or not. We believe these were effective, and we will certainly continue to advise our members on sensible water conservation, whether there is a drought situation or not.

Effects of lowering water levels in pools

Over a prolonged period of time, a ban on topping up pools will put the structural integrity of pools at risk as water levels drop to a dangerous level. Pools may literally pop out of the ground or collapse when the internal water pressure is no longer sufficient to counteract the inward pressure from groundwater. Also, when water level drops below the surface water skimmers, the water cannot be drawn through the filtration and chemical dosing systems and can cause the pumps to cavitate and creates a potential health hazard.

Repair and Maintenance

Last year under the Drought Order some of our members in the Sutton and East Surrey area had a need to drain a few pools for essential repair and maintenance work. We must pay tribute to the water company for their co-operation in setting up a system for our members to ring them to approve draining the pools, and in every case we had very good co-operation. This would be an ideal matter for the proposed Code of Practice to cover and we would like to be consulted on the formulation of the Code if it is decided to go ahead.

Paddling Pools

While children’s paddling pools are not really our remit as an association, we are aware that substantial numbers of these and back garden splasher pools are sold by the big multiple retailers as well as some of our members. Some of the larger units can have rudimentary filtration and sanitizing systems, but in the main they are intended to be filled and emptied each time they are used. We find it hard to justify this during a period of water shortage, but appreciate that for small children’s pools a reasonable limit would allow children to play without having a serious effect on water supplies. We would leave it to the manufacturers of such products to suggest suitable exemption limits.

Private non-domestic sector swimming pools

The proposal to include these pools in the Drought Direction would have severe economic effects on the owners of these pools in the event of Drought Orders being imposed. Many of our members are involved with regular service and maintenance of these pools, providing a regular income throughout the year. Imposition of a ban on topping these up under a Drought Order would affect our members businesses, as well as sending out a negative message about the Government’s lack of support for health and fitness during the run-up to the 2012 Olympics and the fight against obesity. There could also be serious adverse public health concerns if owners of these businesses were unable to maintain the regimes for fresh water replacement recommended in Swimming Pool Water Treatment and Quality Standards by PWTAG and Managing Health and Safety in Swimming Pools by HSE and Sport England.

Our member organization the Swimming Teachers’ Association has hundreds of members providing essential swimming and safety training in private non-domestic pools throughout the country. If these activities had to be curtailed due to a Drought Order, their livelihoods would be threatened, and at the very least they would lose valuable income. Equally important, their pupils would not be trained and could be at increased risk from drowning.

The current number of public swimming pools would not be able to cope with the extra demand, and, as pointed out elsewhere, the extra water used by public pools to maintain water quality standards with increased throughput of bathers would negate any savings from banning private facilities from topping up. It would simply transfer the usage from one facility to another with no overall saving.

Furthermore, many local authorities look to the private sector to cater for increasing demand by the public for this most popular form of exercise and recreation, since they are not prepared to invest in providing adequate new public facilities, and indeed are in many cases closing public pools on economic grounds.

The Industry position

Our members are strongly opposed to the proposed extension of the current powers to ban filling their products under the proposed new discretionary use ban for the reasons stated above. This will have serious adverse economic effects for our members who are all in the SME category, and send out a negative message about the importance of health, safety and fitness in the fight against obesity. As we have shown, our members’ products are not major consumers of water, and we already have in place a number of strategies for water conservation at times of shortage. Water in swimming pools is not lost to the system, but merely retained in storage. There have been instances in the past where swimming pools have proved to be a useful and potentially life-saving emergency source of water for firefighters.

For the same reasons, we consider the proposal to continue to include domestic swimming pools under the Drought Direction to be unnecessary.

We support in principle the proposal for a Code of Practice which could deal with concessions but this is conditional upon our being involved in the consultations over the content of the Code, which does not seem to be spelt out in you r proposals which state “in consultation with Government, water regulators and consumer representatives.” We would expect to be consulted as interested and affected parties. Subject to this, we could envisage any controls over swimming pools, hot tubs and similar products to be dealt with under the Code. We believe this is preferable to giving wide powers to water companies to impose bans on our products without further consultation and at their discretion. While Drought Orders have been relatively few in recent years, hosepipe bans have been more frequent, long-lasting and widespread, and our industry cannot plan ahead if it is under the constant uncertainty of bans being imposed in different water company areas at random.

Realistically, we acknowledge that the Government has nailed its colours to the mast in the publicity they generated when announcing these proposals. Ian Pearson’s widely quoted statements about swimming pools pre-empted this consultation, and will make it publicly difficult and embarrassing for him to accept our arguments and reverse the direction of these proposals. Indeed we would go so far as to say that, for pools and hot tubs, the Minister’s statements have rendered this consultation a meaningless exercise, since he has already publicly committed the Government to a course of action which it will be difficult for him to retreat from. However, recent examples like Home Improvement Packs show it is not impossible.

It is not for us to resolve this self-imposed dilemma for the Government, but if the Minister is still determined to include some form of ban for presentational reasons, we are prepared to discuss with you a possible compromise involving a narrowing of the categories of pools and hot tubs to be covered by the ban, to those which visibly demonstrate a failure to economise on water use.

We would be prepared to discuss the ban being restricted to pools and hot tubs not fitted with heat retaining covers and which are not designed to retain, filter and treat the water within a closed system, which lose more than an average of 120 litres a day. This is equivalent to only three quarters of the average daily usage of one person per household. We would be prepared to monitor through our members how this could be enforced. Paddling and splasher pools would not generally meet these criteria, so the most obvious examples of conspicuous consumption of water would be covered by the ban. It is for the manufacturers and sellers of these products to make the case for an exemption limit for childrens’ pools.
We believe a solution along these lines would provide a real incentive for pool and hot tub owners to ensure they had the most efficient systems..

We would be happy to meet Ministers and Defra officials to discuss these proposals in more detail, and look forward to your response.

The British Swimming Pool Federation Ltd
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