Sunday, February 05, 2006

Interesting article on Hot Tubs and Spas (Insulation and law)

As some of you already know, hot tubs are something I care a great deal about.
I stumbled across this article in this morning's random surfing, and thought it was good enough to reprint here.
(with permission)

Article: Insulation facts and fiction.

(Edited and added to 02-05-06)

For years debate has raged inside the spa and hot tub industry as to how best insulate a spa / hot tub. There have been three primary ways to insulate a spa.

  • Full foam, where the cabinet from the shell to the cabinet is filled with a sprayed polyurethane foam.
  • Partial Foam where only the shell and perhaps the plumbing was covered in foam, ranging in thickness from 1/2" to up to over 8 inches.
  • Thermal pane, where the cabinet was insulated and the shell and plumbing was left un-insulated, making a "thermos bottle" according to advocates.
  • A combinations of the second and third, where shell and plumbing may be insulated as well as the cabinet panels.

All of these have downsides, in either perceived value or accessibility to plumbing in case of leaks, etc. Never to my knowledge was a head to head study done using the same model of tub with the same equipment, and the various methods above done by an independent lab.

Over the years there has been a lot of fiction written about how energy efficient one tub is versus another, and there has even been a few attempts at figuring out how much a tub will cost to run electrically, but none that were as all inclusive as they needed to be to give the buying public a real feel for the costs associated with spa operation.

That is until now.

The California Energy Commission (CEC) has issued a mandate, that all spas made after January 1, 2006 must have passed testing showing that there stand by power consumption is no larger than allowed using the following formula 5(V^2/3) where V, is volume in Gallons. Furthermore that this must be tested and confirmed by a laboratory or testing facility that has been approved by "The Executive Director".


You can download the whole thing there, I will warn you it is a huge PDF that has all the regulations for appliances.

This bit of legislation was brought into being when the CEC received findings by Pacific Gas and Electric. (a nice PDF showing some findings is at )

It basically said that with better insulation the state could save several million Kilowatts a year.

I have been an advocate of this type of testing for years now, as I get tired of the fiction bantered about in the industry. Example: Using one persons formulas for energy efficiency, if you owned one of his spas, it would generate enough surplus energy that you could disconnect from the grid! He's got some good theories, but his math does not work when you add it all together..

(see update at bottom of article)

But here is the problem (well one of the problems), According to the recommendation, the testing facility has to meet specific criteria and be approved (read inspected) by the "Executive Director" this leaves only a few places that spas can be tested. There are well over 3000 models of spas and hot tubs made in the states, and according to the CEC each model made by a manufacturer must be individually tested. When I contacted the CEC for a list of testing facilities they could only give me one name, Intertek when (02NOV05) I contacted Intertek they informed me that only two of their facilities were approved to do this testing, on in Los Angeles and the other in Vancouver. When I asked what the lead time was, they said if I sent my tub in immediately , they should be able to get the testing done by January 1st. but I should act quickly as they were completing testing on a "first come first served" basis. The cost to test one tub is $5500. Each test takes about one week, Intertek has three chambers only.. thus the math says that it could take up to 3000 weeks to test all of the spa models currently for sale in California. (That's right about 57 and a half years!)

Further , every model must be tested separately even if they are equipped identically and hold the same volume of water. (This is one interpretation of the standards, and some clarification has been requested, by the spa industry.)

For some smaller non-California manufacturers this will mean that they will either have to limit there selection in the state of California or not sell into the state after Jan 1 2006. (See update at bottom)

Okay all is fair in business I guess, but California has a public Relations problem on their hands now, too. The rumor mill in the industry has been saying that the CEC has approved some larger California spa manufacturers to do their own testing! If this is true, due to their deadline and costs associated with testing, and fiction printed by some of these same companies, this gives an unfair advantage to some California companies ( or the perception of a wrong doing at the least on behalf of the CEC) and complaints are being registered with the FTC on this point. (See update at bottom)

The trade organization for the spa industry is the National Pool & Spa Institute or NSPI, there silence in this have been deafening! Many non-California companies are planning on no longer paying dues to or being members of the NSPI over their lack of forewarning, and their inability to lobby on behalf of the industry to lawmakers in California (where they are based)

In the end the consumer looses. There will be few products competing for their dollar in the California markets, thus less price control through competition, if this measure succeeds, or a relaxing or abandoning of the measure due to pressure from an industry, that so far has been less than consumer oriented (in many cases).

I still believe that there needs to be labels on spas, that show how they stack up against others in the market, like the energy star labels we are used to seeing on other appliances, but I do not think that the state of California or any other state can alone call for this type of measure. Energystar is a federal program that so far does not include portable spas (despite some stickers on spas that look just like the Energystar label.. if you see one it is...fiction).

There are some valuable things to take away from the CEC and PG&E writings on this subject, the one that stands out in my mind the most is the PG&E study that shoed by having a thicker cover a savings of (net)$18 a month could be achieved, if the cover cost an extra $100 and lasted 2 years. Many of the other things that they found pointed at spas being very much alike despite what they did as an energy saver (ie. type of insulation system, circulation pumps, etc, etc) So from this all we can take, that to buy a cover that is 5" to 4" taper over a standard 4" to 3" taper, you will actually save money $18 annually in California. It is not much, but it's something.

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Update: As of 12/15/05 the CEC has agreed to hold off on enforcement of Title 20. This is so that the pool and spa industry can be brought in on the decision making process. (Something that was not done when Title 20 was originally written)

I have fielded a number of emails and calls, from people inside the industry that are concerned about the testing, and the regulations. Some have said that their spa even though it is very efficient, or as efficient as they can make it, will not pass under the current regulation. Some have gone on to say, that they do not believe that there are many if any that can.

The efficiency test that they are talking about is something like this.

A spa is allowed to use no more watts/hr than this formula allows.

5(V^2/3) V=Volume in US Gallons. So a 425 gallon spa would be allowed about 283 w/h.

I have tested one spa, and under the same conditions, it has passed and failed. The difference between the passing and failing test conditions is beyond me? That data seems good on all tests, insulation method made little difference. (Full Foam, Thermal Pane or Partial foam) I truly feel sorry for the spa industry on a whole if this regulation is allowed to go into effect unchanged. I know from first hand experience that it is a crap shoot weather you pass or fail.

Testing is done something like this.

In a sealed room no warmer than 60 d.F. a spa is run for no less than 72 hours.

The spa shall be no cooler than 102 d.f during the test.

The spa shall be brought up to 102 and a 4 hour period of stabilization is to start. After 4 hours, the test shall begin at the end of the first heat cycle.

The test shall run for 72 hours + one heat cycle. The test shall end at the end of that heat cycle.

*** UPDATE 02-05-2006

Members of the pool and spa industry have met in Los Angeles to discuss a game plan, on how to approach the CEC on fine tuning the regulation.

Like so many other professions, when 13 persons from competing companies, were brought together to discuss a common aim, there were nearly as many opinions on how this should be done, offered up.

Weak points in the current CEC regulations, that were brought up, were,

1. the formula makes it nearly impossible to sell small spas in California, due to it not taking into consideration, the energy required to filter, and ozonate them. Further, if a sliding scale were applied to all tubs, the number of programming settings, that would become standard, would cause a unexpected fanatical burden on manufacturers, and make after market service , expensive if not impossible.

Also, when using the formula as provided by the CEC it is believed that between 80 and 95% of all spas currently built will fail the testing, and use more energy than the 5(V^2/3) allows. Which may in fact lead manufacturers to skew the numbers to pass, rather than improve their products, or completely eliminate all filtration time, thus eliminating nearly 1/3 or the energy used during the testing. (Not the effect the CEC was looking for)

2. Time to enforcement, given that under current circumstances, it will take years before all spas can be tested, it is asked that the phase in schedule be extended, or that family testing be allowed. Family testing being broadened to allow tubs of a range of size using similar equipment be tested as one "Family". This in one case, that I know of would bring the number of tubs to be tested for a specific manufacturer from 17 down to 5. Also under current regulations, it is required that a company be ISO certified in order to be able to conduct it's own tests, ISO Certification for many smaller companies, is a financial burden, and seen as unnecessary to build a high quality and consistent product. When I spoke with one V.P. of Engineering at a smaller mid-west spa manufacturer, he said about ISO Certification, "It will cost us an additional $55,000 per year, for a person just to keep the necessary paperwork up, and had we not just invested $100,000 in new inventory management software, that may have been another expense. I do not see how a smaller spa company can do there own testing, under the current law." It was further discussed, that if in fact each tub had to be tested every year, that this expense, including all modification costs (i.e. thicker covers, more insulation, different programming, inventory costs for these "improvements", would in the end be passed on to the California consumer, as a "California Package" raising the effective price of each tub sold into the state and additional $200 to $500. This in effect negates any savings that may be achieved by the consumer using the PG&E figures, for the life of the spa. Also because the most severe changes would need to be made to the smallest spas, this would place an extra burden on the people of California who wish to buy a spa , but are in lower to lower middle price bracket, for spa buying budget. Thus having an unforeseen effect on citizens of California which are of lower socioeconomic status. If not completely eliminating the most affordable smaller spas entirely from the market place.

My opinion at this point is as follows:
The CEC in conjunction with PG&E had good intentions when drafting this measure, but did not take into account the many variables in the spa business. Nor do I believe that they invested the time required to get industry opinion on the end effects of this regulation. This regulation will in effect have an opposite effect to the one intended if enacted in whole as it is written currently. The state of California would be better served, if they were to re-write the regulation using a plan more similar to the EnergyStar system currently being used by the Federal Government in which a sliding scale of Worst to Best were to be displayed on each model, and that scale is written in kW/Year or kW/Month usage of the product, allowing no formula to be applied to he volume of the spa, thus taking away any advantage given under current regulation to spas of larger than average size. It would then be market factors that would drive the industry to come up with better and better ways to make spas, rather than as it currently is written better and better ways to skew the test results. Alternatively the State could mandate a specific R-Value for spas using the recommendations of the Department of Energy (DOE) and the findings of Oak Ridge National Laboratories (ORNL), as they are applied to say housing. (See ORNL piece on housing insulation, here).

In the end I believe that these new regulations will bring about many positive changes, my only fear is that it will come too late, as the way that they are written currently will in effect punish the countries largest Spa / Hot Tub market, California.

On February 14th the CEC will reconvene on this subject, it is then that in the public comments period of the meeting that the Spa industry will make comments, asking that they be allowed to make recommendations, to alter the current regulations, to better fit with the realities of the spa and hot tub industry as it is today. I feel that this is a good first step, and if done right will benefit not only the end users in the California market but in the end world wide.

The CEC could not be reached for comment at the time of this writing.

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