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APSP Testimony Well-Received at Oregon Title 20 Hearing

The August 15 edition of Industry Currents announced that Oregon had just signed into law an energy-efficiency bill (SB375) covering portable residential spas and hot tubs. The Oregon law is based on the California Energy Commission’s Title 20, a key formula of which is in debate. On October 23, APSP’s testimony at a hearing in Oregon about the Title 20 energy-efficiency standards was well-received by Oregon officials. The officials said they will adopt any clarifications that APSP can work out with California. John Kaufmann, the Oregon Hearing Officer, said that he wants to be kept informed about the APSP testing, and he said he appreciated APSP’s contribution in clarifying the testing protocol and setting appropriate standards for energy efficiency.

Testifying for APSP were APSP’s attorney, Steven Getzoff, and representatives from Marquis Spas, Thermospas, Columbia Spas, Balboa Instruments, and Aqua-Flo, in addition to Region 8 (Northwest region) Government Relations Advisory Committee representative Phil Oaks. Gary Fernstrom, consultant from Pacific Gas & Electric (PG&E) for the California Energy Commission, representing CA Title 20, endorsed APSP’s testimony and urged Oregon to adopt any clarifications that APSP and California work out. In positive news for the spa industry, Fernstrom said that he expected testing and clarifications to be done by mid-2008.

APSP was the only industry representative to make a presentation in person at the hearing. During his testimony, Getzoff made the following statement:

“The APSP and its members applaud and support the efforts and initiatives in California and Oregon on spa energy efficiency. We also recognize it as a reality for the long term. We are working diligently with PG&E and its consultants in an effort to get products to comply and to address possible clarifications and tolerances to the test standard. We had a very productive meeting this summer with PG&E and its consultant, the Davis Energy Group (DEG), toward this end, which will result in a more detailed test protocol on spas of varying size, quality, and make under lab conditions. We are grateful to PG&E and the DEG for their cooperation and input on this testing.

“We also note the effective date of the proposed Oregon regulations for spas is September 1, 2009. We agree with this approach, and would like to take this opportunity to briefly discuss what will be happening between now and that date.

“First will be the more detailed protocol I have mentioned. Working closely with PG&E and DEG, we have just about put the final touches on the protocol. We are also working with Cal Poly San Louis Obispo to participate in this testing and to construct an elaborate testing facility that will be an important resource to the industry and others in years to come.

“Second, we have begun the development of a voluntary consensus, third party-approved standard on portable hot tub energy efficiency under the auspices of ANSI (the American National Standards Institute). The committee that will be drafting this standard includes several leading manufacturers, as well as representatives from PG&E and DEG. An invitation has also been extended to the Canadian regulatory authorities.

“We welcome the Oregon Department of Energy’s participation in all or any of these areas and would like to keep an open line of communication with you as these exciting developments unfold.”

Background

The provisions in Oregon’s new energy-efficiency bill covering portable electric spas become effective September 1, 2009. The legislation is in part based on California’s Title 20, a key formula of which is in debate. APSP has been proactively working with California’s energy commission and others to clarify provisions of Title 20, including the development of a new testing protocol.

California’s Title 20 Appliance Regulations mandate that portable residential spas meet the efficiency standards for appliances. This regulation went into effect January 1, 2006. Since then, leading hot tub manufacturers and APSP have expressed their concerns with Title 20’s formula and definitions. In an effort to clarify these provisions, APSP–working with key manufacturers–has been engaged in a continuing cooperative dialogue with the California Energy Commission (CEC), Pacific Gas & Electric (PG&E), and PG&E’s consultant, the Davis Energy Group. The new draft standard APSP-14, American National Test Standard for Energy Efficiency of Self-Contained Portable Spas and Hot Tubs, will reflect the current technology on how to determine the energy efficiency of portable spas. As part of the development of the proposed ANSI standard, APSP plans to do research and testing of the energy efficiency of portable spas.