Pointing the return Down

Also the interaction taking place between the heated and non heated water is longer. If the return is facing up its interacting with unheated water and the air. I wish there was some data out there to know exactly what the savings are. There are some products claiming outrageous savings.
 
In my mind, the benefit is so insignificant, it would not be worth the bother to attempt a test of any kind. That said, the forum is always interested in the results if you would like to do the test.
 
I tried it, and noticed a couple of things, one of which was obvious. I pointed one return down, and didn't notice a real difference in water temp. I did, however, notice more junk sitting in that corner that couldn't be directed towards the skimmer.

I would rather have a cleaner pool as opposed to having a heat loss issue.
 
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