6 Submissions on Water Efficiency Labelling

The positions of the submissions on WELS are shown in the tables below.

Table 5: Submitters' views on WELS

View on mandatory labelling	Number
Agree	36
No position	3
Oppose	9
Total	48

Table 6: Submitters' views on WELS by stakeholder group

Stakeholder group	Total	Agree with WELS	Oppose WELS	No position
Councils	15	14	1
Industry	12	7	2	3
Sector groups	10	5	5
Personal	5	5
NGO and other	6	5	1

6.1 Views on mandatory labelling

The majority of submissions supported mandatory labelling (18, 67, 25, 85, 100, 103, 129, 130).

Councils were strongly in favour of mandatory labelling, which was seen by them as assisting in managing water supplies that most were responsible for. A number of submissions favoured WELS because this would ensure we are consistent with Australia in our regulatory approach (8, 44, 46, 80, 100, 112).

Some of those opposed to mandatory labelling (22, 45) felt that if improved information was valued by consumers, then the suppliers would provide the information without regulation. Others opposing mandatory labelling, noted that New Zealand is not in the same situation as Australia so the same regulations are not necessarily desirable here.

6.2 The benefits of water savings

Many of those supporting water efficiency thought mandatory labelling would provide savings in water and that these savings would have value.

There were savings to councils from reduced water use (32) and a particular benefit where there is an inadequate water supply (85). In the longer term there could be some savings from deferred capital spending where water use is reduced (42). Submitters 44 and 100 suggested that these savings could be significant. The savings were seen differently in some regions, such as Wellington (101), where they were expected to be small.

Tauranga District Council has achieved savings in water use and wastewater over the past eight years through charging for volume use, and through education and trade waste policies. As a result it has been able to defer major capital expenditure by five years (46). In Auckland (18) there was a water shortage in 1993/94. Expansion is now being looked at again and water conservation is part of the strategy to avoid excessive early expenditure. The Auckland Local Network Operators are aiming for a 5% per capita reduction in water use by 2024 (18). Waitakere City Council (128) is working on water conservation, and labelling will help with this. Their target is to reduce per capita consumption by 25%. North Shore (99) is also achieving water savings but has a different target. Metro water (83) also commented on the benefits from reduced water consumption.

There would be benefits where there is on-site treatment and disposal of waste (69, 128). Some of the on-site systems verge on being a hazard now, and a reduction in water would help reduce this (128).

Labelling could be important when purchasing new items (8, 32, 72). EECA (112) stated that experience with energy labelling shows that labelling works and that consumers respond. This has been backed by a nationwide survey (112).

Labelling raises awareness of water use and has benefits elsewhere (58). Wellington Regional Council (101) commented that the labelling would be highly visible and this would help other conservation measures where benefits could be greater. Of particular concern to Wellington was the outdoor use of water in urban areas. Submission 44 said that while direct savings are likely to be small, other conservation measures would be assisted by labelling.

There is extra incentive to use labelling where water is metered, as it is in Nelson (42). Water use had dropped by 25% since metering was introduced in 1999 (42). Submitter 85 felt there should be water charging, because the current system leads to supply to drinking water standard then cleaning of waste water. There is a need to bring the costs of this into consumer decisions (85). Submitter 50 also thought that pricing mechanisms should be investigated.

6.3 Effect on business

Many New Zealand producers favoured having mandatory labelling aligned to Australia.

Submission 75 commented on issues relating to the differences between Australia and New Zealand in terms of different water pressures. In New Zealand 60−65% of homes have low-pressure hot-water systems, while in Australia only about 5% have them (though more are being installed). The submitter felt that this means that adopting the Australian standards for shower-heads is not appropriate. We should not penalise efficient New Zealand shower-heads (about 50% are already triple A in rating) and we should use flow-control devices in the shower-head or in the mixer/valve rather than the approach used in Australia.

Submission 100 noted that there would be a problem with the Trans Tasman Mutual Recognition Arrangement (TTMRA) if WELS is not introduced. Submission 116 saw a need to look at Asian trade agreements and imports as well.

6.4 Administering the scheme

A number of suggestions were put forward as to how to manage WELS.

Some sought consistency with Australia (46, 74) and the Building Code (8, 66, 74, 112, 129). Submission 69 felt New Zealand should have a plumbing industry control similar to that in Australia, while submitter 58 thought that standards should be under the Building Act with an added labelling requirement.

Administration from Australia is acceptable to some submitters (17, 85, 99, 129). If it was administered from Australia then New Zealand would need to ensure it has a voice on the committees dealing with the scheme (74), and there would still need to be some enforcement in New Zealand.

Submitter 50 thought that as WELS was going to be introduced in Australia, then those selling goods to Australia will have water efficiency labels. In this situation, if New Zealand consumers value labelling it would happen without the need for regulation (50).

The Plumbers, Gasfitters and Drainlayers Board submission (67) suggested that New Zealand needs a plumbing regulator. This would have the WELS function in addition to the licensing of plumbers, regulation of standards and so on. The Plumbers Gasfitters and Drainlayers Act could be amended to provide for this.

EECA as a possible body to regulate WELS in New Zealand was mentioned by submitters 43 and 85. BRANZ (74) indicated an interest in being involved in testing.

Finally, submitter 66 felt that any regulation should allow for individual suppliers "to set increased minimum standards" to provide for specific local issues.

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