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Proposed National Environmental Standard for Water Measuring Devices: Report on Submissions

1 Introduction

2 Overview of Submissions

3 General Submission Summary

4 Submissions on the content of the proposal

5 Implementation of the Proposed Standard

Appendix A: Public Notice

Appendix B: Index of Submitters

2 Overview of Submissions

2.1 Summary of submitters' positions

Seventy-three submissions were received. Table 1 presents a summary of submissions by category. A full set of submitters' names and the category assigned to them is provided in Appendix B.

Table 1: Breakdown of submissions, by category

Submissions from local and central government accounted for almost a third (31 per cent) of all submissions. Of the submissions received from the government sector, one was from central government, 14 were from regional councils, five were from territorial authorities and three were from unitary authorities.

There were 11 submissions received (15 per cent) from individuals.

2.1.1 Position of submitters

Submitters' positions were divided into five categories (support, conditional support, neutral, oppose, not stated) according to their position on the proposal. Submitters who did not directly state their position were attributed a position if it was clear from the submission's content and tone. Where the position of the submitter was not obvious, submissions were categorised as "not stated". Figure 3 shows the breakdown of submissions, by position.

The breakdown of submitters' positions in Figure 3 shows mainly support (37 per cent) or conditional support (19 per cent) for the proposal. There was also significant opposition to the proposal (27 per cent), while some (14 per cent) did not state their position. Two submitters (three per cent) clearly stated their neutrality.

2.2 Key themes analysis

The key themes identified during the analysis of submissions are presented in Table 2, and then discussed briefly in the following text. Key themes were derived from specific submissions on parts 3 to 6 of the discussion document. These key themes were further broken down into sub-themes in order to adequately address the range of submissions received.

Table 2: General key themes: summary

Need for and support for the NES

The majority of submitters supported the need for an NES for water measuring devices.

A number of submitters who did not support the proposed NES suggested a variety of alternative methods.

Standard development and consultation process

There were a number of concerns about the development and consultation process. Further information was requested by some, in addition to the clarification of a number of terms.

Costs and benefits

Many submitters stated that the proposed NES would be costly to implement. A number also made comments about the content of the cost-benefit assessment.

Scope and exemptions

The scope of the proposed NES was commented on by a number of submitters. The proposed exemptions also received extensive discussion.

Minimum standards for measuring flow in pipes

Many submitters made comments and suggestions on the proposed requirements for measuring flow in pipes. The accuracy requirement was one of the most significant sub-themes.

Minimum standards for measuring flow in channels

The proposed requirements for measuring flow in channels attracted a range of comments, in particular about the accuracy requirement.

Installation and maintenance requirements

A number of suggestions were made about the four proposed installation and maintenance requirements. The proposed requirement of independent verification of meters and the related five-year timeframe received comments in a large number of submissions.

Data recording and transfer

A wide range of submissions discussed data recording and transfer. The sub-themes covered everything from data format to technical difficulties.

General/other

Submissions containing comments that were not directly applicable to the alternative themes were included in the general theme category.

Implementation of the proposed standard

A number of questions were raised about the implementation of various parts of the proposed NES. The capacity of the water-meter industry and regional councils was one of the major sub-themes.