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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

4 Submissions on the content of the proposal

This section of the report collates feedback from submitters who commented on specific requirements of the proposed NES as opposed to the more generalised comments covered in the previous sections.

4.1 Scope and exemptions

To ensure that accurate information is gathered about the actual water taken in all catchments, it has been suggested that the proposed NES apply to all water takes that currently require resource consents under operative or proposed regional plans. The NES would apply across all regions and all catchments or aquifers. At present there are three types of water takes for which a resource consent is not required. It is proposed that the NES would not cover these:

• RMA section 14(3)(b,c), which allows takes for an individual's domestic purposes and for animals' drinking water, provided there are no adverse effects on the environment
• RMA section 14(3)(e), which allows takes for fire-fighting purposes
• permitted activity takes that are allowed for in a regional plan.

The discussion document did not specify exemption requirements for the proposed NES, which raised questions about what water takes should be exempted from the requirements and how this process might occur.

Many submitters also commented on the proposed scope: 25 made reference to the scope of the proposal and 15 commented on exemptions.

4.1.1 Scope

The NES would be a minimum standard to be applied to all new resource consents to take water. Resource consents to take water would only be granted if they contained conditions that complied with the standard. All new water consents (including those that replace an expired consent) would have to meet the NES.

Four submitters supported the scope of the proposed NES. One applauded the intention to establish performance standards, and another said the scope was adequate at its inception.

One commented that care needs to be taken to keep water use as a separate issue.

The proposed standard was seen by some as not taking into account seasonal flows.

One comment was that the size and nature of the take were not adequately considered in the discussion document (ie, whether a take was small or large and whether it was covered by an old or new consent). One submitter believed that all takes should be considered in the scope of the standard, while another stated that the scope of the standard is too broad. One comment was that the standard should consider specifying the volume or rate of water abstraction, and have guidelines tailored to this.

There were also comments on what other aspects the standard needs to consider. The main ideas were that water-rich regions need to be further considered, or have exemptions clarified. One submitter said that the proposed NES needs to specifically address high-volume users.

It was argued that implementation prioritisation is missing from the existing discussion document, and there was also a request for a focus on greater flexibility in exemptions.

A number of concerns were raised about how resource consent conditions would be met under the proposed scope of the discussion document. They included:

• the NES extending only to takes that require resource consent (support)
• regional councils can manage takes within their own regions
• recycled water is not considered
• measuring the returns of water to a water body needs to be addressed so that net takes can be estimated.

Permitted activities within the scope of the NES were commented on by 10 submitters.

The clear consensus was that there should be flexibility for permitted activities to be measured and monitored. Two-thirds of those submitters identified regional councils as being the specific regulatory authority to do this.

Other comments were that permitted activities should not be metered at all, that permitted activities should not be covered by the NES, and that small takes that are complying with permitted activities should be exempt.

4.1.2 Clarification of scope

Four submitters commented on specific areas of the scope that need clarification. Comments clustered around the standard not being straightforward and the need to clarify who is covered under the standard. A number of submitters said that it is not clear if the NES covers

hydro-schemes and coastal takes. One submitter questioned how the electricity sector will be affected. Others said that it needs to be clarified whether each criterion alone is sufficient to justify an exemption, or whether all three criteria would need to be met.

4.1.3 Requirement to review existing consents

Five submitters made varying comments on the requirement to review existing consents without meters so that they comply with the standard. The majority of these did not object to the review requirement, although they did make a number of suggestions. Comments were:

• the timing of reviewing existing consents should be tied to existing consent replacement
• existing water takes and consent holders should be given three years to comply with the application of the standard instead of five
• new consents (not old ones) should require monitoring
• an NES can only be implemented through conditions on consents, and only through a consent review process.

4.1.4 Exemptions

The discussion document posed questions about what water takes should be exempt from the water measuring requirements and how a process for exemptions might work. The following factors were considered to be relevant to assessing exemptions:

• whether the volume of actual take can be estimated easily and accurately
• whether the level of allocation is very small compared to resource availability
• whether the effect on the environment is minor.

Fifteen submitters commented on exemptions. Two expressed support for establishing criteria for exemptions, while two believed there should be no exemptions. One submitter commented they were unsure as to whether each criterion alone was enough for exemption; if not, it was recommended it should be. One suggestion for exemptions was to set the threshold dependent on the size of the take.

Other comments on exemptions included:

• temporary users should be excluded from the requirement to have data loggers
• allow flexibility as there are parts of some regions where permitted activities amount to a large volume of water taken (cumulative effect)
• stock water should not be exempt from measuring
• if takes are constrained through pipe size, metering should not be required.

Table 5: Summary of submitters' comments about scope and exemptions

4.1.5 Regional councils to decide exemptions

Fourteen submitters considered that regional councils should be given the power to make decisions on exemptions, reporting, monitoring, thresholds, measuring and metering requirements. This was considered a more flexible approach able to be tailored to local circumstances.

Table 6: Summary of submitters' comments about regional councils deciding exemptions

4.2 Minimum standards for measuring flows in pipes

Submissions on minimum standards for measuring flows in pipes were divided into the seven minimum requirements for all new pipe water measuring devices outlined in the proposal. These are to:

• be capable of continuous measurement
• measure volume in cubic metres
• have data storage capability
• have an accuracy standard of ± 5%
• be capable of recording daily volume
• be fit for purpose
• be tamper-proof and sealed.

Ten submitters commented on the overall proposed minimum standards for measuring flow in pipes. Seven of these supported the requirements, with one also stating that they supported the fact that neither specific devices nor industry standards were referred to or required. One submitter felt the minimum requirements were too stringent for some takes and suggested that allowances need to be made for different situations. Another referred to the practicalities of the requirements and argued that they had not been able to obtain a price for a meter that met all the requirements.

4.2.1 Continuous measurement

Eight submitters made comments and suggestions on the requirement for water measuring devices to be capable of continuous measurement. One stated that continuous measurement was a key issue and needs to be carefully considered, while two felt that clarification of the term "continuous measurement" is necessary.

It was pointed out that even when measurements are continuous, the data is often only stored at 15-minute intervals. Three submitters suggested that 15-minute measurement intervals are sufficient and that the requirement should be altered to reflect this position. One argued that meters should be capable of continuous measurement.

4.2.2 Units of measurement

The requirement that water measuring devices measure volume in cubic metres was commented on by seven submitters. Three supported the requirement, although one of these said that a time component is essential, while four submitters argued that there was no justification for mandating that water takes be measured in cubic metres. One of these said that volume measurements in cubic metres were not suitable for showing compliance with consent conditions. There were suggestions for alternative units in the form of litres per minute and megalitres per day.

4.2.3 Data storage capability

Eight submitters made comments and suggestions about the requirement for all water measuring devices to have data storage capability. The standard was supported by three, while three said changes were required and that more guidance and clarification in particular were needed about what data storage meant. One submitter suggested that data loggers have a minimum of two years' storage. The data storage ability was opposed by two submitters, who argued that it was an onerous requirement, especially for small users. One suggestion was that the measuring device components (meter and logger) should be dealt with separately.

4.2.4 Accuracy requirement for pipes

The proposed minimum accuracy standard for all new pipe measuring devices within the NES is ± 5%. Twenty-one submitters made specific comments about this requirement.

Six submitters supported the accuracy standard. However, two made reference to the wording of the standard, suggesting that "in situ" be added and that the requirement would be more precise if it read "maximum accuracy error of ± 5%".

On the one hand, four submitters said that the accuracy standard was too high. The main argument here was that the accuracy standard may be suitable in a test situation but is too stringent for in the field. One suggestion was that the standard be altered to ± 10%. On the other hand, the standard was deemed to be too low by two submitters: one felt the accuracy standard should be more stringent and altered to ± 3%, while the other said that while the standard was appropriate for most consent holders, it would be too generous for users with large takes.

Three submitters stated that the accuracy standard was too inflexible and that the objectives of the NES would be better achieved by having a variable accuracy standard. Two submitters suggested that the maximum water meter error rates should decline with increasing water takes (ie, reduce the error limit to ± 2.5% on consents over 100 L/s).

The practicalities of the accuracy standard were addressed by eight submitters. One said that accuracy levels need to be better defined, and suggested that "statistical uncertainty" was a more easily defined parameter. Difficulties in setting an appropriate accuracy standard were raised by two submitters, who said that water conditions can rapidly affect accuracy. A suggestion was made to nominate flow rates at which meters are required to achieve ± 5% accuracy.

Table 7: Summary of submitters' comments about minimum standards for measuring flows in pipes

4.2.5 Recording daily volume

Seven submitters commented on the requirement for water measuring devices to be capable of recording daily volume. Six opposed the standard for a variety of reasons, including:

• daily volume is too great an interval
• instantaneous measurement is not covered
• the requirement is not suitable for certain takes (eg, from an aquifer)
• the capacity to record daily volume is rejected unless it is imposed by regional councils
• there is no need for the requirement as it could be dealt with at the regional council level (two submitters).

One view was that it is important to record the rate of abstraction as well, not just the daily volume.

4.2.6 Fit for purpose

The requirement that water measuring devices "be fit for purpose" was commented on by 10 submitters. Two supported the requirement in its entirety, four suggested that a clearer definition of "fit for purpose" is required, and two suggested that suitable meters be specified in this section. One submitter argued that the phrase is too broad, and therefore open to differing interpretations, and suggested that the wording be changed to "designed to measure the type of water they are being used to measure". One submitter said that meters for groundwater takes may be adversely affected by water quality.

4.2.7 Tamper-proof and sealed

Nine submitters made comments and suggestions on the requirement for water measuring devices to be tamper-proof and sealed. Seven opposed this requirement because making such a device "tamper-proof" is difficult, if not impossible, to achieve. One submitter said than only electronic and electromagnetic meters will be secure. Two commented that the practicality of this standard would be improved if the wording is altered to "be as tamper-proof as possible or practicable". One view was that a method is needed to ensure that meters are tamper-proof.

4.3 Minimum standards for measuring flows in channels

Submissions on minimum standards for measuring flows in channels were divided into four main sub-themes. These sub-themes reflect the four proposed minimum requirements for all new channel water measuring devices, which must:

• continuously measure water levels
• have a water level accuracy of ± 10mm
• maintain a rating curve to convert water levels to flow
• fit a data logger to store the water-level data.

Five submitters commented on the overall minimum specifications for channels. One supported all the proposed minimum standards for measuring flow in channels, while one said that no standard is defined for determining open channel flow and that this must be included as part of the proposed NES. Further comments and suggestions included:

• regional councils should have discretion to determine technical specifications
• there should be allowances for regional council discretion to determine when flows in channels should be measured.

4.3.1 Accuracy requirement for channels

Twenty-four submitters commented on the channel accuracy requirement of ± 10 mm.

Two believed the level of accuracy is appropriate and at a fair and correct level, while 11 felt the accuracy is too low because this level does not translate to a defined flow rate accuracy. Two submitters argued that higher accuracy is required because both the national and international accepted requirement for flow measurement is ± 8%.

Four submitters considered that accuracy should vary with flow. One believed it to be preferable to have a high tolerance on instantaneous flow rates for water consents, and a total accumulated volume with a lower tolerance. This would allow for the inevitable variations in flow that will occur in pumped systems.

Seven submitters thought that accuracy should be expressed as a percentage of flow, with one saying the use of a level standard is inappropriate; accuracy should instead be expressed as a percentage of volume. Two submitters expressed concern over the size and shape of the channel creating discontinuity. One submitter calculated that the accuracy requirement equates to ± 18% at low flows for a partial flume fitted in some channels, so a percentage accuracy standard is more appropriate.

Two submitters specified that accuracy measurements should apply to flow and not water levels.

Table 8: Summary of submitters' comments about minimum standards for measuring flows in channels

4.3.2 Data storage capability

Four submitters mentioned data loggers in reference to minimum specifications in channels. One comment was that a data logger cannot be installed on systems with a pressure-plate measure box (which is common in Central Otago). One submitter said the nature of data recorded must be considered, and another said that requiring loggers at remote sites or those that are affected by variable climatic conditions is not appropriate. Concerns were raised that there is no cell phone coverage in many areas, so manual recording would be the only option and could not be done daily due to access difficulties.

4.3.3 Continuous measurement of water levels in channels

Eight submitters commented on measurement. Three believed alternative methods should be allowed, while three voiced concern that instantaneous measurement is not accurately covered in the standard and needs more definition, and possibly a benchmark point. One submitter supported the requirement for continuous measurement in channels and one opposed it.

4.3.4 Rating curves

Ten submitters discussed rating curves in their submissions. Four believed further clarification is needed on to how to use and apply rating curves to flows and levels. Two submitters expressed concern that the curves will be difficult to maintain, while one supported the specifications outlined in the document.

One comment was that the rating curve will need to be derived by an experienced practitioner. Other concerns were that the cost of maintaining the rating curve may outweigh the benefits, and that the gaugings required to maintain accurate rating curves differ depending on the type of channel, flume or weir used.

4.4 Installation and maintenance requirements

Many submitters supported the installation and maintenance requirements stipulated in the discussion document, and some even considered they should go further. There was agreement that poor installation is the main cause of inaccurate data and correct installation is very important to maintain accuracy.

Two submitters thought that the installation and maintenance section (section 4.4 in the discussion document) should only apply to pipe flows. One saw the need for a separate section for the installation, maintenance and calibration of channel-measuring devices or a maintenance schedule for each device as appropriate. There was also a suggestion that where consent is given to take water from multiple source points, the measuring device should measure the combined flow. Another submitter felt that people putting in new installations for channels should be encouraged to install some form of weir control, because they improve accuracy and can be cost effective. Similarly, a suggestion was that for multiple inflows into channels there needs to be one major measuring point only.

4.4.1 Installation to comply with manufacturer's instructions

There was general support for installations to comply with manufacturer's instructions and to be installed by qualified people. Two submitters raised concerns about the quality of installation and requested that only approved and registered installers install meters. One suggestion was to change the wording to "must be installed by approved personnel".

Many agreed that a certification programme for installers is a good idea and that installation compliance should be checked by councils. One submitter asked for a national code of practice that complies with the proposed standard. It was generally felt that meter accuracy should be calibrated in situ, although one submitter asked if this was possible and another stated that there are technical difficulties with this. One submitter considered that meters should be calibrated prior to their first use, while another said that meters that are reading accurately but not installed as per manufacturer's instructions should be accepted within the standard.

4.4.2 Installation as close as possible

Five submitters cautioned that installation requirements should be flexible enough to allow for site variability, which would not compromise the intent of the standard. Several raised practical issues relating to installations (eg, access to a power supply, cell phone coverage, vehicle access, topography). Several considered the standard should read as close as practicable and not as close as possible. One view was that the installation point standard needs to be broader (ie, as close as possible to the last take point). It was also suggested that this point be deleted and discretion regarding the location of installations be given to regional councils.

Other points raised about the location of installations included:

• installation below ground should be allowed for
• measuring devices should not be able to be bypassed and unmeasured water taken easily
• measuring devices should be installed at an appropriate location upstream of the first outlet, regardless of location to the take point.

4.4.3 Independent verification of meters

There was considerable support among submitters to require independent verification and testing of meters by qualified technicians; indeed, this was considered an essential component of the proposed standard. However, one submitter, while supporting the requirement, questioned its practicality.

Three submitters requested more clarity around what "independent verification" means and who would be qualified to do it. One view was that there are several ways to verify so the method should be left up to the regional council. Five submitters were concerned about the costs of independent verification, or felt it could not be justified.

Three submitters said that there needs to be an audit process for the verification of water meters in the field. Consistency was the main issue raised, and suggestions made to achieve this included:

• a certificate of compliance being issued after inspection
• consistent mechanisms required to ensure measurement compliance.

4.4.4 Verification timeframe

There was variable support for the five-yearly timeframe for accuracy verification.

Six submitters considered that five years was too long, while six others considered that five years was too short and should be longer. Most of those who commented on the installation and maintenance requirements considered five years was the right length of time. Finally, two submitters considered that the verification timeframe should be left up to the regional council to determine.

One submitter felt that new sites should be verified after one year and then every five years if no issues are discovered. Other timeframes for verification included:

• annually
• every two years
• every three years (especially in areas with high sediment)
• every four years (if the meter has an appropriate filter)
• every five years, or as the manufacturer specifies (whichever is lesser)
• every five years as a default (councils can be stricter)
• on a random audit basis.

Other points regarding verification included the following:

• a standard should be added to require accuracy verification to occur at the typical or historical flow rate for the system
• the standard should require meters to be accurate at all times
• maintenance inspections should occur a minimum of every two months
• rating curve checks should occur in accordance with guidelines for calibrated flow-measurement structures
• there is a need to ensure that the testing equipment to calibrate meters has an accuracy of ± 1% and is certified annually to international standards
• the wording should be changed to "the instrument accuracy of all measuring devices should be independently verified every five years"
• guidelines should be given on the timeframes in which a meter must be repaired in the case of malfunctions (electrical, flooding)
• the verification interval should be suited to the measuring device concerned
• calibration needs to occur onsite.

Table 9: Summary of submitters' comments about installation and maintenance requirements

4.5 Data recording and transfer

A large number of submitters made comments and suggestions about the data recording and transfer section within the Proposed NES for Water Measuring Devices. Their remarks and proposals have been divided into nine categories, with a number of submitters commenting on more than one aspect of data recording and transfer.

Eight submitters commented on the overall requirements within the data recording and transfer section. Seven of these supported the general requirements, while two stated that there may be situations when the requirements will need to occur more frequently. The requirements were deemed to be too stringent for small takes by one submitter, who suggested that manual, paper-based systems that operate on monthly readings would be suitable for some situations. Two submitters said that more frequent recording and transfer should be addressed through individual consent conditions, as specified by regional councils.

Eleven submitters made remarks about the need for the data recording and transfer requirements. The arguments as to why data recording and transfer requirements are not necessary were diverse, and included:

• manual, paper-based systems should be appropriate for small takes (two submitters)
• recording requirements would force a significant number of water abstractors to fit data loggers where they might otherwise not need them
• demand and use of the data will be of little relevance to the water user (two submitters)
• the requirements are unnecessary because existing methods are sufficient for measuring water (two submitters).

One submitter stated that the reasons for collecting data need to be articulated more clearly. Flexibility in the data recording and transfer requirements was sought by one submitter, while another said that alternative methods can and should be used to record data and that these methods need to be acknowledged.

4.5.1 Necessity of data

Five submitters made reference to the necessity of the data the NES proposes to gather.

Two felt that water-use data at a national level is not necessary, one believed that electronic data logging is not necessary, and three commented that only sensitive takes should be measured.

One submitter supported the need for the data the NES proposes to obtain, while another believed that all-round measuring is pointless.

4.5.2 Daily data recording

The daily recording interval requirement was commented on by 24 submitters. There was some support for the daily recording requirement proposed, but greater flexibility was advocated in the majority of submissions.

Sixteen submitters said that the requirement needs to be practically achievable and relevant to the scale and source of abstraction, and eight made suggestions about appropriate recording intervals. The suggested intervals ranged from more stringent requirements to less onerous requirements. One view was that the proposed recording interval is appropriate. The comments included:

• daily reporting is often inadequate where use varies significantly over a day, and the standard should be one hour or less
• a 15-minute interval is appropriate
• a daily requirement should be the absolute minimum for smaller takes - reductions should be dependent on consent conditions
• weekly recording is sufficient
• monthly recording is more appropriate as daily is not necessary
• it is nonsensical to require daily logging while only requiring annual reporting
• councils should determine recording intervals
• the daily minimum is impractical and unnecessary for some takes and there is little benefit to be gained from this information (two submitters).

The discussion document posed the question of whether recording intervals should vary with the source of take. A number of different flexible recording intervals were suggested by submitters, including:

• a daily recording requirement for rivers (surface water takes) and a weekly requirement for aquifers (groundwater takes)
• weekly or monthly recording, which is more appropriate in some instances
• more frequent recording for large takes and in times of drought.

Five submitters said that it was essential for the NES to retain sufficient flexibility for regional councils to retain discretion in determining appropriate recording intervals.

Three submitters made specific comments about the wording of the daily recording interval requirement:

• a day should be the maximum interval, not the minimum
• the standard does not need to include the phrase "occur at a minimum of daily intervals"
• the wording should be altered to "daily intervals except where it can be shown that daily volume is constant over a number of consecutive days in which case it can be based on an average daily volume".

Table 10: Summary of submitters' comments about data recording

4.5.3 Method of data storage

Two options for data-recording methods were outlined in the discussion document: electronic storage on "data loggers", and a manual, paper-based system for recording and storing information. Ten submitters made comments and suggestions about the data-storage options discussed in the proposal.

The submitters' stances varied. Five supported a requirement for electronic data storage, whereas three stated that data loggers should not be required in all instances. One submitter said that more flexibility was required in order to determine for each situation which devices should be installed. Another said that data-storage-capable meters can only be justified for some consents where real-time data is imperative.

4.5.4 Data transfer

The discussion document proposed that the transfer of data to regional councils be the responsibility of the consent holder and should occur at least annually. Twelve submitters made a range of comments and suggestions about the data transfer requirements. These statements have been divided into three general categories: frequency, method of transfer and practicalities.

Frequency

Several submitters commented on the frequency of one year. Two said that annual reporting seems appropriate, but that there may be some circumstances that require more frequent transfer of data. One said that annual reporting was inadequate for most compliance monitoring purposes.

Four submitters said that the frequency-of-transfer requirement needs to be altered.

Their suggestions for more appropriate intervals included that the frequency of transfer should:

• reflect the level of take activity
• be on at least a quarterly basis
• be relevant to the manner in which the data will be used
• occur no less than annually.

Method of transfer

Two main methods of transfer are addressed in the discussion document: electronic and manual data transfer. One submitter said that electronic transfer can be achieved using telemetry, text message or website reports. A number of others also referred to telemetry as one method of data transfer. One submitter stated that there are limitations on the capacity of telemetered systems, and another stated that manual readings are not desirable due to the ability to falsify this information. This same submitter said that telemetered data capture is preferable.

Practicalities

A variety of practical implementation aspects were addressed by submitters, including the following:

• if data is transferred at 15-minute intervals from the measuring device to a central database, data loggers would not be necessary at each measuring station
• hardware to download data is required
• it is not always practical for consent holders to obtain information and send it to the council
• the data transfer network will require ongoing maintenance in order to avoid loss in data quality.

4.5.5 Responsibilities of data recording and transfer

Thirteen submitters referred to the responsibilities of various stakeholders for data recording and transfer requirements. Six agreed with the proposal and said that recording and transfer should be the responsibility of the consent holder. One said that users could be checked by regular audits in order to ensure they are recording and storing data consistently. One said that transfer of data should not rest with the consent holder but did not suggest an alternative option.

Two submitters stated that joint responsibility was the most appropriate scenario for managing the data recording and transfer requirements. One considered that responsibility for data recording and transfer should be shared between water abstractors and regional councils. Another considered that regional or central government should have primary responsibility for the development and implementation of appropriate systems for the transfer and management of water-use data.

Six submitters said that regional councils should have the greatest responsibility for implementing the data recording and transfer requirements. Specifically:

• three submitters said that the Government should give regional councils the responsibility for how the data is collected and derived
• one submitter said that the NES should impose a requirement on regional councils to manage water-use data in an appropriate manner and to make the accumulated data available.

Table 11: Summary of submitters' comments about data transfer

4.5.6 Format of data

The format of data recorded and transferred was commented on by six submitters.

Their suggestions included the following:

• data should be in a format that is compatible with software being used by regional councils (eg, TIDEDA)
• data should be in an electronic format agreed upon by the consenting authority
• "real-time" water-use data should be able to be publicly displayed, therefore adaptable systems are required
• event-based data is required
• data should be available in a well-known format so that it can be easily analysed (eg, Excel)
• data needs to be easily understood by water users.

4.5.7 Consistency of data recording and transfer

Various components of consistency were considered by eight submitters. Two said that an acceptable level of missing data needs to be defined. Three submitters raised the issue of ensuring consistency between and within regions, and one of these suggested that performance criteria for regional councils could be included in the NES.

Other comments included the need for:

• consistency in reporting
• a national storage system.

4.5.8 Technical practicalities

Five submitters said that there were a number of technical difficulties with the data recording and transfer section. Two commented that there were problems with maintaining an electronic meter and data logger on a portable pump. Other comments covered:

• potential compatibility issues, because a range of water meters are available and consequently a range of meter output types
• data logging being inappropriate and difficult for some takes (ie, where there is no power source)
• the issue of using supplied information for enforcement purposes, which can arise when there is self-monitoring (ie, providing self-incriminating data).

4.5.9 Further guidance

Further guidance or greater clarification about the data recording and transfer sections was requested by five submitters. Their suggestions included:

• tools need to be developed and available to users before the NES is finalised
• councils need to identify their recording and transfer requirements
• concern over how regional councils will receive, manage and make effective use of water measurement information
• support for the development of data management best-practice guidelines
• regional councils should make water-use information available to the public.

4.6 Other comments on the proposal

Six submitters made comments and suggestions about a range of subjects that were not directly applicable to any of the previous sections on the Proposed NES for Water Measuring Devices. Their comments are included below:

• a process for dispute resolution is required. One submitter suggested that this could be part of the guidelines that complement the NES
• the continuation and expansion of business operations should involve charges for water within their management structure (ie, reflect the value of the resource)
• the community in each catchment should form a company to manage water takes (which would be accountable to regional councils)
• the NES should specify that more stringent rules be allowed if a regional council deem it is appropriate
• irrigation should be restricted to the hours of 7pm to 7am to promote the most effective use of water
• the NES should also place a consent condition allocating an annual volume on those consents that do not have such a condition. The annual volume can be determined by the council in consultation with the consent holder.