5 Implementation of the Proposed Standard
Submissions on the implementation of the Proposed NES for Water Measuring Devices were broken down into eight main sub-themes. A large number of submitters commented on the implementation of the proposed NES, with concerns and suggestions ranging from the training of the water meter industry to water-meter guidelines.
5.1 Capacity issues
Thirteen submitters made suggestions and comments about the capacity issues that may arise from implementing the Proposed NES for Water Measuring Devices.
Seven submitters felt that implementing the NES would require large amounts of time and resources, at the regional council level in particular. Reviewing existing consents and ongoing monitoring was seen to be a time-consuming process by these submitters. One submitter suggested that central government resources should be provided to assist the implementation process. An alternative suggestion was that the monitoring requirements should be in proportion to the potential adverse effects.
Two submitters were concerned that sudden widespread implementation would increase the number of unskilled technicians. One suggested that this problem could be alleviated by collating a list of skilled technicians in order to improve implementation. Another considered there was a need for guidance material on installations.
A number of submissions referred to an audit procedure as part of the implementation process. Four submitters argued that there needs to be an audit of the water-metering industry in order to achieve consistency. Specific comments included:
- prospective suppliers should be audited to a certain standard in order to avoid cheap imports from flooding the market
- currently anyone can sell a flow meter - this needs to alter for the NES to be effective.
Table 12: Summary of submitters' comments about capacity issues
|
Comment |
Submitter number |
|---|---|
|
Reviewing existing consents and monitoring will be a time-consuming process |
18, 36, 40, 49, 52, 65, 66, 70 |
|
An audit process required |
1, 48, 57, 71 |
5.2 Implementation timeframe
The timeframe for implementing the NES was commented on by six submitters, five of whom argued that more flexibility is required. Comments included:
- the NES should only be implemented when existing permits come up for review
- councils should be able to review existing consents to require data loggers when circumstances warrant it
- some locations will find it difficult to comply within the timeframe
- a phased timetable for implementation is the most appropriate, so that those who account for the greatest proportion of water takes are required to comply first.
One submitter commented that the five-year timeframe is too long and that this should be altered to accelerate the implementation process.
5.3 Meter guidance
Six submitters suggested that national guidelines for water meters be required or a list of compliant meters developed. Two submitters recommended that a list of appropriate meters and loggers which would meet the requirements of the NES be developed. One view was that this would ensure that all data storage mechanisms would be compatible with regional council systems. Two submitters said that guidelines to test meters were also required in order to have consistent confirmation that a water meter is fit for the purpose.
5.4 Implementation guidance
Six submitters commented on how regional councils might implement the proposed NES.
The majority of these said that more guidance is required in order to clarify the responsibilities of regional councils with regard to implementation. One suggestion was that the NES should require regional councils to establish an annual reporting regime for all water sources to ensure standardisation. Comments from other submitters included:
- the NES could potentially be too flexible in allowing regional councils to choose and specify more stringent requirements
- the process surrounding application for, and granting of, exemptions needs to be clearly specified
- the NES should provide for greater discretion to be exercised by regional councils as to actual metering requirements.
5.5 Industry training
Improving the capacity of those affected by the NES for water measuring devices was addressed by four submitters. Training of both the water-metering industry and those who have water takes was commented on.
One submitter said that a significant number of water users do not have the skills to use computers for data logging, so training is required. Three submitters said that water-metering companies should have standardised qualifications. One suggested that commercial practitioners could be certified by skilled regional council staff. Other specific comments from submitters included:
- companies should have trained personnel and calibration certificates
- a national training programme or certification process is required.
5.6 Operational problems
Three submitters had concerns about the practicality of implementing the NES requirements. Specific problems mentioned included:
- it may not be possible to retrofit a measurement device in a way that achieves the accuracy of the proposed standard
- operational problems for pumped systems are envisaged
- it is false to assert that existing water measuring devices can be easily and cheaply upgraded to data-logging capability.
5.7 Implementation planning
The future direction of the NES implementation process was commented on by two submitters. One suggested that central government form a task force of councils to assist in the implementation of the NES. The other said that the NES needs to be aligned with the best approach for water quantity and quality so that they are compatible.
5.8 Other
A number of submitters made reference to a range of other aspects relating to implementation of the NES, including enforcement procedures and inconsistent approaches. Specific comments included:
- fines should be introduced for non-compliance (or the consent revoked if data is not supplied)
- implementation requirements within the NES are at odds with earlier statements and the consultation workshops.
