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 Measurement Canada
Sector Review
Water
Consultation
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Water Trade Sector Review Minutes - Toronto
To access any of the PDF documents included in this page, please use this free Adobe Acrobat Reader as needed.
Option consommateurs Presentation: The Option consommateurs presentation was delivered by Ms. Geneviève Reed:
Discussions and Recommendations Recommendations: The following recommendations were derived through consensus. This implies that the vast majority of stakeholders who attended the meeting agreed with the recommendations. There may continue to be stakeholders who would have preferred a different recommendation. Recommendations from the previous meeting in Edmonton were provided to the Toronto participants. The recommendations in these minutes are only from the Toronto meeting and they may not reflect the final recommendations that are sent to the Measurement Canada Senior Management Committee. The final recommendations will be a compilation of the recommendations from all six (6) stakeholder consultation meetings. 1. Approvals Recommendation 1.1 Measurement Canada is to require that all customer billing or custody transfer water meters, used by water utilities, must be Type Approved (including updates and revisions) before they can be used in trade. This would apply at all levels of trade. This recommendation is consistent with the Edmonton meeting recommendation. Recommendation 1.2 The Type Approval process will include provisions for testing a prototype water meter to ensure that it meets the applicable standard. This recommendation is also consistent with the Edmonton meeting recommendation. Recommendation 1.3 The Type Approval process is to only apply to new water meter prototypes that are submitted for approval after a certain date (to be determined). Existing water meter models used in trade will continue to be exempt from the type approval process. This recommendation is consistent with the Edmonton meeting recommendation. Recommendation 1.4 Measurement Canada is to form a joint working group, with representation from all applicable stakeholders, that will establish the details of the requirements for the Type Approval of water meters. Again, this is consistent with the recommendation from the Edmonton meeting. Comments and Discussions: Stakeholders want Measurement Canada to make sure that approval testing is not a costly process. Stakeholders were told that Measurement Canada approval testing for a basic volumetric petroleum meter (up to 2 inch in diameter) generally costs around $4000 . More complex meters can cost up to $7000 . Single approvals often include more then one type of model and/or size of meter. In general, meters and registers are approved separately and, if compatible, they can be used together as a single measuring device. It should be noted that these costs are for petroleum meters which are required to have an in-service limit of error of 0.25 percent. The approval testing for water meters may involve a reduced amount of testing. The Measurement Canada service standard for the testing of prototype measuring devices is as follows: “A Notice of Approval will be issued within 90 calendar days of receipt of the instrument and all appropriate documentation if the instrument is found to be in compliance with the requirements.” Delays as long as eighteen months sometimes do occur. This is usually the result of the manufacturer not supplying the necessary technical data and/or the device does not initially meet the performance requirements. Stakeholders were informed at the meeting that cold water meter approval testing is performed by the California Department of Agriculture, California Approval Program (CAP). After the meeting, Mr. Welsh contacted Mr. Dan Reiswig, Technical Manager, Liquid Measuring Devices Lab, Division of Measurement Standards, California Department of Agriculture. Mr Reiswig said that his organization charges approximately US$2500 for the approval testing and issuing of a Certificate of Approval document for a basic 5/8 inch residential water meter. The approval process takes about two months but with the upcoming move to a new facility they hope to reduce this time to one month. The meter manufacturer representatives at the session informed the other stakeholders that the cost of approval testing would likely be reflected in the selling price of the water meters. They are also concerned about the cost per unit for the approval testing of water meters models which are not widely sold in Canada. As was mentioned in Edmonton, Toronto meeting stakeholders are concerned that the (AWWA) American Water and Wasterwater Association standard C700 does not apply to some types of water meters (ex: Mag Meters). It was expressed by one stakeholder that the (OIML) International Organization of Legal Metrology standard R49-1 only applies to electronic meters. The WTSR team is to verify the scope of the OIML standard. It was also expressed that the OIML standard would be a step backwards as far as tolerances are concerned. Update OIML R49-1 Scope 1.1 This Recommendation applies to water meters used to meter the actual volume of cold potable water flowing through a fully charged, closed conduit. These water meters shall incorporate devices which indicate the integrated volume. 1.2 This Recommendation sets out the conditions with which the water meters shall comply to meet the requirements of the Services of Legal Metrology in countries where these instruments are subject to State controls. 1.3 This Recommendation also applies to water meters based on electrical or electronic principles, and to water meters based on mechanical principles incorporating electronic devices, used to meter the actual volume flow of cold potable water. It also applies to electronic ancillary devices. As a rule ancillary devices are optional. However, national or international regulations may make some ancillary devices mandatory in relation to the utilization of the water meter. Most water meter manufacturers claim to meet the AWWA Standard. Manufacturers sit on the committee that establishes the AWWA Standard. Stakeholders indicated that there may not be any testing needed other than by the manufacturers to demonstrate compliance with AWWA meter design standards. Measurement Canada should not be the only device approval laboratory. Other authorized locations could be acceptable if they meet the established standard and have a good track record. Measurement Canada oversight would be required. Measurement Canada should authorize organizations who want to provide approval testing. Other jurisdictions could be used but they must meet the requirements. (consensus). AWWA is the recommended criteria for approval testing but other standards should be studied. OIML R-49-1 should be looked since new meters, manufactured outside of North America, may be introduced into the marketplace in the future. In a later discussion, on this topic, manufacturers raised the concern about adding additional requirements for the Canadian market which is a small portion of water meter sales and that this may have manufacturers rethinking their investment in Canada. 2. Initial Inspection Recommendation 2.1 Measurement Canada is to require that all customer billing or custody transfer water meters used by water utilities, must pass a mandatory initial inspection before being used in trade. This should apply at all levels of trade. This recommendation is consistent with the Edmonton meeting recommendation. Recommendation 2.2 Initial inspections may be performed by any person or organization provided they meet established requirements. Initial inspections could be done either at the factory or in-situ, when required, as long as the devices comply to all established requirements before use in trade. This recommendation is also consistent with that from the Edmonton meeting recommendation. An additional point to this recommendation is that a separate model for alternative service delivery should be considered for the water sector and that the existing accreditation and registration programs may not be a good fit for this sector. Recommendation 2.3 The requirement for initial inspection should only apply to new water meters. Water meters already in-service will be exempt from the initial inspection requirement. This recommendation is consistent with the Edmonton meeting recommendation. Recommendation 2.4 Municipalities or water utilities will be responsible for the inspection of the installation of water meters. Measurement Canada should work with the water industry to establish standard requirements for the installation of (ICI) Industrial, Commercial, and Institutional water meters. The industry is to follow manufacturer specifications, local plumbing codes and any other requirements needed to ensure the meter is measuring accurately. This recommendation, although similar to the Edmonton meeting, includes the recommendation that Measurement Canada work with the water industry to establish installation requirements rather than leave installation requirements to the industry. Recommendation 2.5 Measurement Canada should form a joint working group, with representation from all applicable stakeholders, to establish the details of the initial inspection requirements. A joint working group approach should also be used to establish the installation requirements. This recommendation, although similar to the Edmonton meeting, includes the recommendation that Measurement Canada also should form a joint working group to establish installation requirements. Comments and Discussions: Stakeholders agreed that meter manufacturers will probably conduct the majority of water meter initial inspections but they also expressed belief that an utility or 3rd party organization could be used to perform initial inspections provided that the established requirement were met. At the meeting, a stakeholder asked the WTSR team which type of organizations were conducting the initial inspection of water meters in Europe. Update: Some example of which type of organizations conduct initial inspections of water meters in Europe for. Country Germany Organization Type accredited meter laboratory Country France Organization Type accredited meter manufacturer Country Portugal Organization Type accredited meter manufacturer Country United Kingdom Organization Type accredited meter manufacturer or government inspector It was agreed by all stakeholders that a statistically valid sample testing was acceptable and this option should be considered. Concern was raised by a few stakeholders about the present process used by some meter manufacturers at their test facilities when they conduct meter calibrations/tests on residential meters. This process involved testing the register and the meter body separately. Manufacturers clarified that this was done to save time. Discussions were also made about whether a security seal needed to be affixed to all or some of the water meters used in trade. Stakeholders stated that incorrect installation of ICI meters can have a huge impact on accurate measurement. The use of wrong registers can also have an effect on the accuracy of the registration. It was agreed that manufacturer’s installation requirements should be the minimum requirements for the installation of ICI meters. In a later discussion with WTSR team members, meter manufacturers acknowledged that consumer and utility stakeholders want to make initial inspections mandatary. The manufacturers want to express their concerns about the potential for additional costs if they are required to make major changes to the methods they use to process new water meters which are sold in Canada. 3. Re-verification Inspections Recommendation 3.1 Measurement Canada to require that all customer billing or custody transfer water meters, used by water utilities, be subjected to a mandatory re-verification inspection. This would apply at all levels of trade. This recommendation is consistent with the Edmonton meeting recommendation. Recommendation 3.2 Re-verification inspections may be performed by any person or organization provided they meet the established requirements. Re-verification inspections could be conducted at water utility meter shops, meter manufacturer test facilities or by 3rd party meter service organizations. Where it applies, re-verification inspections could also be conducted in-situ. This recommendation is consistent with the Edmonton meeting recommendation. Sustainable alternatives to the existing accreditation and registration programs should be considered for meter re-verification in the water sector. Recommendation 3.3 Measurement Canada is to form a joint working group, with representation from all applicable stakeholders, to establish the details of the re-verification inspection requirements. This will include re-verification periods, sampling plans, and the option to re-verify or replace meters. The requirement for re-verification inspections should be implemented over a period of years (phase-in). This recommendation is similar to the Edmonton meeting with added mention of phase-in periods. Comments and Discussions: Some stakeholders felt that re-verification testing should be done strictly on a voluntary or best practices basis. One stakeholder proposed that re-verification testing should initially be done on a voluntary or best practices basis and regulation only be put in place if an insufficient number of municipalities were adhering to this option. As was mentioned at the Edmonton session, some stakeholders believe that by having a regulation in place, utility managers felt more empowered to ask their superiors for funds to re-test their meters. In the end, the WTSR team went around the table to reach a consensus as to whether the requirement for re-verification/ meter replacement should be regulated or done on a voluntary/best practices basis. The criteria for reaching the consensus on this matter was as follows:
Ten stakeholders were in favour of regulation and three were in favour of voluntary or best practices. The consensus therefore was that there should be regulations put in place to require meter re-verification or replacement. An overlying concern with any re-verification requirements is the cost to the municipality and their taxpayers. It was felt that many of the larger municipalities are already re-testing their meters and the costs would be minimal. Smaller municipalities may not have the resources to be able to re-test their meters. It was recommended that a 3/4 to 5/8 inch residential water meter should be re-inspected or replaced within 20 years of installation. Re-inspection could be done via sample testing, with meters staying in service if the sample test results were acceptable. It was also agreed that the larger the size of water meter, the greater the need for re-inspection or replacement at an early date. Another issue addressed was the strong belief that the meters are always under-registering and therefore no customers were being overcharged. The question of non-equity within the water system caused by inaccurate meters was discussed. Several stakeholders acknowledged that their customers would not be happy to know that they were paying more then their neighbour even though they were consuming the same amount of water. The issue of the costs to rectify this problem were raised. Some stakeholders mentioned that the volume that passes through the meter should be considered when setting re-verification periods. This was especially true for ICI meters. For many municipalities it may not be practical to administer the tracking of volume for 5/8 inch meters. Stakeholders asked if there was any funding available to offset the cost of implementing these recommendations. Measurement Canada stated that no funding is available from them. One manufacturer stated that funds have been provided in the past through the Infrastructure Program for the installation of water meters. It was noted that there were no participants from the custody transfer meter manufacturing industry present at the meeting. The WTSR team agreed this was a the concern but they had invited consumers at all levels to attend either in person or by phone. One meter manufacturer representative stakeholder thought that it may not be necessary for re-verification inspections at large custody transfer points where regional water suppliers sell water to city or municipal purchasers. The municipalities at the meeting who bought or sold water from other jurisdictions all felt that their meters should be subjected to re-verification but the WTSR team will discuss this matter at other meetings if there are parties present who engage in this type of high level trade transaction of water. For a water utility one of the major costs of replacing a residential meter is the time spent accessing water meters in private dwellings.
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| Created: 2005-08-04 Updated: 2005-12-02 |
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