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 Measurement Canada
Sector Review
Water
Consultation
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Water Trade Sector Review Minutes - Montreal
To access any of the PDF documents included in this page, please use this free Adobe Acrobat Reader as needed.
Comments and Discussions: A stakeholder asked what percentage of utilities completed the 2003 Water Trade Sector Review CWWA (Canadian Water and Wastewater Association) Survey. Mr. Welsh responded that approximately 4000 Canadian municipalities were sent the survey and 736 (18.4 percent) responded. Most of the respondents were small to medium size municipalities. Almost all of the large Canadian cities took part in the more detailed 2001 Measurement Canada Water Utility Meter Survey. The report from both of these surveys can be downloaded from our website. Option consommateur Presentation: The Option consommateur presentation was delivered by Ms. Geneviève Reed:
Comments and Discussions: A stakeholder enquired about the scope of Options consommateurs participation in the review and asked if it was representative of all consumers. Ms. Reed and Mr. Welsh gave details on the number of consumers that were contacted and on the extensive research that was conducted by their organization. Some of the questions and answers were as follows: A participant wanted to know how many people surveyed were from Montreal. Mr. Welsh replied that fifty (50) respondents were from Quebec and 74 percent of the respondents wanted regulation. He added that twenty seven (27) respondents were from Montreal and 92 percent of them wanted regulation. It was explained that the reason for the smaller number of respondents from Quebec and Montreal was due to the fact that many of the consumers, who were initially called, did not have water meters. A participant asked whether or not the surveyed people indicated that they have had a problem with their meter. Ms Reed responded that no major problems were reported. A stakeholder asked if the survey included a question about the costs of having regulations for water meters. Ms. Reed replied that the respondents in the survey were not directly asked about the cost of regulations but the focus group participants were asked this question and they were not opposed to increase costs as long as they were reasonable. No dollar figures were given to the focus group participants. A stakeholder asked Ms. Reed if the question of costs come-up often in the focus group sessions. She replied that “no” it did not come up often in the discussion with the focus groups. A copy of the Option consammateur report “Should Residential Water Meter Accuracy be Regulated in Canada” is available on our website. 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 stated recommendations. There may continue to be stakeholders who would have preferred a different recommendation. Recommendations from the previous meetings in Edmonton, Toronto and Vancouver were provided to Montreal participants. The recommendations in these minutes are from the Montreal meeting only and they may not reflect the final recommendations that are sent to Measurement Canada’s Senior Management Committee. The final recommendations will be a compilation of the recommendations from all six (6) stakeholder consultation meetings. 1. Approvals Benoit Montpetit of Measurement Canada conducted the presentation on the approval segment. 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 on the condition that it is not overly onerous or too costly. This recommendation is consistent with the Edmonton, Toronto and Vancouver meeting recommendations. Recommendation 1.2 The Type Approval process is to include provisions for testing a prototype water meter to ensure that it meets the applicable standard. This recommendation is also consistent with the Edmonton, Toronto and Vancouver meeting recommendations. Recommendation 1.3 The Type Approval process is to only apply to new water meter prototypes which 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, Toronto and Vancouver meeting recommendations. 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 , Toronto and Vancouver meeting. Comments and Discussions: Mr. Montpetit informed the stakeholders that Measurement Canada’s charges a rate of $60 per hour for the type approval process. Stakeholders were informed that Measurement Canada’s service standard for the testing of prototype measuring devices is: “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.” Stakeholders were informed by Mr. Welsh that the California Department of Agriculture, Measurement Standards Division is the only organization in North America that currently performs approval testing of water meters. This organization’s California Type Evaluation Program (CTEP) charges approximately US$2500 for the approval testing of a basic 5/8 inch residential water meter and the issuing of a Certificate of Approval Document. 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. There are organizations in other countries which also perform approval testing. A meter manufacturer representative, who attended 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 primarily concerned about the approval testing of water meters models which are not widely sold in Canada. For these models, the cost of approval testing may be quite high when looked at on a cost per unit basis. A stakeholder indicated that there may not be a need for substantial additional testing beyond that which is already being performed by the meter manufacturer. This voluntary testing is done to demonstrate that the meters are in compliance with the American Water and Wastewater Association (AWWA) meter design standards. It was mentioned that the AWWA has no approval standard for some types of meters and this organization does not test the prototype models to ensure that they meet the standards. Mr. Welsh explained how the AWWA C700 series were developed by the AWWA. Participants felt that Measurement Canada should not necessarily be the only device approval laboratory that conducts approval testing. Other authorized locations could be acceptable if they meet the established standard. Measurement Canada oversight would be required and Measurement Canada would be the organization that would make the decision as to whether or not a given water meter is approved for trade use in Canada. Measurement Canada should authorize organizations who want to provide approval testing. Approval testing in other jurisdictions could be considered if the method of testing met the established requirements. One stakeholder asked the WTSR team if standards other than AWWA existed. Mr. Welsh responded that other standards for water meters did exist. These standards would be considered if a consensus of stakeholders recommend that Measurement Canada establishes specifications for water meters. The other standards (or portions of the standards) to be considered would include:
Another stakeholder asked if water utilities generally require that water meters meet a standard when they purchase them. A meter distributor replied that in most tenders there is a provision that, as a minimum, the water meters must meet the AWWA Standard . A service company representative indicated that he supported the consumer group’s position on the type approval process because they want accuracy in water metering even if they are conscious of the added costs. In a later discussion on this topic, a manufacturer raised the concern about adding additional requirements for the Canadian market. This market represents a small portion of total water meter sales in North America. Different requirements in Canada may cause meter manufacturers to rethink their investment in the Canadian marketplace. It was requested by stakeholders that Measurement Canada should take into consideration the relatively low cost of water in Canada if regulations for water meters are established. The participants at the meeting were informed by Mr. Vinet that Measurement Canada would not create new Canadian regulations for water meters without first examining the other standards used in other international and North American jurisdictions. If needed, Measurement Canada could adapt them for the Canadian marketplace. Measurement Canada could also work with organization that develop and modify water meter standards to ensure that these standards are reflective of the wishes of the Canadian water industry stakeholders. Mr. Vinet provided the example of Measurement Canada’s membership in OIML (International Organization of Legal Metrology) and our participation in the NIST (National Institute of Standards and Technology) committees that establish specifications for trade measurement devices in the United States. A stakeholder asked if subsequent tests are required after approval. For the purposes of the type approval process some testing may be required after the device is put into service. This is often done where it is not possible or practical to test a prototype model in the laboratory. In these cases the device can be used in trade prior to receiving full approval. The WTSR team again reiterated that the approval testing is different then the initial and subsequent inspections (re-verifications) which are performed on all individual devices. A stakeholder asked Measurement Canada whether a manufacturer requires another approval if they modify an approved device. They were told that the original approval would need to be revised if the modification could effect the accuracy or use of the device. Minor changes would simply require that the manufacturer or applicant notify the Measurement Canada Approval Laboratory. A stakeholder asked whether the meter manufacturer or Measurement Canada specifies what the flow rate should be for a given type and size of meter. The WTSR team responded that the meter manufacturer specifies how the device works and what are the rated minimum and maximum flow rates. A participant asked what would happen if they buy a device that does not meet the requirements. Mr. Montpetit responded that if there is a requirement that water meters must be approved then you would not be able to use the device for billing purposes. It should be noted that there would have to be a phase-in period and existing meters would be exempt from the approval process. A stakeholder asked if a meter built in Europe could be used in Canada. Requirements should be flexible to allow for the use of a less expensive meter type (e.g. single-jet) in municipalities where the properties of the water will allow for the use of this type of meter. Mr. Welsh responded that it could be used in Canada provided the device meets the Canadian requirements. As was noted in the opening presentation, any Canadian requirements that are established must be such that they don’t pose a barrier to international and North American trade agreements. A stakeholder asked if any new requirements or standards were implemented as a result of the reviews that were completed in some of the other trade sectors. Mr. Vinet responded that some other trade sector reviews recommended that mandatory re-verification should be introduced. In other trade sectors the recommendation was that the level of Measurement Canada intervention should be reduced for certain levels of trade. He added that Measurement Canada is trying to adopt international standards whenever it is possible These standards can be modified to meet any special Canadian requirements. A stakeholder asked if Measurement Canada has the power to set legal requirements. Mr. Welsh responded that under the Constitution of Canada, the Federal Government is responsible for all weights and measures matters and Measurement Canada is the federal agency that administers and enforces the Weights and Measures Act. Mr. Vinet added that if the result of the trade sector review is that Measurement Canada should intervene and establish regulatory requirements, Measurement Canada will establish and enforce such regulatory requirements. 2. Initial Inspection Recommendation 2.1 Measurement Canada is to require that all customer billing or custody transfer water meters, used by water utilities, 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, Toronto and Vancouver meeting recommendations. Recommendation 2.2 Initial inspections may be performed by recognized and authorized 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, Toronto and Vancouver 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, Toronto and Vancouver 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 Industrial, Commercial, and Institutional (ICI) 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, also includes the recommendation made in Toronto and Vancouver, 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 is to 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, is similar to the Edmonton meeting, but also includes the recommendation made in Toronto and Vancouver that Measurement Canada should form a joint working group to establish installation requirements. Comments and Discussions: Stakeholders asked what constitutes an initial inspection. An initial inspection is the first inspection of an individual device before it may be placed into trade service. This inspection ensures that:
The participants at the meeting 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 requirements were met. A stakeholder asked what is meant by sampling. Mr. Welsh explained that sampling is when a small group of meters are randomly selected from a larger group of meters. The sample group of meters are tested and the results of the tests will determine if the meters in the entire group are in compliance with the performance requirement for that type of meter. Measurement Canada currently uses sampling in the inspection of many electricity and natural gas meters as well as for the net quantity inspection of some pre-packaged products. The sampling plans used are based on ISO (International Organization for Standardization) standards. It was agreed by all stakeholders at the meeting that statistically valid sample testing was acceptable and this option should be considered. As in the previous meetings, several stakeholders stated that incorrect installation of ICI meters can have a huge impact on accurate measurement. It was agreed that manufacturer’s installation requirements should be the minimum requirements for the installation of ICI meters. A meter manufacturer expressed concerns about the cost of the initial inspection and the fact that it would be passed on to the water utilities. Their concern was mainly caused by the fact they did not know what the new requirements would be. Their concerns would be lessened if the initial inspection procedure was in-line with the current procedure they use for the calibration and testing of new water meter. A meter distributor said that we should look at what is being done in the USA for initial inspection in order to establish our initial inspection procedures. He cautioned that by changing components in the meter, the calibration could be altered. Two other stakeholders mentioned that they had found water meters with the wrong register in service. Several stakeholders also expressed concern as to what would constitute an initial inspection and whether or not an initial inspection would be required if a register was replaced. There was also the concern of whether an installation inspection would be required if a replacement meter was put into an existing water service. One question was asked about what will happen when a new customer moves into an existing building and the new customer has a significantly different water usage. Will water meter sizing be included in the regulations. These are all areas that the joint working group will have to consider when developing water meter specifications A stakeholder wanted to know if Measurement Canada could establish water meter installation specifications which are based on the manufacturer’s requirements. The utilities would then follow these specifications when conducting the installation inspections. Mr. Welsh replied that this was possible and the joint working group would decide on what specifications would be required. Mr. Welsh gave examples of other Measurement Canada specifications where the installation requirements are of a general nature and they complement the manufacturers installation requirements. Mr. Welsh asked some of the water utility representatives at the meeting what would happen if a contractor installed a water meter that causes 50 percent under registration. Would the utility leave the installation as is and put the meter into service? A stakeholder replied that it is quite possible that the installation would be left as is due to the political pressure that the municipality is under. 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 recommendation is to apply to all meter sizes and types for ICI customers. Special consideration should be given to residential water meters in cases where the customer’s annual water bill is low. This recommendation is consistent with the Edmonton and Toronto meeting recommendation except for the re-verification of residential water meters and the mention of “at all levels of trade”. At the Montreal meeting, stakeholders felt residential meters should be looked at differently if the water charges are not high. At this meeting there were no stakeholders present who were directly involved in the trade transaction of water between municipalities and therefore this issue was not discussed. Recommendation 3.2 Re-verification inspections may be performed by recognized or authorized organizations 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, Toronto and Vancouver meeting recommendations. 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 other meetings. Comments and Discussions: It was recommended that a 3/4 to 5/8 inch residential water meter should be re-inspected or replaced within 20 or 25 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 earlier date. Some stakeholders mentioned that the volume that passes through the meter should be considered when setting re-verification periods. It was pointed out that for many municipalities it may not be practical to administer the tracking of volume for 5/8 inch meters. One stakeholder suggested that limits of errors used to determine if a water meter passes or fails re-verification should be established for water meters. These limits of error should be less stringent for residential water meters. The joint working group should consider a tolerance greater than 1.5 percent. The joint working group should develop requirements that allow more than one option for residential water meters. The price per cubic metre charged by the water utility should also be considered when determining the allowable tolerances for in-service water meters. A concern was raised by one participant regarding the potential conflict of interest if manufacturers are allowed to perform meter re-verification. The consensus of the rest of the participants was that this practice was not perceived as being a conflict of interest. In Vancouver, the issue of accessing residential water meters was not a major concern. The water utilities in the Greater Vancouver area now installing residential water meters in meter boxes. These boxes are located outside of the house. This differs from other Canadian locations where extreme cold weather necessitates that the water meters are installed inside the customer’s residence. Some stakeholders stated that in the City of Montreal it would be very costly to remove or replace water meters because it is extremely difficult to access some of the meters. One meter service company disagreed and said that it was not that big of a problem and the time it takes to replace a residential meter is quite short. A stakeholder stated that at one time water meters were refurbished by replacing the inside seals, bushings, and/or pistons. This procedure is no longer practised by almost all water utilities.
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| Created: 2005-08-04 Updated: 2005-12-02 |
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