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 Measurement Canada
Sector Review
Water
Consultation
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Water Trade Sector Review Minutes - Halifax
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 if Measurement Canada is the agency that can require water utilities to use meters for the billing of water. Mr. Welsh responded that Measurement Canada does not have the power nor the intent of requiring the mandatory use of a water meter when billing the customer for the volume of water consumed. Mr. Welsh added that some provinces require universal water metering when giving infrastructure grants to local municipalities. Another stakeholder asked if Measurement Canada intends to regulate water meters in the same manner as it does for electricity and natural gas meters. Measurement Canada representatives explained that Measurement Canada has no agenda in regards to regulating water meters. The recommendations put forward at the stakeholder meetings will be the basis for Measurement Canada’s level of intervention in the water trade sector. One participant asked if Measurement Canada had contacted the National Research Council (NRC) in regards to the Best Practices Guide for Water Meter Use (Establishing a metering Plan to Account for Water Use and Loss). This document was developed by the NRC in cooperation with the Canadian Federation of Municipalities. Mr. Welsh replied that Measurement Canada has been in contact with the author of that document. A stakeholder stated that Mr. Guy Fillion had been presenting information on the various Best Practices Guides to municipalities across Canada. This stakeholder felt that municipalities should follow the Best Practices Guide and Measurement Canada intervention may not be required. Mr. Welsh replied that most of the water utility and municipal representatives that he had met were unaware of the existence of this document. Option consommateur Presentation: The Option consommateur presentation was delivered by Ms. Geneviève Reed:
Comments and Discussions: A stakeholder asked if consumers had indicated what level of Measurement Canada intervention they wanted in regards to water meters. Ms. Reed responded that consumers were not directly asked what level of intervention should be used for water meters, but that from the feedback that was received, the vast majority wanted national regulations for water meters in Canada. Another participant asked if consumers know that a water meter is used as a management tool, not as a measurement device. Ms. Reed replied that consumers were not asked that question. A stakeholder asked why consumers were told that there were no regulations because the American Waste and Wastewater Association (AWWA) standard is a regulation. Mr. Welsh responded by stating that the AWWA standard is not a regulation unless it is designated to be one by a government body. It was stated that presently it is a voluntary standard which individual utilities may or may not follow. 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, Vancouver and Montreal were provided to Halifax participants. The recommendations in these minutes are from the Halifax meeting only and they may not reflect the final recommendations that are sent to Measurement Canada’s Senior Management Committee (SMC). 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 on the condition that it is not overly onerous or too costly. This recommendation is consistent with the Edmonton, Toronto, Vancouver and Montreal 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, Vancouver and Montreal meeting recommendations. 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, Toronto, Vancouver and Montreal 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, Vancouver and Montreal meeting. Comments and Discussions: Mr. Welsh informed the stakeholders that Measurement Canada’s charges a rate of $60 per hour for the type approval process. 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. Stakeholders agreed 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 use in trade in Canada. The stakeholders agreed that 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. A meter manufacturer at the meeting asked Measurement Canada whether another approval is needed if they modify an approved device. Mr. Welsh explained that the original approval would need to be revised if the modification could affect 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 if a water meter built in Europe could be used in Canada. Mr. Welsh responded that it could be used in Canada provided the device met the Canadian requirements. He also reiterated that if Canadian requirements are established, they must be such that they don’t pose a barrier to international and North American trade agreements. A participant was interested in knowing why Australia was requiring residential meters to be approved ahead of larger commercial water meters. Mr. Welsh presumed that in Australia this scenario was adopted to provide a degree of confidence in the devices at the level where. After the meeting, Mr. Welsh contacted Mr. Terry Lancaster of the Australian National Measurement Commission. He confirmed that because these consumers have the least ability to protect themselves, residential water meters were chosen as the initial device type for revocation of the Weights and Measures exemption. Mr. Welsh speculated that the possible reason they only approve devices up to 350 mm in diameter in Japan may be due to the physical limits of testing a meter with a known quantity of water. Another participant asked if a manufacturer could be authorized to perform approval testing. Mr. Welsh responded that a manufacturer could perform approval testing provided they met the established requirements. Only Measurement Canada would have the authority to grant the Notice of Approval. A stakeholder stated that the use of water meters can have a great effect on the amount of water consumed by the average residential service. An average residential service in Canada (with no meter) annually uses approximately 50 percent more water than a metered residential service. Another stakeholder stated that they have installed 20 000 waters meters since 1993 and he wondered what the cost would be if all the meters had to be approved. Mr. Welsh explained that only the prototype model would have to undergo approval testing and all meters that were already in service would be exempt from the approval process. Another city representative indicated that his city had spent between 7 to 12 millions dollars on new meters and he wondered if any new legislation and/or Measurement Canada involvement would not cost his taxpayers $2 for every $1 the city saved. The stakeholders did acknowledge that water meter accuracy is important since the meters are used to apportion the costs of providing water services and/or wastewater services to their customers. A service company participant indicated that one of his clients (municipality) had spent $14 000 to find out that they were under-metering by $5000. He did however state that the municipality felt in the long run, the money spent was a good investment since they now had a better idea of the accuracy of their water meter population. As was mentioned at the other meetings, the meter manufacturers are mainly concerned with the uncertainty as to what the standards or specifications will be for water meters used in trade 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, 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, Vancouver and Montreal meeting recommendations. Recommendation 2.2 Initial inspections may be performed by recognized and authorized organizations provided they meet established requirements. Initial inspections could be done at any recognized location (ex. factory, utility, service company or in-situ) as long as the devices comply to all established requirements before being used in trade. This recommendation is also consistent with that from the Edmonton, Toronto, Vancouver and Montreal meeting recommendation. The wording has been changed to indicate that initial inspections could be conducted at any recognized location. 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, Vancouver and Montreal meeting recommendation. Recommendation 2.4 Municipalities or water utilities should 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 water meters at all levels of trade. 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 four previous meetings, also includes installation requirements for residential water meters. 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, Toronto, Vancouver and Montreal in that Measurement Canada should form a joint working group to establish installation requirements. Comments and Discussions: A participant felt that the term inspection was confusing since the industry uses the word “testing or meter test” when describing the procedure used to check the accuracy of the meter. Mr. Welsh explained that Measurement Canada uses the terms “inspection, verification and re-verification” to describe this operation. The participants at the meeting agreed that meter manufacturers will probably conduct the majority of water meter initial inspections, but they also expressed their belief that a water utility or 3rd party organization should be allowed to perform initial inspections provided that the established requirements are met. A stakeholder asked what is meant by sampling. Mr. Stouros explained that sampling is when a smaller group of like 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 larger group are in compliance with the performance requirement for that type of meter. Mr. Welsh explained that Measurement Canada currently uses sampling in the inspection of many electricity and natural gas meters, as well as in the net quantity inspection of some pre-packaged products. It was agreed by all stakeholders at the meeting that a statistically valid sample testing was acceptable and this option should be considered. Stakeholders stated that incorrect installation of industrials, commercials and institutionals (ICI) meters can have a huge impact on accurate measurement. This fact was also mentioned in the previous meetings. It was agreed that the manufacturer’s installation requirements should be the minimum requirements for the installation of ICI meters. As in previous meetings, meter manufacturer expressed their concerns about the cost of the initial inspection and the fact that any additional costs 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 a new water meter. 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 compliment the manufacturer’s installation requirements. Stakeholders raised concerns about the need for Measurement Canada to recognize that the original testing and/or initial inspection of the meter may take place outside of Canada. Measurement Canada should recognize the testing that is done at these facilities if they can meet the Canadian requirements. The meter manufacturers mentioned that testing of large meters can be performed at many of their test facilities in North America or Europe. 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 of water meters. 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 recommendations from the Edmonton, Toronto and Vancouver meetings. The stakeholders in the Montreal and Halifax meetings believe residential meters, in locations where water charges are low, should be looked at differently. 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 any recognized location (ex. water utility meter shops, meter manufacturer test facilities, or 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, Vancouver and Montreal meeting recommendations. 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:
This recommendation is also similar to the previous four meetings, but the joint working group is provided with some factors that they must take into consideration when establishing re-verification requirements. Measurement Canada should consider sustainable alternatives to the existing accreditation and registration programs for meter re-verification in the water sector. Comments and Discussions: Although the majority were in agreement, a consensus was not reached as to what the time criteria should be for the replacement or re-inspection of 5/8 inch and 3/4 inch residential water meter. The stakeholders felt that the joint working group should look at many different factors when deciding on this matter. This should include the study of test results from a cross-section of Canadian municipalities. Factors that should be considered include:
Stakeholders recommended that re-verification inspections could be done via sample testing. The meters could stay in service if the sample test results were acceptable. It was agreed that the larger the size of water meter, the greater the need for an earlier re-verification inspection. It was noted that sampling may not be an option for small utilities since they may have a small number of meters due for re-verification in any given year. Mr. Stouros mentioned that the Measurement Canada sampling plans used in the re-verification of electricity and natural gas meters allow for samples to be taken from lots that have seal expiry dates of two consecutive years. Something similar could be considered for water meters. Another option to consider would involve taking a sample of meters from two or more small municipalities. There could be advantages and disadvantages associated with this practice. Another option discussed would allow for the replacement of the meter instead of having it re-verified. It was requested that any requirements for re-verification periods take into consideration the high cost of removing and installing new or re-calibrated residential meters. A stakeholder mentioned that the meters often get filled with silt and they are often flushed out before they are tested in a meter shop. Testing the meters at a test facility may yield different results when compared to testing the same meter in-situ. The stakeholders agreed that it is not practical to test residential meters in-situ. A stakeholder wanted to know if meters that are already in-service would be grandfathered from re-verification. This stakeholder also wanted to know if a decision was made that all meters needed a re-verification after 20 years, would the municipalities have to immediately remove all of the meters in question. Mr. Welsh responded that these are areas which the joint working group would discuss and the vulnerable parties would have to agree with the decisions made. The final decision on this matter would ultimately be made by Measurement Canada’s Senior Management Committee. Some participants expressed their belief that mandatory re-verification inspections may drive some municipalities to introduce a flat rate price structure or to abandon water metering for residential services. This will exacerbated if the cost of the re-verification program far outweighs the increase in revenues that the municipality derives from the introduction of the program. Another concern expressed by some municipal water officials is that the introduction of mandatory re-verification inspections may not be enough to sway the political will needed to fund this type of requirement. One stakeholder felt that making re-verification inspections mandatory is a drastic change which could have a dramatic impact on small utilities. He was concerned that to go from no regulation to mandatory re-verification inspections may force some utilities to abandon the use of water meters. He suggested that Measurement Canada should first introduce voluntary guidelines with a slow transition to the use of mandatory regulations if the situation so warrants it. One stakeholder was concerned that Measurement Canada would introduce regulations but not follow up on the enforcement of the regulations. Mr. Welsh reiterated that one of the criteria of the trade sector review process is that all recommendations must be sustainable and enforceable. Several stakeholders expressed their belief that the vast majority of utilities would out-source the meter testing (re-verification inspections) to other recognized organizations. The point was raised by a meter manufacturer representative that several provinces now require that utilities and municipalities are legally bound to maintain depreciations funds for all aspects of their water and sewer systems. A stakeholder made a point of saying that a re-verification program was necessary to ensure the accuracy of the meters and to give us knowledge on when to change or calibrate the meters. A service company representative proposed that Measurement Canada should set minimum requirements. An individual water utility or municipality should then have the option of submitting an alternative inspection plan which will be considered by Measurement Canada. A water utility representative proposed that the utilities should be required to file a plan with Measurement Canada detailing their re-verification program. This plan would be in the public domain and it would not require Measurement Canada’s acceptance. This would be similar to the Canadian Environmental Protection Act (CEPA) program that was implemented by Environment Canada. The final consensus on this matter was that there should be mandatory re-verifications for water meters in Canada. This decision was contingent on the need for extensive consultation with all stakeholders on the details developed by the joint working group prior to the implementation of any mandatory re-verification inspection requirements.
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| Created: 2005-08-04 Updated: 2005-12-02 |
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