ARCHIVED—Water Trade Sector Review — Decisions

Measurement Canada’s Senior Management Committee’s Decisions - Water Trade Sector Review Recommendations

2004-06-15

This document contains Measurement Canada's decisions regarding the recommendations for establishing an appropriate level of intervention in the water trade sector.

This document should be read in conjunction with Recommendations for Establishing an Appropriate Level of Measurement Canada Intervention in the Water Sector (distributed in May 2004), and the associated discussion paper (distributed in January 2004). These recommendations were developed after extensive consultation with sector stakeholders.

The goal of this document is to communicate the decisions of Measurement Canada senior management and associated explanations, considerations and clarifications.

Measurement Canada is presently identifying and analysing the legislative and regulatory changes that will be required to implement the recommendations. The implications associated with adopting the recommendations will also be considered. This work will enable Measurement Canada to determine the implementation schedule and major milestones. Stakeholders will be consulted during the development of the implementation plan and the document will be completed in the fall of 2004.

Type Approval

Recommendation #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 and a cost benefit analysis is to be performed before the program is launched.

Recommendation #2
The type approval process is to include provisions for evaluating a prototype water meter to ensure that it meets the applicable standard

Recommendation #3
The type approval process is to only apply to 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.

Recommendation #4
Measurement Canada is to form a joint working group to establish the details of the requirements for the type approval of water meters. Representation on the group will be from all applicable stakeholders groups.

Measurement Canada Decision:

• Recommendations 1, 2, and 4 accepted.
• Recommendation 3 partially accepted.

Considerations, Conditions and/or Limitations:

• Measurement Canada will pursue the adoption of international standards (e.g. American Water and Wastewater Association (AWWA), International Organization of Legal Metrology (OIML), International Organization for Standardization (ISO) ) to facilitate future mutual acceptance agreements for Type Approval evaluation and to avoid creating technical barriers to trade for foreign meter manufacturers. In consultation with its stakeholders, Measurement Canada will also participate in the review and development of these international standards to address the needs of Canadians.
• A sunset date will be determined, in consultation with stakeholders, by which point all new water meters sold and installed for billing purposes will have to be of a type approved by Measurement Canada. This will mean that existing model designs, which are still being sold after the sunset date, will also have to be submitted to Measurement Canada for type approval. This is necessary to ensure a level playing field for all meter manufacturers and distributers.

Initial Inspections

Recommendation #5
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. Where applicable, Measurement Canada should recognize the use of a statistically valid sample testing plan when the mandatory initial inspection of water meters is performed. The initial inspection requirement should apply at all levels of trade.

Recommendation #6
The initial inspections of water meters 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.

Recommendation #7
The requirement for initial inspection should only apply to water meters that are put into service after a certain date (to be determined). Water meters already in-service will be exempt from the initial inspection requirement.

Recommendation #8
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.

Recommendation #9
Measurement Canada is to form a joint working group to establish the details of the initial inspection requirements. The group is to include representation from all applicable stakeholders. A joint working group approach should also be used to establish the installation requirements. The joint working group is to perform a cost/benefit analysis before initial meter inspection is made mandatory.

Measurement Canada Decision:

• Recommendations accepted.

Considerations, Conditions and/or Limitations:

• None

Re-verification Inspections

Recommendation #10
Measurement Canada is to require that all customer billing or custody transfer water meters, used by water utilities, be subjected to a mandatory re-verification inspection. Where applicable, Measurement Canada should allow the use of a statistically valid sample testing plan when the mandatory re-verification inspection of water meters is performed. The mandatory re-verification inspection should apply to all levels of trade except where a regional municipal authority is supplying water to its member municipalities. For this level of trade it is recommended that water meters be exempt from mandatory re-verification requirements but a “best practices” or “protocol” process should be established by the Regional Municipality to ensure the water meters are performing to the required standard.

Recommendation #11
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. Measurement Canada should consider sustainable alternatives to the existing accreditation and registration programs for meter re-verification in the water trade sector.

Recommendation #12
Measurement Canada is to form a joint working group to establish the details of the re-verification inspection requirements. The joint working group will include representation from all applicable stakeholders. The joint working group is to perform a cost-benefit analysis before re-verification is made mandatory. The details of the re-verification inspection requirements will include re-verification periods, sampling plans, and the option of replacing the meter in lieu of a re-verification inspection. The requirements for re-verification inspections should be implemented over a period of years (phase-in) and take into account:

• the economics of a water meter inspection program;
• the composition of the water;
• the method of charging for water and sewer services (when based on water meter registration);
• the water and sewer rates.

Measurement Canada Decision:

• Recommendations 10 and 11 accepted.
• Recommendation 12 partly accepted.

Considerations, Conditions and/or Limitations:

• The technical requirements for re-verification inspections should not take into account the economics of a water meter inspection program, the composition of the water; the method of charging for water and sewer services, nor the water and sewer rates. The establishment of requirements on the basis of these factors would lead to major inconsistencies across the country and would be extremely difficult to administer and enforce. However, some of these factors are to be considered when establishing accuracy limits of errors for in-service meters and when conducting the cost-benefit analysis of the program.

Legislation

Recommendation #13
Measurement Canada should establish and implement regulations and/or specifications for meters used by water utilities for customer billing or custody transfer . This will apply for all water meters at all levels of trade.

Recommendation #14
Measurement Canada is to form a joint working group to establish the details of the requirements for water meters. The joint working group will include representation from all applicable stakeholders. Areas to be discussed will include type approvals, initial inspection requirements, re-verification requirements, installation requirements and performance requirements. The joint working group is to look at existing legislation or standards when developing these requirements.

Measurement Canada Decision:

• Recommendations accepted.

Considerations, Conditions and/or Limitations:

• None

Physical Standards

Recommendation #15
Measurement Canada is to establish and implement regulations for all trade measurement standards and test equipment used for the initial inspection and re-verification of water meters in Canada.

Recommendation #16
Measurement Canada is to certify physical standards and test equipment. Other organizations should also be allowed to certify standards provided they meet the established requirements and are authorized by Measurement Canada.

Recommendation #17
Measurement Canada is to continue to pursue the recognition of other international standards laboratories.

Recommendation #18
Physical standards and test equipment used to test or certify water measuring devices will be subject to mandatory calibration intervals.

Recommendation #19
Measurement Canada is to form a joint working group to establish the rules and requirements for all trade measurement standards and test equipment used for the initial inspection and re-verification of water meters in Canada. The joint working group will include representation from all applicable stakeholders.

Measurement Canada Decision:

• Recommendations accepted.

Considerations, Conditions and/or Limitations:

• None

Complaints and Disputes

Recommendation #20
Prior to involving Measurement Canada, all efforts should be made by the water utility to try and resolve customer complaints and disputes regarding water meters. Before Measurement Canada becomes involved in the complaint or dispute process, Measurement Canada will request that the water utilities and their customer try to resolve the water meter complaint or dispute. Measurement Canada will act as the 3rd party final arbiter for complaints and disputes regarding water meters which have not been resolved by the water utilities.

Recommendation #21
Measurement Canada is to establish a formal process to investigate consumer complaints and disputes regarding water meters.

Recommendation #22
Measurement Canada is to consult with all applicable stakeholders when establishing the rules and requirements for a formal process to investigate consumers complaint and disputes.

Measurement Canada Decision:

• Recommendation 20 accepted.
• Decision on recommendations 21 and 22 is deferred.

Considerations, Conditions and/or Limitations:

• Measurement Canada will investigate complaints. The extent of the formal investigation process and whether this process will be based on the Electricity and Gas Inspection Act (disputes) or the Weights and Measures Act (complaints) model will be decided in 2005. This decision will be made after Measurement Canada has decided on the best legislative framework to regulate water meters.

Marketplace Monitoring

Recommendation #23
A marketplace monitoring process for the water trade sector should be determined during the implementation stage of the Water Trade Sector Review. Input from all applicable stakeholder groups should be obtained.

Recommendation #24
Measurement Canada is to consult with all applicable stakeholders groups when establishing the processes for the marketplace monitoring of the water trade sector.

Measurement Canada Decision:

• Recommendations accepted.

Considerations, Conditions and/or Limitations:

• None

Sub-metering

Recommendation #25
Measurement Canada’s level of intervention in this sub-sector should be determined in consultation with stakeholders during the water trade sector review implementation.

Measurement Canada Decision:

• Recommendation accepted.

Considerations, Conditions and/or Limitations:

• None

Wastewater (Sewer)

Recommendation #26
Measurement Canada’s level of intervention in this sub-sector should be determined in consultation with stakeholders during the water trade sector review implementation.

Measurement Canada Decision:

• Recommendation accepted.

Considerations, Conditions and/or Limitations:

• None

Bulk Water Sales - Bulk Water Outlets

Recommendation #27
Measurement Canada will not require the approval, initial inspection and periodic inspection of measuring devices that are used in trade transactions of water sales at bulk water outlets in Canada.

Recommendation #28
Measurement Canada will investigate complaints of bulk water outlets if the transaction is based on the quantity of bulk water sold.

Recommendation #29
Measurement Canada will develop and implement limits of error (tolerances) that can be used to determine whether the sales of a stated quantity of bulk water is acceptable. The limits of error will be based on stakeholder input, recognized international and industry standards, and the relative cost of the water being sold. These limits of error would be applied to the sales of bulk water by any form of trade measurement.

Measurement Canada Decision:

• Recommendations accepted.

Considerations, Conditions and/or Limitations:

• None

Bulk Water Sales - Bulk Water Delivery

Recommendation #30
Measurement Canada will not require the approval, initial inspection and periodic inspection of measuring devices that are used in trade transactions of water sales by tanker truck in Canada.

Recommendation #31
Measurement Canada will investigate complaints received if the fee/charges are based on the quantity of bulk water sold/delivered by tanker truck.

Recommendation #32
Measurement Canada will develop and implement limits of error (tolerances) that can be used to determine whether the delivery/sales of a stated quantity of bulk water is acceptable. The limits of error will be based on stakeholder input, recognized international and industry standards, and the relative cost of the water being sold/delivered. These limits of error would be applied to the sales/delivery of bulk water by any form of trade measurement.

Measurement Canada Decision:

• Recommendations accepted.

Considerations, Conditions and/or Limitations:

• None

Wastewater Removal and Hauling

Recommendation #33
Measurement Canada will not require the approval, initial inspection and periodic inspection of measuring devices that are used in trade transactions of wastewater removal and hauling in Canada.

Recommendation #34
Measurement Canada will investigate complaints received if the fee/charges are based on the quantity of wastewater removed/hauled by the wastewater hauler.

Recommendation #35
Measurement Canada will develop and implement limits of error (tolerances) that can be used to determine whether the removal/hauling of a stated quantity of wastewater is acceptable. The limits of error will be based on stakeholder input, recognized international and industry standards, and the relative cost of the waster being removed/hauled . These limits of error would be applied to the removal/hauling of wastewater water by any form of trade measurement.

Measurement Canada Decision:

• Recommendations accepted.

Considerations, Conditions and/or Limitations:

• None

Wastewater Disposal

Recommendation #36
Measurement Canada will not require the approval, initial inspection and periodic inspection of measuring devices that are used in trade transactions of wastewater disposal in Canada. This would only apply to measuring devices that are used exclusively to determine wastewater disposal charges.

Recommendation #37
Measurement Canada will investigate complaints received if the fee/charges are based on the quantity of wastewater disposed of at a wastewater disposal facility.

Recommendation #38
Measurement Canada will develop and implement limits of error (tolerances) that can be used to determine whether the disposal of a stated quantity of wastewater is acceptable. The limits of error will be based on stakeholder input, recognized international and industry standards, and the relative cost of the wastewater being disposal. These limits of error would be applied to the disposal of wastewater by any form of trade measurement.

Measurement Canada Decision:

• Recommendations accepted.

Considerations, Conditions and/or Limitations:

• None