Submissions due for NSW Metering Regulations

The NSW Government is seeking feedback on additional changes to the draft Water Management Amendment (Metering) Regulation 2019 due Monday, 12 August via the NSW Government Have Your Say portal.

The GVIA has taken this opportunity to again highlight key challenges that our members and water users across the state are having with implementing the NSW Non-Urban Water Metering Regulations.

Implementation concerns:

As explained during the metering roadshow in Moree, most of our members are required to have compliant water meters by the first roll-out date on 1 December 2019 with remaining water users on the 1 December 2020.

With this in mind, our major concern is the ability of our members to meet their obligations by this first roll-out date.  The reasons are two-fold;

• Ongoing drought conditions means that wet-testing of new meters, or flow testing of existing meters cannot be undertaken by our members. 
• Department’s inability to provide additional information to support accuracy testing methodologies and finalise telemetry requirements, which means that not one of our members can have a compliant meter at the time of writing this submission.

However, it is the second issue which is most concerning considering it was clearly articulated during consultation on the regulations that the timeframes were aspirational and that it is actually, government delays that has rendered the policy unimplementable to this point.

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Our recommendations:

Enable individuals to seek ‘Ministerial exemption for a transitional status’ to meet mandatory metering requirements in exceptional circumstances such as no water availability to undertake manadorty testing of equipment. An application can be made following advice from a Duly Qualified Person, who has assessed the site for all requirements other than any required wet-testing procedures and therefore is systematic approach for all impacted water users to provide due evidence of effort and outline a work plan to achieve compliance.

Amend roll-out date for meters requiring government approved data loggers and telemetry to begin from 1 December 2020.  Importantly this approach more time to:

• Test and secure more device options, other than the limited suite being investigated now;
• Address redundancy issues with existing telemetry users;
• Address data accessibility issues including timeliness and format; and
• Enhance data integration opportunities with existing farm management software and government systems, like Water NSW’s Water Accounting system; and
• Assess the cost implications of the single Data Acquisition Service model, which were not previously consulted on.

Extending the telemetry timeline does not detract away from the accuracy of meters or the fact these meters are securing recording data via existing data loggers with tamper evident seals.  Therefore, this minor extension is a practical solution that will deliver and enduring and achievable outcomes.

Make a submission today!

To help demonstrate the challenges of implementation, it would be of assistance if members could individually make submission supporting these recommendations but also providing YOUR specific issues with implementation like water availability, lack of services, ordering delays, larger off-takes with limited options (other than the fact you do not know the telemetry requirements).

NSW GOVERNMENT HAVE YOUR SAY

Other outstanding issues include:

• Guidance on in situ testing of accuracy.
• Alternative approaches for larger than 1200mm pipe diameters whereby there is not an AS4747 pattern approved meter(s).
• Meter supply and options in 600mm-1,200mm diameter categories when there remains limited meter choice. 
• Guidance on suitable documentation to support validation of pre-1 April 2019 installations via examples.
• Clarification on installation requirements for non-pattern approved meters.
• Legal right of a water user to access water allocations with a non-compliant water meter.

For Members, more information on the metering requirements are available on the Member Update page (you must have your login details to access).