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Mitchell, Phillip
From: COLE Tom [[email protected]]Sent: Friday, 24 December 2010 12:01 PMTo: Utility MeteringCc: TURNER David; CHAN Peter; SHEPPARD DavidSubject: Consultation Electricity Meters - Metering Dynamics
Page 1 of 2Consultation Electricity Meters - Metering Dynamics
27/01/2011
Legal Metrology Policy National Measurement Institute PO Box 264 Lindfield NSW 2070 Attention: Electricity Metering
Dear Sir/Madam,
In response to your "Consultation Paper on the lifting the exemption for electricity meters under the National Measurement Act" Metering Dynamics Pty Ltd would like to provide the following feedback as requested.
Question 1: Comments on this proposal are invited, in particular:
(a) What impacts, positive or negative, would there be for you if the exemption was lifted?
Provided the grandfathering arrangements as proposed are implemented, there should be little impact on operations as pattern approval is already being included as a requirement in new meter purchase specifications. There would be a need to review the ENERGEX meter contract requirements to ensure that the aspects of initial verification have been adequately covered.
Suppliers of meters will pass on their costs of gaining and maintaining their verification authority accreditation, and pattern approval costs, to customers through increased meter prices. It is not expected that this will be a major increase given that many suppliers are already doing this.
(b) What financial impacts would there be for you if the exemption was lifted?
To cover the cases where initial verification has not been carried out by suppliers, ENERGEX proposes to have its NATA accredited Meter Laboratory accredited as a verifying authority for electricity meters.
Question 2: Comments on the options are invited, in particular:
(a) What issues and costs would these proposed options present for you?
It is understood that the main objective of the lifting of exemptions for electricity meters is to provide protection to domestic customers who do not have the knowledge, capability or capacity to influence the choice and accuracy of the meters used in their installations and not per se to maximise the number of meters in the market covered by the National Measurements Act. The lifting of exemptions could more logically be applied to meters used in domestic premises rather than based on any particular level of annual consumption. In this regard, even option 1 covers far more meters than is necessary for customer protection.
One could debate whether the lifting of exemptions adds any additional confidence to installation metering accuracy above that which is already provided under the National Electricity Rules.
Other Comments
1. Where period contracts for the purchase of meters are in place where the requirement for pattern approval has not been included as a requirement and where there may be a number of years yet to run on that contract, the grandfathering arrangements would need to cover up to the expiry period of those contracts not just to date of the lifting of the exemptions.
2. With advances in technology, there are times when manufacturers may work in conjunction with electricity network operators to trial new types of meters, or new meter functionality, prior to the finalisation of meter design and the commitment to the not insignificant cost of formal pattern approval. Some allowance should be made for exemptions to be obtained for a limited number of meters for trial purposes provided of course the accuracy requirements of the meters are satisfied.
If you require any further information or clarification please do not hesitate to call me on the numbers below.
Regards Tom Cole Manager Metering Compliance and Projects Metering Dynamics Tel: 07 3407 5906 Mobile: 0405 768 421 Fax: 07 3407 5454 Email: [email protected] Web: www.meteringdynamics.com.au Metering Dynamics is a business name of ENERGEX Limited
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27/01/2011
