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									       WATER EFFICIENCY LABELLING AND STANDARDS (WELS) SCHEME – Consultation paper
                                  Anonymous submission




Appendix C: Questionnaire
The following are extracts of the questions posed in this discussion paper. Please provide your
comments in the spaces provided.

Chapter 4: Changes to the fee structure


      Question 1 (page 7):
      Registrants: What would assist in streamlining registration for your organisation?

□ No Comment
Comment: Improved online system would assist in streamlining the application and renewal of
registrations. The current system allows a registration to be submitted when information is incorrect
or inadequate. A WELS inspector then has to manually review and return applications that are not
complete. This means there is often a large turnaround time, as well as multiple submissions made for
each application to the scheme.

EFT payment to the scheme is not adequate for business. Tracking payments for applications can be
confusing and haphazard. It is hoped that the payment of registrations is simplified in any revised
WELS scheme. The introduction of an online invoicing system from WELS to our account department
would speed up payment terms and remove the level of confusion that exists.



Chapter 4: Proposed changes to registration


      Question 2 (page 14):
      What is your preferred registration option and why? You may like to estimate the impact
      of each of the registration options on your business, taking into account the number of
      models and registrations you are likely to utilise in 2012/13 and the administration costs
      involved.

□ No Comment
Comment: Option 2 is preferred registration option. Currently there is some confusion as to the
definition of a model and we are eager to have this matter settled. The number of registrations that
we would need to create to cover all subcategories makes option 3 unviable and we believe that
customers prefer contacting                    directly rather than accessing product information
online.
      Question 3 (page 14):
      If your preference is for option 3 (product sub-categories), are the proposed sub-
      categories in Table 4.3 on page 12 appropriate? Can you suggest how the sub-categories
      can be made more relevant?

□ No Comment
Comment: Our preferred registration option is option 2




      Question 4 (page 14):
      Do all products that you sell have a unique code? For businesses that do not
      employ a unique code for their products, does this create difficulties? In your
      opinion, what is the most effective way to separately identify individual
      models/variants registered under the WELS scheme?


□ No Comment
Comment: Products are manufactured with a unique code but                        specialise in
customised water control products. We cosmetically modify designs to suit the customer
requirements.

During the WELS forum in Melbourne it was mentioned that any modification (cosmetic or otherwise)
to an existing WELS rated model may not be recognised and that a registration will need to be done for
each possible permutation of design. We feel this goes against the purpose of the WELS scheme and
would make product research harder rather that simpler for a customer. We acknowledge that the
expectation is in the first year of the revised scheme that models will remain as they currently are and
that the Standards Australia committee WS-032 is to provide further clarity on a 'model' to incorporate
into the Standard by the second year of the scheme.




       Question 5 (page 15):
      Is there a need for sets of minor products under the new arrangements?
       Why/why not?

□ No Comment
Comment: We feel that adding the ability to register minor products worthwhile as there are
situations where a limited numbers of model are manufactured which require WELS registration.
     Question 6 (page 15):
     Do you supply sets of minor products? If so, what percentage of your business
     do these products constitute?

 No Comment

Comment:




     Question 7 (page 15):
     Are the criteria for sets of minor products appropriate? If no, please provide
     reasons.
□ No Comment
Comment: Yes.




     Question 8 (page 16):
     Do you have a preference for a particular renewal system - fixed (e.g. annual)
     or flexible (e.g. 1, 2 and 3 years)? Why?


□ No Comment
Comment: Both fixed and flexible renewal systems have their advantages. Fixed registration may
involve further resourcing at                  but would allow us to keep a tighter rein on the
number or models registered to the WELS scheme. This could save money in the long run as models
can be removed within a year of them going obsolete. The option for a flexible renewal system could
be advantageous as resources need not be assigned each year to renew WELS models. If a flexible
renewal system is selected                     would like to see a two- year system implemented.




      Question 9 (page 17):
      For transitioning to the new fee arrangements, do you prefer that registrations
      commence from the date of inception of the new scheme, or an option that staggers
      commencement of new registrations?

□ No Comment
Comment: Understanding that the WELS scheme is run by a small team of personnel we would like to
see a staggered commencement of new registrations to relieve the pressure on WELS staff to keep up
with registration.
Question 10 (page 18):
Which of the two options for treatment of existing fees at the commencement of the new scheme do
you consider the most appropriate and/or administratively straightforward for you? Why?
a) Existing fees are pro-rata credited and the total amount returned is collected through higher fees,
    or
b) Existing fees are not credited to individual registrants, but their retention used to lower fees.



□ No Comment
Comment: We would be happy with option b) and seeing existing fees be used to lower our renewal
fees at the commencement of the revised WELS scheme.




      Question 11 (page 20):
      What is your preference for grandfathering provisions, and why? Should grandfathering
      be indefinite, with the Minister able to specify a date of ‘no further supply’, or should
      there be a specified period of grandfathering after the WELS standard is changed?


□ No Comment
Comment: Grandfathering provisions should be indefinite while current SOH exists. A ‘no further
supply’ clause should apply only once SOH is exhausted and before new items can be manufactured
they must be registered with WELS. Old or obsolete stock should not be allowed to be grandfathered.
                         is not expected to be requiring any models to be ‘grandfathered’.




Question 12 (page 20):
Should flow controllers be removed from the WELS scheme or should
registration of these products become mandatory? Please provide reasons for
your answer.
□ No Comment

Comment: Flow controllers should be added to the scheme to simply the registration process for
models that contain a flow controller. We would be interested to see how this will streamline the
applications of models. Would we still need to attach a WaterMark certificate? We would be
interested in understanding how would the automatic link between models and WELS registered flow
controller would work?
Chapter 5: Proposed changes to compliance and administration of the WELS scheme


Question 13 (page 22):
Is there anything else you would like to see for WELS compliance (e.g. new
penalties or offences and different compliance responses)?

 No Comment

Comment:




Question 14 (page 22):
What do you think of the current level and focus of WELS compliance
activities?
 No Comment

Comment:




Question 15 (page 23):
Do you agree with the requirement that all advertising for WELS products must
have WELS information? If yes, why?
□ No Comment

Comment: Yes. This makes identification of water efficient products easier for the end consumer and
promotes the scheme to the wider community.




 Question 16 (page 23):
Is there another way to monitor the advertising requirement? If yes, how?


 No Comment

Comment:




Question 17 (page 24):
How do you access registration information about products (e.g. through the
Gazette, through the public database or otherwise)?
□ No Comment

Comment: Through the public database.

Question 18 (page 24):
Where would you like to access registration information about products? Why?
□ No Comment

Comment: The public database would be the easiest method and it would provide the most up-to-date
way to access registration information.



Chapter 6: Other proposed changes and further scheme development


      Question 19 (page 25):
      Do you support the ability of WELS inspectors to enter premises without paying a fee if
      there is one?

□ No Comment

Comment: Yes.




      Question 20 (page 25):
      Do you support more extended holding of evidentiary material? Why or why not?

□ No Comment

Comment: Yes. If the seized items allow compliance staff to more quickly work through cases then
allowing them to seize a greater number of items would be beneficial.




      Question 21 (page 26):
      How much detail of alleged breaches do you think should be publicised?

□ No Comment

Comment: The current system of reporting court convictions and breaches to the WELS Act (when
agreed upon) is adequate.
      Question 22 (page 27):
      Do you support follow-up check testing being at the cost of the registrant of the ‘failed’
      product? Why or why not?

□ No Comment

Comment: The registrant is registering a model so they should pay for any follow-up testing if the
results to the first test are adverse.




      Question 23 (page 27):
      Do you have any concerns about any ‘person’ being able to apply for registration of a
      WELS product provided they can supply required test results, WaterMark certification
      etc? If yes, please outline your concerns.

□ No Comment

Comment: A person wising to register a model with WELS should have a valid ABN and business name
to prevent issues regarding stolen intellectual property. We would not want to see our models sold
under a different brand name without our permission.


1.

      Question 24 (page 27):
      Do you think the WELS Regulator should have any specific functions? Why or why not?

 No Comment

Comment:




      Question 25 (page 28):
      Do you have any concerns about information sharing between WELS and other
      government agencies? If yes, please provide details.

 No Comment

Comment:
     Question 26 (page 28):
     Does the definition of ‘supply’ also need to cover any other aspects? If yes, please provide
     details?


 No Comment

Comment:




     Question 27 (page 28):
     Have you experienced any issues with the current definition of ‘supply’? If yes, in what
     instances.


 No Comment

Comment:




     Question 28 (page 29):
     Do you consider that WELS should be more closely aligned with WaterMark and/or the E3
     energy rating scheme? Please provide justifications for your response.


□ No Comment

Comment: We would like to see WaterMark oversee WELS scheme as this would simply and
streamline the registration process and reduce WELS scheme administrative cost.




     Question 29 (page 29):
     Should the scheme be eventually split between plumbing and whitegoods products and if
     so, in what timeframe?


 No Comment

Comment:
    Question 30 (page 29):
    Do you see value in a single ‘sustainability’ label? Why? Who would derive the most
    benefit from such a label?


 No Comment

Comment:




    Question 31 (page 30):
    Please provide any other comments or suggestions that you would like to make about
    improving the WELS scheme.


 No Comment

Comment:

								
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