Response 608020851

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Introduction

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David George Dawson

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Current regulatory framework

4.1. What should be the role of Australia’s measurement laws in a modern economy?

What should be the role of Australia’s measurement laws in a modern economy?
Our measurement laws should cover all aspects of measurement when the devices are used as Instruments in Trade for sale or purchase or to prosecute individuals for breaking the Law such as speed and traffic light road law infringements.

Measurement laws in other countries

5.1. What should be within the scope of Australia's measurement laws?

What is the appropriate scope of Australia measurement laws?
Our Measurement Laws should cover all States and Territories and override State government Laws currently existing in order to provide uniformity.

5.2. Are there ways in which the current scope of Australia’s measurement laws could be expanded or limited?

Are there ways in which the scope of Australia’s measurement laws should be limited?
I am particularly interested in Red Light cameras as there appears to be serious inconsistencies in appropriate installation layout, andinterpretation of information collected.

Principles-based legislation

6.1. Would you be confident of operating in a principles-based regulatory environment for measurement? Why or why not?

Would you be confident of operating in regulatory environment for measurement that is characterised by principles-based legislation? Why?
Yes, our measurement system must be based on principles.

6.2. Would the need for detailed guidance material limit the value and flexibility of a principles-based approach to measurement laws?

Would an implemented principles-based approach acquire such a quantity of additional guidance and specification that the value of the principle-based approach was neutralised?
No

Measurements used for trade

7.1. Are there benefits from directly regulating an area of measurement as opposed to providing broad principles of good measurement practice without direct intervention?

Are there benefits from directly regulating an area of measurement as opposed to providing broad principles of good measurement practice without direct intervention?
Regulation s required in order to have uniformity of interpretation, particularly across States.

7.2. What regulatory models should Australia’s measurement laws enable (for instance, principles-based, compliance-focused and/or rules-based), and why?

What regulatory models should Australia’s measurement laws enable (for instance, principles-based, compliance-focused and/or rules-based), and why?
We need both to cover interpretation.

Changing nature of trade measurement

7.1.1. What types of measuring instruments should be regulated by Australia’s measurement laws?

What types of measuring instruments should be regulated by Australia’s measurement laws?
All instruments should be regulated where accuracy determines the outcome and should cover all measurement and Cameras should be added to the list.

7.1.2. How should Australia’s measurement laws apply to transactions for goods and services that are based on measurement?

How should Australia’s measurement laws apply to transactions for goods and services that are based on measurement?
Let the States look after that aspect.

7.1.3. What regulatory models should be applied to quality and quantity measurements?

What regulatory models should be applied to quality and quantity measurements?
I don't believe that regulatory models should cover quality issues, that's a marketing issue. NMI should confine itself to quantity measurements only.

Exemptions

7.2.1. How should Australia’s measurement laws specify the types of measuring instruments they apply to? For instance, by exemption or inclusion requirements?

How should Australia’s measurement laws specify the types of measuring instruments they apply to? For instance, by exemption or inclusion requirements?
Services under State Government such as water, electricity, or gas services should not be exempt from NMI control. The States currently use a relaxed criteria when compared to private enterprise. There is no justification for this as the public suffer. Take a water meter for example, once the meter is installed there is no accuracy checking throughout its life unless the property owner/user complains, then only to have to pay for the re-calibration. Likewise accuracy requirements are slack compare to say fuel measurement.

7.2.2. What are your views on the current listed exemptions?

How are the current listed exemptions not appropriate?
See above.

Non-trade measurements

8.1. What future measurement needs or priorities would benefit from a measurement framework?

What future measurement needs or priorities would benefit from a measurement framework?
See my comments on Traffic cameras. I have evidence of faulty equipment at a sight in Melbourne that has collected no less than 30,000 fines over a five year period.

8.2. Should the focus of the Australia’s measurement laws be to regulate measuring instruments or measurement results, or both?

Should the focus of the Australia’s measurement laws be to regulate measuring instruments or measurement results, or both?
Both.

8.3. How should the national measurement framework apply to non-trade measurements and instruments? Should the approach be different for different types and/or categories of measurement?

How should the national measurement framework apply to non-trade measurements and instruments? Should the approach be different for different types and/or categories of measurement?
Not necessarily.

8.4. What are the types of non-trade measurements (and measuring instruments) that would benefit from inclusion within the measurement framework?

What are the types of non-trade measurements (and measuring instruments) that would benefit from inclusion within the measurement framework?
Red light and speed cameras.

8.5. Are there instances in which non-trade measurements (and measuring instruments) requires a nationally consistent approach to measurement?

Are there instances in which non-trade measurements (and measuring instruments) requires a nationally consistent approach to measurement?
Yes, in road law.