Response 808445013

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Introduction

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Name:
Stanislaw (Stan) Brulinski

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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?
They should provide the metrologically valid and acceptable basis for transactions within Australia. Internationally, they should be compatible with reputable overseas measurement systems and provide unquestionable measurements to support trade

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?
All measurements that are used in trade

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?
Utility (gas, water, electricity) measurement must be expanded with a combination of development of testing/pattern approval laboratories and approval of overseas testing by reputable laboratories. The system cannot be too expensive to operate so NMI's fees must be reasonable and not based on commercial rates of return.

Changing nature of trade measurement

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?
They should provide the metrologically and economically achievable and sound rules

Exemptions

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

How are the current listed exemptions not appropriate?
Current exemptions related to utility measurements (gas, water, electricity) are absolutely unacceptable in Australia in 21-st century. In gas industry, millions of transactions of selling and buying gas are based on outdated state regulations which were never reviewed. Additionally, transactions for gas sales/purchases at the pipeline level (high-pressure gas) are based on meters that were never recalibrated after their first installation. Since there is no high-pressure meter testing facility in Australia, operators developed pseudo-verification methods to avoid high costs of recalibrating overseas. NMI should develop a high-pressure facility to facilitate inexpensive verification of gas meters. Heating value/calorific value of gas is currently determined by the use of gas chromatographs. These devices are calibrated using either NIST-traceable reference gases or locally gravimetrically mixed gasses that do not have a full certificate for all components. To account for heavy hydrocarbons, Australians are using a formula developed of Nth Sea gases.

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?
Gas utility measurements affecting almost all Australian households. This should include not only volumetric metering at flowing conditions but also measurements/calculations of pressures, temperature and heating value used to convert gas used to energy.

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?
Results

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?
Too general to answer