WATER EFFICIENCY LABELLING AND STANDARDS (WELS) SCHEME – Consultation paper
Thornthwaite Technologies Pty Ltd (Submission 2)
Please give us your feedback on:

Is the definition of a model as 'what is in the database now as a
model' workable for you?
At this stage for the purposes of re-registering for the first year of the new WELS
registration system we agree to the use of the definition of a model as those
models that are currently on the WELS data base for Presto and Rada. Our
acceptance is on the basis of the use of the tiered registration fee option.
However our preferred definition of a tap model is as follows:
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Taps that shall be considered to be the same model if they have the same
style or shape including the same WELS star rating and be identifiable by
having a specific model name or number.
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Variations such as different external finish / colour; hot or cold or warm
colour indicators; or minor variations in the mode of operation shall be
disregarded and not be used as a reason to have to make it necessary to
create a new model. Such variations may well have there own individual
part number but such additional numbers shall not be regarded as another
model.
All our models have a unique name. All our model variants have a unique code.
For example;
1) Model unique name: Presto 605
Presto 605 model variants
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P64608 Presto 605 cold (it has a blue indicator)
P64626 Presto 605 warm (it has a yellow pip or indicator)
P64604 Presto 605 S cold (it has a blue indicator) – push button
must be released for flow
P64614 Presto 605 S warm (it has a yellow indicator) – push button
must be released for flow
P64654 Presto 705 – This has a lever instead of a push button
however the body is the same as the model 605.
2) Model unique name: Rada “Pulse” System
Rada Pulse sensor system model variants (a selection)
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650631 Rada Pulse 120 sensor for flow to a basin
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650681 Rada Pulse 129 sensor for flow to a basin
650651 Rada Pulse 124 sensor for flow to a basin
Note: All variants use exactly the same solenoid valve regardless of the
activation sensor configuration.
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Do you accept the proposal that further clarity regarding the
definition of a model be tasked to the Standards Australia
committee WS-032 during the first year of the new arrangements?
Yes, plus public and industry input and feedback.

Do you support a tiered registration fee, where an annual
registration fee is charged and linked only to the number of
models registered?
Yes. One of the benefits is that it gets rid of the artificial method of
grouping products (e.g. limiting to 15) in some other options.
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If you support such a fee arrangement, do you support pro-rata
crediting of existing fees, and the consequent higher fees that
result?
We accept the fee arrangement of the pro-rata crediting of existing fees
and the acceptance that initially the new fees will have to increase.
Will the increase be over one year or three years? We assume that the
fees will then be reduced back to the non fee credit level plus any annual
inflation increase in the future.
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