Melbourne Water - Essential Services Commission

16 June 2011
Mr Chris Hutchins
Project Manager- Trade Waste
Water Division
Essential Services Commission
Level 2 35 Spring Street
MELBOURNE VIC 3000
Dear Chris
Re: Draft Trade Waste Customer Service Code
Thankyou for the opportunity to provide a submission to the Essential Services
Commission on the Draft Trade Waste Customer Service Code.
Melbourne Water has considered the draft code and in general the code is consistent
with the processes and approach that are being developed between Melbourne Water
and the Retail Water companies. It should be noted however, that the draft code would
not directly apply to Melbourne Water, other than through the referral of applications,
as well as the development and publication of acceptance criteria in combination with
the Retail Water Companies. Therefore it is suggested that the code should be modified
to specifically describe MWC’s role, and the applicability of the code to MWC. Further
detail related this point and other general comments on the code are provided in the
Attachment.
If you have any questions concerning any of the comments, please do not hesitate to
contact me on 9235 2142 or email lidia.harvey@melbournewater.com.au.
Yours sincerely
LIDIA HARVEY
TEAM LEADER, SEWAGE QUALITY MANAGEMENT
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Attachment 1
Melbourne Water (MWC) comments on the Trade Waste Customer Service
Code (Draft)
1. The Draft Trade Waste Customer Service Code, Draft Decision document, May 2011
is a useful supporting document to the customer service code. It is unclear if this
document will continue to be a supporting document to the code, as an appendix or
reference document. Such a document (modified as required) that could provide
clarity and explanation of the code would be seen as valuable and worth maintaining
as a reference document in addition to the code.
2. MWC is included in the definition of a Water business. This has a number of
implications for MWC particularly given the obligations of a Water business in the
customer service code, most of which do not apply to MWC. There may be an
opportunity based on the comment 1 above to provide clarity around which clauses
apply to MWC. However, if there is no guiding document for the customer service
code, then a more specific description of MWC will be required in the code and the
exclusion of clauses related to MWC. Some of the comments that follow relate to the
ambiguity of role of MWC and application of code given MWC does not have any
direct Trade waste customers.
3. Section 1 does not apply to MWC as we do not have any direct Trade Waste
customers however there may be a need for the Metropolitan Water businesses to
refer an application to MWC for consideration. This should be made clear in either
the code or the guiding document. An additional clause such as clause 6.2 (c)
would be a useful addition in for the clarification of MWC’s role in being consulted
and involved in the process for assessing the risk from trade waste to its system
when required.
4. Section 2 does not apply to MWC as we do not have any direct Trade Waste
customers. This should be made clear in either the code or the guiding document.
5. Section 3 does not apply to MWC as we do not have any direct Trade Waste
customers. This should be made clear in either the code or the guiding document.
Clause 3.2 appears silent on the requirement of the customer to provide a copy of
the Risk Assessment to the Water business, or other Water businesses (Melbourne
Water) impacted by the risk. Making the requirement of the customer to conduct
and supply the findings to the water business explicit will support the metropolitan
water businesses development of the ISQMS 1 and in particular Protocol 2- Site
Specific Risk Assessments.
6. Section 4 does not apply to MWC as we do not have any direct Trade Waste
customers. This should be made clear in either the code or the guiding document.
7. Section 5 does not apply to MWC as we do not have any direct Trade Waste
customers. This should be made clear in either the code or the guiding document.
MWC has Bulk Sewerage Usage Charges- Load, major Trade waste (per tonne)
1 ISQMS- Integrated Sewage Quality Management System independently certified to
ISO 22000.
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however this is passed on to the Retail water businesses and which in turn may be
passed on to the Trade Waste customer at the RWC’s discretion.
8. Clause 6.1 requires each Water business to maintain a current statement of
approved acceptance criteria and be readily available on its website. Based on the
definition of Water business, it is also a requirement of Melbourne Water to do this.
MWC does not have any direct Trade waste customers therefore this clause would
not be applicable to MWC. This should be made clear in either the code or the
guiding document.
9. The National Wastewater Source Management Guideline published by the Water
Services Association of Australia, referred in clause 6.2 (b) is currently being
reviewed, and will be renamed to the Australian Wastewater Quality Management
Guidelines later this year.
10. Clause 6.2 (c) relates directly to MWC and is consistent with the process being
developed in the ISQMS by the metropolitan Water businesses.
11. MWC will be involved in the process for establishing, replacing or amending
approved acceptance criteria as described in clause 6.3 however given MWC does
not have any direct Trade waste customers therefore this clause does not directly
apply to MWC. This should be made clear in the either the code or the guiding
document.
12. The acceptance criteria is currently located in the Statement of Obligations and
approved by the Minister for Water. It is unclear if the commission is approving the
acceptance criteria on behalf of the Minister, or where the ‘official acceptance
criteria master list’ will be stored. This list should be available to any water business
or customer upon request.
13. A technical understanding by the commission to assist in considering an application
under clause 6.3 would be a highly desirable outcome.
14. Clause 6.5 (e) appears ambiguous- does this mean maintaining a register of all
applications, including those rejected?
15. Clause 6.5 (g) (ii) seems to repeat ‘name of customer’ which is already in Clause
6.5 (g) (i).
16. Clause 7.1 (b) refers to clause 3.1 (d). No such clause exists. Additionally, the
mention of clause 3 in this section seems unrelated to the dispute resolution clause.
17. Clause 7.1 and 7.2 may relate to MWC particularly when it is a dispute between
MWC and another water business or in conjunction with another water business as
related to any involvement in any other matter with a customer. This section does
not appear to address the issue regarding dispute between two water businesses.
This should be made clear in the code or the guiding document.
18. Clause 7.2 refers to “the customer’s water business”. This is not defined in the
code.
19. Clause 7.2 should require the customer’s water business to advice customer and the
other water business of the other water business’s involvement.
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20. Section 8 should consider not just sewerage treatment but the 5 key objectives 2 in
its business planning processes. Additionally, water businesses should plan for total
sewage loads which include trade waste. MWC will need to consult with the
Metropolitan Water businesses and vice versa to assist with each others business
planning process.
21. Clause 8 (c) should consider alternatives to just accommodating increases in
capacity such as reducing pollutants at the least community cost.
22. Section 9 and 10 do not apply to MWC as we do not have any direct Trade waste
customers. It should be made clear in the code or the guiding document that MWC
is not required to prepare a customer charter for Trade waste.
23. Part E- definitions should reflect Melbourne Water’s role as a referral authority
regarding applications, customer-specific acceptance criteria, and it’s role in working
with RWCs regarding approved acceptance criteria and as per comments above.
2 % key objectives include:
1. Ensure safety of workers in the sewerage system,
2. Protection of assets,
3. Protection of treatment plant (including biogas),
4. Protect receiving environment/facilitate licence compliance
5. Recycling: water and Biosolids (by products)
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