Melbourne Water - Essential Services Commission

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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. 1
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. 3
Page 1: 16 June 2011 Mr Chris Hutchins Proj

Melbourne Water - Essential Services Commission

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