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Regulating the supply of water

From "Bermuda water and wastewater regulatory structure"

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Thank you for the opportunity to submit comments and suggestions for the adoption of Regulations pertaining to the supply of piped water by Watlington Waterworks (“WW”). I submit that the Regulations should comprise (and impose) the following obligations upon WW:- 

1. Obligation to monitor their water distribution system diligently on a daily basis so they know what is being drawn by each of the customers they serve. Belco does this for electricity usage, and there is no reason why Watlington should not be held to that same standard given the importance and cost of this precious commodity.

2. Obligation to calibrate their water meters annually and certify to their customers (each individually) and their regulator that they have been calibrated and are accurate.

3. Obligation to inform their customers of any issues or excess usage, no supply, limited supply or interrupted supply within 24 hours of issue arising.

4. Regulations to be adopted in relation to the maximum acceptable levels of bacteria, chemicals, pesticides, runoff and other solids in potable water. Such regulations should be in line with those required in the United Kingdom and/or European Union.

5. Continuity of Supply and Minimum Service Levels to be set and met on an ongoing basis by WW as the supplier of water to residential and commercial users of the same. 

6. Regulations to be adopted in relation to the amount of “down time” permissible by Watlington Waterworks’ systems before refunds / rebates are owed to consumers. 

7. Regulations to be adopted in relation to the duration of time that public and private roads usage can be disturbed, impeded and / or prevented by Watlington Waterworks digging/pipe laying/paving/leak fixing.

8. Regulations to be adopted on the levels and extent of the compensation to be paid by Watlington Waterworks for disruption of road usage, business interruption due to blocked roads and access ways, etc. and loss of business by affected landowners.

9. Accountability in the form of clearer and more detailed billing processes to be required and employed by Watlington Waterworks, and monthly billing to be provided to customers on a timely basis.

10. Responsibility to be assigned to Watlington Waterworks for monitoring their customers’ usage on a daily basis in order to intervene in the event of faults on the Watlington line and on the customers side of the Watlington Waterworks meter in order to reduce waste due to line and /or meter malfunctions. Belco does this and the same capability is available for water suppliers. 

11. Regulations to be established to require regular calibration of water meters in accordance with manufacturer’s guidelines. For example, if the manufacturer recommends annual calibration, then every meter should be calibrated annually. Failure on the part of Watlington Waterworks to calibrate each water meter annually should result in fines and means that one cannot rely on the meters for accuracy. 

In closing, Watlington Waterworks has been carrying on their business without any accountability for their systems errors and the malfunctions with their equipment. They take the position and presume that their system (although not maintained in accordance with manufacturers guidelines) is operating with 100 percent accuracy, and that any issues arising are the fault of (and are to be paid for by) their customers, with no questions asked. When one attempts to discuss an issue with them, Watlington’s representatives take the position that everything up to their meter is all that they are to be involved with. But yet they also don’t calibrate, monitor and supervise their meters and piping systems in accordance with manufacturers recommendations as to timing and in accordance with other global best practices.

I am suggesting and requesting that the Government establish laws and regulations to regulate and hold Watlington Waterworks accountable in accordance with current best practices for piped water producers and suppliers in the UK and EU with immediate effect.

Thank you for your consideration.

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proposed