[ca-gw] Letter to DHCD

[Steve Bilson]

Dear Mr. Rowland -

As you've read, SB1258 says that "(c) In adopting building standards under
this section, the
department shall do all of the following:
   (1) Convene and consult a stakeholder's group that includes
members with expertise in public health, water quality, geology or
soils, residential plumbing, home building, and environmental
stewardship.
   (2) Ensure protection of water quality in accordance with
applicable provisions of state and federal water quality law.
   (3) Consider existing research available on the environmental
consequences to soil and groundwater of short-term and long-term
graywater use for irrigation purposes, including, but not limited to,
research sponsored by the Water Environment Research Foundation.
   (4) Consider graywater use impacts on human health.
   (5) Consider the circumstances under which the use of in-home
graywater treatment systems is recommended.
   (6) Consider the use and regulation of graywater in other
jurisdictions within the United States and in other nations."

To help satisfy all those law sections, I trust you will consult with Dr.
Charles Gerba at the University of Arizona (520) 621-6906, who is an
internationally recognized specialist in wastewater microbiology and who
wrote the scientific analyses of the Water Conservation Alliance of Southern
Arizona's (CASA) greywater study that resulted in Arizona allowing greywater
on the surface as long as the system didn't pool or run-off and which
eliminated permits for single-family greywater systems.  

Dr. Gerba can confirm what everybody but a small band of environmental
health zealots here knows, that greywater is not nearly the health risk that
California's existing code considers it to be, much less the code that DHCD
has proposed to date.  His highly educated insights on the real risks
associated with a code that virtually nobody follows, as is presently the
case with California's existing greywater irrigation code, are enlightening.
I trust you will include Dr. Gerba in all future SB1258 proceedings.

You should probably also consult with Val Little, CASA's Director, as she
was the driving force behind Arizona's legislation that resulted in
Arizona's greywater code.  She can be reached at (520) 626-2678 and
vlittle at u.arizona.edu.

Arizona's Department of Environmental Quality wrote that state's greywater
irrigation code.  The point person for that legal process was and still is
Michele Robertson.  She can be reached at mir at azdeq.gov.

Thank you.

Stephen Wm. Bilson
ReWater Systems, Inc.
Cell (619) 322-0141

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