[ca-gw] [SPAM] Re: Letters to DHCD

Fri Mar 27 15:24:07 PDT 2009

The existing state greywater irrigation law and code includes multi-family
and CII systems.  The triennial adoption process does not mandate that an
agency throw out all existing state revisions to a model code just to adopt
the new model code.  

On the contrary, H&S code sections require the agency to consider those
existing state revisions right along with the new model code.  One of those
same H&S code sections is cited in DHCD's announcement of their revision
process.

DHCD states they plan to  "Repeal amendments to the model code that are no
longer necessary, repeal or amend building standards that are not addressed
by a model code", and "Relocate or codify existing adopted and necessary
amendments to the model code into the format of the model code proposed for
adoption, the action of which has no regulatory effect; adopt new necessary
amendments to the model code proposed for adoption; and/or", "Adopt new
building standards that are not addressed by the model code proposed for
adoption."  But for some bizarre reason, people are giving DHCD a free pass
on this critical aspect of their current code writing process.

This revision process is supposed to include ALL  the issues involved with
1) adopting a model code, and 2) implementing SB1258, not just adopt the
model code with the least amount of work involved.

Can you imagine what a mess California's building industry would be in if
every 3 years we all had to start over from the archaic model code again?!
That is what is happening as long as we don't demand they include MFD and
CII systems in this revision process.  Collectively, many of us spent
thousands of hours on the MFD CII issue per AB313 in 1995-1997.

Make DHCD do what they're supposed to do!

From: Sonia Diermayer [mailto:sodier at mindspring.com] 
Sent: Friday, March 27, 2009 1:58 PM
To: Steve Bilson
Cc: 'Jon Bauer'; ca-standard at graywater.org
Subject: Re: [ca-gw] [SPAM] Re: Letters to DHCD

It looks to me as if the current rewrite will only apply to residential--not
CII. That is the current scope of DHCD's authority, and that wasn't
fundamentally altered by the legislation:

http://info.sen.ca.gov/pub/07-08/bill/sen/sb_1251-1300/sb_1258_bill_20080529
_amended_asm_v94.pdf

Existing law requires the Department of Housing and Community 

Development to propose the adoption, amendment, or repeal of building 

standards to the commission relating to hotels, motels, lodging houses, 

apartment houses, and dwellings, and the buildings and structures 

accessory thereto, except as specified. 

Sonia

On Mar 27, 2009, at 9:20 AM, Steve Bilson wrote:

Regarding multi-family and CII systems, all the same problems exist in the
existing and proposed state codes as for single-family systems.  I've
addressed all of those problems in my long, detailed comment letter to DHCD
prior to the February 25th hearing.

The bottom line is, as long as our greywater irrigation code is written to
look like a sewage disposal code, inspectors will deliberately or
inadvertently treat greywater irrigation like sewage disposal and virtually
nobody will pay that kind of money to try to reuse their water.  The code
needs to be radically changed on its face as well as in substance.

There are hundreds of thousands of "illegal" greywater systems installed due
to this one fact..

From: ca-standard-bounces at graywater.org
[mailto:ca-standard-bounces at graywater.org] On Behalf Of Jon Bauer
Sent: Friday, March 27, 2009 8:39 AM
Cc: ca-standard at graywater.org
Subject: [SPAM] Re: [ca-gw] Letters to DHCD

The East Bay Municipal Utility District has submitted a three page letter to
DHCD dealing with residential outdoor use of greywater, proposing specific
code changes.  Im sorry I dont have a copy here today but will forward it to
the list when I get back to this office next week.  It was also circulated
to water conservation departments around the Bay Area.
-Jon Bauer

Also attached is POWER's first letter to the department, addressing the
narrow topic of allowable indoor gray water technologies. Please, if anyone
is aware of additional technologies, forward that info to me. thanks
POWER will be developing additional letters, one advocating residential
categorical exemption a la Arizona but replacing the gpd threshold with the
residential category as a whole; I've spoken with William Bennett at EBMUD
and this is their agency's strong preference as well. The third letter will
address larger CII (commercial, industrial, institutional) systems; I'd like
any information or help with this. 
thanks
be well

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