[ca-gw] Art's Consolidation of Stakeholder MeetingChanges Published

Fri May 1 09:59:11 PDT 2009

Bob,
Very helpful input-Thank you for lending your experience and expertise.

Dick Bennett
Water Conservation Administrator
East Bay Municipal Utility District
Ph: 510-287-0597

-----Original Message-----
From: ca-standard-bounces at graywater.org
[mailto:ca-standard-bounces at graywater.org] On Behalf Of Bob Castle
Sent: Friday, May 01, 2009 9:34 AM
To: Sonia Diermayer; Oasis Design
Cc: ca-standard at graywater.org
Subject: Re: [ca-gw] Art's Consolidation of Stakeholder MeetingChanges
Published

Hi Folks,

The CA Dept of Public Health (formerly CA Dept of Health Services) has
certain narrow concerns about the proposed Graywater Code from HCD.
These concerns can be resolved in my opinion.  The big enemy of
graywater (and recycled water too for that matter) is the CA Conference
of Directors of Environmental Health and some local environmental health
authorities.

The DPH is mainly concerned about:  

1)  Calling graywater - even "treated" graywater - as recycled water or
reclaimed water unless it actually meets CA Title 22 requirements.  It
doesn't meet Title 22 and even a large graywater user would have trouble
meeting the requirements:  Daily coliform bacteria testing; turbidity <
2 NTU; treatment to inactivate virus; and other safeguards.  If you call
it recycled water, you are inviting regulation by the DPH which (trust
me please) you don't want.

2)  Flushing toilets with graywater - The DPH requires disinfected
tertiary recycled water for flushing toilets.  This is the highest of 3
classes of recycled water regulated by the DPH.  None of the vendors of
graywater treatment systems have applied to the DPH to demonstrate that
their devices provide an equivalent and reliable water quality as
defined for recycled water in Title 22.  Without the equipment vendors
doing this, the DPH will oppose.  The biggest use of graywater is for
irrigation.  I recommend that you pick your battles and focus on
irrigation.

3)  CA Health and Safety Code designates purple pipe as the color for
recycled water.  Graywater is not recycled water.  Use another color for
marking.  Existing IAPMO code for non-potable water is yellow with black
print.  

Stay away from 1 through 3 above, and the CA DPH should leave you alone.

This advice comes from someone with over 20 years of advocacy with
recycled water and who wants to see graywater succeed in California and
elsewhere.  Best to pick battles you can win.

Regards,

Bob Castle
Water Quality Manager
Marin Municipal Water District

>>> Sonia Diermayer <sodier at mindspring.com> 5/1/2009 12:13 AM >>>
(Will roll up sleeves on Art's Consolidation tomorrow...)

A few issues/points from Monday's meeting--please comment and/or  
correct my interpretations:

1) Jim Rowland said that Arizona has no state graywater code, but  
rather Env. Health "regulations". He also said, based on phone calls  
to several local AZ cities (which adopt IPC or UPC, and do require  
permits), that they really discourage graywater use and don't issue  
many permits.

---Is this accurate? Does this mean we should stop citing AZ as a  
success story?

2) In conversations after the meeting both Jim and Doug independently  
said that the major opposition to DHCD's revision will come from the   
Public Health (CA Dept of Public Health?) and Environmental Health  
people(CA Conference of Directors of Environmental Health?); those  
parties are withholding comment for now, but could totally jettison  
the proposed draft at Building Std's Commission.

---So after we submit our last specific code comments this Monday,  
maybe we should direct our attention (and that of legislators and the  
Gov) to those 800# gorillas on the sidelines who could shoot down the  
DHCD's efforts. Is anyone familiar with those agencies and on whom/ 
how we could apply preemptive pressure there?

Website searches yielded some possibly useful angles/info:

CA Dept of Public Health>>  Division of Drinking Water and Env  
Mgmt>>  Drinking Water Systems>>  Drought Preparedness & Water  
Conservation
http://www.cdph.ca.gov/certlic/drinkingwater/Pages/ 
DroughtPreparedness.aspx  (see "Actions" #7, and "Reports" #4)

CA Conference of Directors of Environmental Health>>  CAEHA  
Legislative Reports>>  2009-04-15 Land Use Report
http://www.ccdeh.com/commttee/land/default.asp 
http://www.ccdeh.com/legislation/2009/2009-04-15/ 
LandUseLeg_Report41509.pdf

3) State Water Resources Control Board is going to be closely  
scrutinizing any provisions for GW on the  ground surface...

---Should we accept the "under 2 inches of mulch" provision and not  
insist on open surface placement of drip emitters to not make too  
easy a target for SWRCB?

4) Commercial, Industrial, Institutional use of graywater are not  
within DHCD's purview.

---So, drop any requests around that.

5) SB 1258 specifically gives local jurisdictions the right to pass  
ordinances prohibiting GW.

---So DHCD can't change that.

On Apr 30, 2009, at 8:51 AM, Oasis Design wrote:

> Dear Stakeholders,
>
> Talked with Jim today; Kim has officially given us until monday to
> submit our comments on the code.
>
> I have attempted to consolidate and resolve all the comments from the
> meeting and letters into one document:
>
> http://www.graywater.org/graywater-policy/new-standard/89-test 
>
> (the link to the doc is at the bottom)
>
> Please edit with track changes on and post or e mail me your comments
> asap and I'll upload revisions.
>
> Art
>
> -- 
> -o-o-o-o-o-o-o-o-o-o-o-o-o-o-o-o-o-o-
> Art Ludwig
> Oasis Design
> Ecological Design publishing & consulting
> Santa Barbara, CA
> Fax: 805 967-3229  Phone: 967-9956
> http://www.oasisdesign.net 
> -o-o-o-o-o-o-o-o-o-o-o-o-o-o-o-o-o-o-
> _______________________________________________
> ca-standard mailing list
> ca-standard at graywater.org 
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>
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