[ca-gw] ReWater's comments on DHCD's 5/15/09 draft

[Jon Bauer]

Hey everyone,
 
I also am very pleased with many of the outcomes and DHCD staffs' efforts, though it is a shame at how many good ideas have not been incorporated and probably wont be at this point.  Unfortunatly, Draft #3 is not that well written yet, e.g.:

*why can't they just remove 100% of all references to Authority Having Jurisdiction, since that is their obvious intent?  (I believe the second definition of Treated Graywater is the one they intended to purge and just forgot, thus leaving in the one reference to the AHJ).

*What's with this definition "simple systems are when..."? etc).  

*Does anyone else think the following sentence is circular?: A written construction permit shall be obtained from the enforcing agency prior to the erection, construction, reconstruction, installation, relocation or alteration of any graywater system that requires a permit.
 
I want to wholeheartedly agree with Steve Bilson on the problem with the language in System Requirements for a Complex System.  The ONLY functional difference in this Draft #3 that I can see between a simple and complex system is who designs it, and leaving it up to an inspector or the EA to decide if the designer is adequate is potentially arbitrary and leavs an opening for discrimination and lawsuits.  However, once that is taken out, there would be no distinction between these two types of systems that I can see: both need a permit, both can be exempted from a permit by an ordinance, both are not clotheswasher/single fixture systems, etc.  The only reason I see to even have this distinction in the code is that it would make it easier for local activists to lobby their EA to get an exemption to permits for somethign called a simple system if there is something called a complex system on the books.  In my opinion, other than that, they've created four types of graywater systems where only two are needed (possilbility of contaminating the public water supply / no possibility of contaminating the public water supply).  What do others think of this reading of Draft 3?  Did I miss something?

 

Maybe we need in the code definitions for "simple code" and "complex code" and standards for the writing of each.

 

jb

 


 

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