[ca-gw] Support for Existing State Greywater Irrigation Code

[Steve Bilson]

Dear Mr. Panelli:

 

After participating on the California Ad-Hoc Graywater Committee in
1990-1992 co-chaired by the California Department of Water Resources and the
Department of Health Services, in 1992 I sponsored Assembly Bill 3518 to
legalize certain types of single-family greywater irrigation systems.  I
then worked another two years with local and state agencies to get the rules
written, and in 1994 Appendix G of the California Plumbing Code was
published.  That was the first state greywater irrigation code in the
nation.

 

In 1995, I sponsored Assembly Bill 313 to legalize certain types of
commercial, multi-family, and institutional greywater irrigation systems,
and then worked another two years with those state and local agencies
getting the revised code in place.  When that code was published, it was the
first state greywater irrigation code for all types of greywater irrigation
systems in the nation.

 

After 15 years of selling greywater irrigation systems, in 2007, I asked
members of the State Assembly to carry legislation to revise the state
greywater irrigation code once again, this time to more specifically comply
with the well known science on the issues.  A Senator decided to carry the
weight instead, and Senate Bill 1258 was authored.  SB1258 directed the
California Department of Housing and Community Development to examine what
other states have recently done with their codes due to the massive amount
of science available on greywater and to revise our code based on that
science.

 

After a year of researching the science and seeing what other states have
done to their codes due to that science, and after holding numerous public
hearings on the matter, DHCD revised the state greywater code in many places
to more accurately reflect the reality that greywater is actually quite
benign.  One of the findings DHCD made was that because a substantial number
of people are already using their laundry greywater in make-shift systems
that could be better designed from a health and safety perspective, and none
of those people have a permit for their systems, simply giving them and
people like them guidelines to follow would result in better designed and
safer simple systems.

 

DHCD found that when the State of Arizona went to a "guidelines" process for
simple systems there, the number of complaints about unpermitted greywater
systems dropped.  By including that particular no permit for simple system
revision to our code, our state intends to improve the safety of this one
type of greywater system that time has proven no agency can control anyway.
It would be counterproductive for San Francisco to now re-impose the same
old failed enforcement policy that the state recently found is
counterproductive from both a water conservation and a health and safety
perspective.

 

Please reconsider your efforts to restrict the state greywater code by
disallowing simple systems without a permit.  My company does not sell that
type of system, so we have nothing to gain from your decision either way.
However, I know that allowing simple systems without a permit is the right
thing to do, from both a water conservation and a health and safety
perspective.

 

Stephen Wm. Bilson

ReWater Systems

www.rewater.com

cell (619) 322-0141

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