[ca-gw] [Ca-standard] state wide registration system idea

Thu Oct 15 12:33:06 PDT 2009

Unfortunately, those are very accurate observations.  You're no cynic.

Fighting this battle on the current battle field is the only option we have
right now.

From: ca-standard-bounces at graywater.org
[mailto:ca-standard-bounces at graywater.org] On Behalf Of Bruce Broderick
Sent: Thursday, October 15, 2009 12:15 PM
To: Oasis Design <
Cc: ca-standard at graywater.org
Subject: Re: [ca-gw] [Ca-standard] state wide registration system idea

Not wanting to be a cynic, I have to bring up the "Politics of Water". The
reaction of officials and/or private water districts with the prospect of
losing revenue as a result of people reusing their water after it has been
metered is a scary prospect to many districts and municipalities. I was
naive enough to think that this wasn't so until one evening when I was
giving a presentation to a fairly large water district about the merits of
Graywater for residential use. One of the board members brought up the
downside of residential use to them was that revenue would decline because
of reuse and also if it got widespread it would have an adverse effect on
their own  Graywater recycling infrastructure that they charge rates for.
Water is big business. It would be foolish for anyone to assume that water
lobbyists are not already involved deeply in this battle. Locally, I became
aware of this after giving several presentations to our City Council with
regards to Graywater and water conservation in general. It turns out that it
is one of their last untouched CASH COWS. Many cities have countered
conservation by raising base rates to offset any perceived savings and
thereby keep their revenues from being adversely effected. Others, such as
here in my community, charge by the number of individuals in the household
instead of using the new "two year old" meter system that was installed to
upgrade the system. S.F. certainly won't be the last city that will attempt
to hobble this new code. And, I am not saying that this is the reason for
this choice of action by S.F. officials. It just deserves a good look.

_____________________________________________
Bruce Broderick
Being Water L.L.C.
CEO, Product Development
P.O. Box 717 Fort Bragg, Ca. 95437
707 964 7856
 <http://www.marketerschoice.com/app/?af=1029459> www.beingwater.com
_____________________________________________

On Thu, Oct 15, 2009 at 10:59 AM, Oasis Design <oasis at oasisdesign.net>
wrote:

The problem with a "registration" process is that it's totally unique.
They'd have to create a new bureaucracy to implement it (receiving folks,
training, forms, computer input, IT support, etc.).  That'd cost a fortune,
and no city has extra money.  The closest thing they have right now is the
permit process.  So, by asking for a tracking feature, you're really asking
for a permit imposition, and there we are again, right back to where we

started 20 years ago.

This notification/ registration idea is an interesting one. My thoughts on
it, which have evolved considerably, follow below (and at
http://www.oasisdesign.net/greywater/law/california/currentcode/#notificatio
n )

I'd be interested to hear the thoughts of others. Steve's point is one I
hadn't thought of; it is true that registration advocates have been speaking
as if there are resources lying around to create this new thing, when there
aren't even resources to do the old thing (the last county I did design work
in supposedly just layed off 61 inspectors).

My current idea, which follows, would require minimal additional resources,
by triggering greywater inspection/ registration only when inspectors were
on the property anyway...

(I am about to go into internet shadow for the next week...I look forward to
finding the perfect resolution of all these battles in my in box on my
return!)

Art

~~~~~~~~~~~~~~~~

Notification/ Registration of Greywater Systems

Notification/ registration of greywater systems (or a certificate of
negative declaration) have been proposed as a possible compromise between
permitting and not permitting. The current standard allows this option:

If required, notification has been provided to the Enforcing Agency
regarding the proposed location and installation of a graywater irrigation
or disposal system.

At first I was excited about this, but then I realized that this would
probably be less satisfactory than either of the other scenarios.

I assume that these are the goals of registration:

   1. Better systems
   2. Better understanding of what is happening in the district
   3. Greater control
   4. Increasing knowledge base concerning what types of systems, uses,
waste streams, application rates, treatment devices are most effective for
managing graywater reuse.
   5. Encouraging communication between graywater system users and the
public sector
   6. Establishment of a user database so new developments in graywater
reuse can be made available to those who have participated in the
notification process

Registration is likely to have the opposite of the desired effect for every
one of these goals. Here's why:

   1. The chilling effect of a registration requirement on professional
installations is probably worse than requiring a permit. Homeowners would
perceive it as an open invitation to inspect the site at any time in the
future. The likely result is that installations will be done by unskilled
homeowners without benefit of professional assistance in order to avoid
registration. In many areas, the reduction in numbers of professional
installations may cross the threshold of viability of greywater
installations as a business (it is a low margin business to begin with),
with the result that even those that would be happy to have their systems
done professionally and registered won't have the option of professional
help. The result: worse systems than would be achieved under the "standards
but no permits" scenario (which eliminates all barriers to installation by
licensed professionals).
   2. With the vast majority of the greywater systems driven underground,
the sample will be of little statistical or other value. Ditto for the rest
of the points...with 9999 out of 10,000 installations unregistered, little
benefit will be gained.

If your jurisdiction is interested in registration, here's an approach that,
while it aims a bit lower, I think will actually hit the targets: (I've
written it here in the form of suggested language for the state standard, it
certainly would be allowed under the current language quoted above)

If required, the Enforcing Agency may inspect clothes washer and/or single
fixture systems concurrent with an inspection on the property for another
purpose, or an enforcement action for another purpose, or in response to a
complaint.

Here's the details:

   1. When permitted new construction or remodeling includes a greywater
system, the greywater system must be registered to add to the county's
experimental best practices database. The trigger could be set anywhere
desired, from any permit at all-re-roof your house, gw system get's
registered-to highly selective-new construction, for sure, and maybe major
replumbing.
   2. Greywater systems could be voluntarily registered
   3. When there is a complaint, the greywater system would be registered,
and this form of registration unlike the others, would constitute
justification for follow up visits.

So...I think this gives the best of both worlds:

   1. whenever an inspector is already at a site, the county would get
another entry in their database. Peoples bubble of privacy is already
penetrated at this point, so it wouldn't seem so calamitous. The sample
could include all new construction and remodeling, adding sizable, non-self
selected chunk of data to the system that had just one independent variable
(a permit for something else) rather than the highly biased sample you'd get
from people who for some reason came forward for with mandatory
registration.
   2. Voluntary registration would presumably get a few exemplary systems
out of the woodwork and into the database, perhaps systems installed by
professionals looking to add credibility to their work.
   3. Complaint based-registration would get samples from the opposite
end--lousy, problematic systems-into the database, and would provide an
incentive to people to keep their greywater noses clean, and a mechanism for
tracking, monitoring, and actively abating that small percentage of systems
that doubtless contribute disproportionately to lowering the average
performance.

If your jurisdiction is interested in going this route, please E mail us;
I'd be interested in helping develop optimal language.

Art Ludwig

-- 

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