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Policy examples |
This packet contains all the information in the greywater policy center in PDF format. It was a very popular item in the Vote for new books & articles, but when we generated it, it seemed useless to us without live links. Please Contact us and let us know if it is useless to you, too, or if it is so much nicer to read in hard copy that you prefer it to reading the greywater policy center online: Greywater policy packet (pdf, 4.3MB).
My advice to regulators is simple: Copy Arizona. Don't copy California, the Uniform Plumbing Code, or anyone else. The Arizona law could use a tune up, the other laws need overhaul or scrapping. New Mexico has copied Arizona, and Texas is considering it.
Oasis Design can consult with your organization on all aspects of greywater policy, including public input, test installations, and the editing or writing of the codes and internal/public information materials themselves. We have helped the states of New York, New Mexico, and the cities of Santa Barbara, California and Cottonwood, Arizona and Melbourne, Australia in this way. Please E mail us if you are interested.
We've uploaded an editable model greywater ordinance, ready for adoption. E mail us if you want to add something to this document (do it in track changes, then use our contact form to get our real address so you can send us the attachment).
Model Greywater Ordinance (doc)
—Or—Why soil perk is so much less critical for greywater systems than septic systems
(and why requiring professional percolation tests for greywater systems and outsized leaching area requirements are a waste of resources)
Table 16-2 and table G2/ (CPC and UPC greywater irrigation areas, respectively) are both simple port overs of UPC table K2, the uniform plumbing code standard for leachfield area. The loading rates are exactly the same. No thought or research has gone into distinguishing greywater and clarified septic tank acceptance rates in these laws, that I know of.
But, (shallow) greywater system LTAR is drastically different than (deep) septic leachfield LTAR:
On the other hand,
Greywater mulch basins can sustain over 100 times the loading rate of adjoining leachfields under ideal conditions (in one instance I calculated that the greywater mulch basins legally required for a two shower bath house on an organic farm with exceptionally good soil tilth could safely process the combined sewage from half the neighborhood of surrounding tract houses for 24 hours, should the sewer system fail—something a lot more likely than greywater surfacing from that system).
However, ideal conditions do not always prevail. Overall, I believe that a reasonable, highly conservative standard for shallow (6-9") greywater-fed dispersal would be a loading rate twice that for deep septic leachfields.
In reality, I estimate that the LTAR for greywater applied shallow is on the order of twice that of a 24” deep septic leachfield on a given site with low percolation soil, and four times the LTAR on well-percolating soils. I'm sure these figures would double again for application under mulch as compared to soil (another reason to allow mulch to substitute for soil to shield people from contact with greywater).
Given this, and the much less drastic consequences of overloading a greywater system as compared to a septic system, it is hard to justify the economic and ecological costs of an "official" percolation test, requiring a backhoe, auguring equipment, truck, pipe, & gravel, when a homeowner can get all the information needed in an hour, with a shovel, hose, ruler, and a watch.
This is the model to emulate, especially our slightly improved version: Greywater Laws and Improvements (pdf, 250k). Their three tiered system makes so much sense it is hard to justify regulating grey water any other way.
With this one stroke, Arizona has raised their compliance rate from near zero to perhaps 50%.
And, homeowners are more likely to work towards compliance for the informal systems that still fall short.
What's more, the door is now open for professionals to install simple systems.
They require a standard permit.
In Arizona, regulators apply oversight to grey water systems in rational proportion to their possible impacts.
Instead, regulators require that systems meet performance goals. They don't care how the system is built. They just want it to function well. This is the preferred approach. It creates a favorable climate for innovation. Technical progress is not likely to quickly outdate the law.
The final idea I suggest you copy:
The booklet can be more easily updated than the law.
For more see links above.
Here's the law for tier one systems:
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R18-9-711. Type 1 Reclaimed Water General Permit for Gray Water A. A Type 1 Reclaimed Water General Permit allows private residential direct reuse of gray water for a flow of less than 400 gallons per day if all the following conditions are met: 1. Human contact with gray water and soil irrigated by gray water is avoided; 2. Gray water originating from the residence is used and contained within the property boundary for household gardening, composting, lawn watering, or landscape irrigation; 3. Surface application of gray water is not used for irrigation of food plants, except for citrus and nut trees; 4. The gray water does not contain hazardous chemicals derived from activities such as cleaning car parts, washing greasy or oily rags, or disposing of waste solutions from home photo labs or similar hobbyist or home occupational activities; 5. The application of gray water is managed to minimize standing water on the surface; 6. The gray water system is constructed so that if blockage, plugging, or backup of the system occurs, gray water can be directed into the sewage collection system or onsite wastewater treatment and disposal system, as applicable. The gray water system may include a means of filtration to reduce plugging and extend system lifetime; 7. Any gray water storage tank is covered to restrict access and to eliminate habitat for mosquitoes or other vectors; 8. The gray water system is sited outside of a floodway; 9. The gray water system is operated to maintain a minimum vertical separation distance of at least five feet from the point of gray water application to the top of the seasonally high groundwater table; 10. For residences using an onsite wastewater treatment facility for black water treatment and disposal, the use of a gray water system does not change the design, capacity, or reserve area requirements for the onsite wastewater treatment facility at the residence, and ensures that the facility can handle the combined black water and gray water flow if the gray water system fails or is not fully used; 11. Any pressure piping used in a gray water system that may be susceptible to cross connection with a potable water system clearly indicates that the piping does not carry potable water; 12. Gray water applied by surface irrigation does not contain water used to wash diapers or similarly soiled or infectious garments unless the gray water is disinfected before irrigation; and 13. Surface irrigation by gray water is only by flood or drip irrigation. B. Prohibitions. The following are prohibited: 1. Gray water use for purposes other than irrigation, and 2. Spray irrigation. C. Towns, cities, or counties may further limit the use of gray water described in this Section by rule or ordinance. |
It has been pretty quiet in the field.
Some health service people hate the new law, but they can't demonstrate that anyone is getting sick, which is the only real concern.
Environmentalists upset that grey water + composting toilets are not allowed has been the main feedback coming back to the Department of Environmental Quality (see the department's clarification, PDF, 12k).
AZ DEQ is planning to revise the rules in 2003. They are considering allowing kitchen sink water if a grease trap is used, and kitchen sink water is applied subsurface. This would solve the composting toilet issue, as kitchen sink water wouldn't be left out in its own, awkward third system.
Phoenix is not interested in grey water. Rural areas and Southern Arizona are very interested (13% were already reusing grey water in Southern Arizona prior to the law change, according to a Water CASA study).
Builders of new homes in Southern Arizona are open to the extent that they are considering embracing a law which requires dual plumbing in new construction.
The big missing link is qualified retrofit installers.
Much has been made of the fecal coliform levels in kitchen sink water in the Water CASA study. The 88,400 fecal coliforms/ 100 ml level was used to justify excluding kitchen sink water from the law. This equates to nearly a gram per day of mammalian fecal matter going down the kitchen sink, which defies common sense (more on understanding Fecal coliform measurements).
This high reading is most likely caused by indicator organisms growing in the plumbing due to the nutrients in the food bits in the sink. Does this mean pathogens also breed? If so, extra caution is warranted, if not, then not.
This question can and should be resolved by comparing indicator to pathogen levels at different points in the plumbing; the sink, the trap, the outlet.
Even if pathogens do breed in the kitchen sink plumbing, the levels are still 98% less than the 5,000,000 typical fecal coliform level in raw sewage, so the kitchen sink water could reasonably be handled by a more stringently designed greywater system.
Kwami Agyare, Engineering approvals unit 602 -771-4664
Chuck Graf 602-771-4661 author of grey water guidelines.
The Water Conservation Alliance of Southern Arizona provided the impetus behind the rationalization of grey water laws in Arizona.
It's like the California grey water law, which it is patterned after, except worse.
How to improve IPC grey water law
Malibu has their own innovative greywater law. Their graywater handbook produced by Peter Warshall and Associates is a great resource.
The mulch basins are a good feature.
Committee Bill 6414- 2001- AN ACT CONCERNING A MUNICIPAL PILOT PROGRAM
FOR GRAY WATER- establishes a pilot program for the use of gray water from
publicly owned treatment works. As part of the pilot program, the
department may approve the use of such treated gray water in public schools
and municipal facilities in manners determined by the
department, provided such uses do not negatively impact public health.
(This is a message from a visitor to the Oasis web site) Colorado needs some help too! Can only use the grey water for below ground use, in other words make a leach field as the only accepted use.
More rumors, from various sources, indicate fairly liberal attitudes by Colorado inspectors in practice. Anyone able to shed light on this apparent contradiction?
(Another visitor message) Colorado Health Department (State) is UNsympathetic. We need a new state law. Individual counties are usually sympathetic to grey water, but don't want to violate state law.
Best method is to plumb the house as if recycling grey water, install a "Y" valve going to the septic tank, and after Certificate of Occupancy is issued, divert the flow to wherever you want. Inspectors don't care.
Obvious drawback is one has to build a septic system.
(This is a spurious entry included because it is an interesting case of lawmakers confusing the definitions of reclaimed water and grey water.)
Senate Committee Approves Business = Tax Benefits for Water Conservation-
Businesses that undertake certain large-scale water conservation projects would
get substantial tax benefits under NJBIA-backed legislation released by the
Senate Budget and Appropriations
Committee on February 26. The bills, A-2380/A-2381 (Bagger, Suliga) , are aimed
at helping companies capture, treat and use "gray water" in their
production processes. "Gray water" is treated effluent that is normally
discharged into waterways by local sewage-treatment facilities. By capturing
it, treating it further, and using it for non-drinking water in their factories,
businesses can conserve millions of gallons of potable water suitable for drinking.
A-2380 would provide a 20 percent investment tax credit against the corporation
franchise tax for purchase of equipment used to treat effluent from a wastewater
treatment system. A-2381 would exempt the purchase of this equipment from the
sales and use tax.
Old New Mexico grey water law considered greywater as part of septic system law—a bad idea.
New greywater law based on Arizona model—a much better approach—signed March 11th 2003:
HB114 -- Facilitating Gray Water Use in NM Landscapes
See summary below or go to the full legislation on the official site.
Rep. Mimi Stewart was the bill's lead sponsor.
3/8/03--We did it! HB114 that allows us to use gray water for residential
landscapes passed the Senate yesterday with only two senators voting against 35 others who voted in favor!
Thanks to everyone who called, emailed and testified over the last weeks. Your
efforts made a real difference!
Also, since the bill has an emergency clause tacked on to it, the bill will
go into effect immediately
--instead at the beginning of the fiscal year in July.
This will be great for New Mexico!
Thanks, Melissa McDonald
What would HB114 do?
HB114 simplifies state code so that gray water can be used safely in the landscape.
Currently state code does not differentiate between black and gray water (defined below). This makes gray
water re-use prohibitively expensive. By making the necessary distinction and creating safe guidelines,
we will take an essential step in conserving New Mexico’s most valuable resource for future generations.
With essentially no expense to the state, the positive effect of HB114 would be immediate.
HB114 would NOT undermine any local ordinances, because it allows for towns,
cities, and counties to be more restrictive when it comes to gray water reuse
What is Gray Water?
Technically, gray water is untreated household wastewater that has not come
in contact with toilet waste (black water). Primarily, gray water includes waste water from bathtubs, showers,
bathroom sinks, and clothes washing machines. HB114 also stipulates that wastewater from kitchen sinks,
dishwashers and the washing of material soiled with human excrement to be "black water".
Is Gray Water Safe?
Yes. When handled properly, gray water is safe. HB114 includes best management
practices developed to protect public health and water quality. Arizona and Texas already have gray water regulations
similar to HB114. Many of the rules in Arizona are based on an extensive study conducted in Tuscon,
which can be found at http://ag.arizona.edu/AZWATER.
Some of the benefits of this new Gray Water Reuse Legislation:
Conserves Water
Beautifies Communities
Saves money on water bills
Supports water efficient homes
Saves water for future generations
Reduces demand on water systems
Creates plumbing and landscaping jobs
If you would like more information on this bill, please contact:
Melissa McDonald 424-4444
Paul Paryski 660-4077
Representative Mimi Stewart 986-4341
A11028-2002- To encourage water conservation by requiring the Department of Environmental Conservation to promulgate regulations regarding the use of reclaimed wastewater and gray water. - passed Assembly, sent to Senate 4/02.
Green building tax credit includes "alternate supply water:" gray water, rainwater, runoff, and groundwater which enters basement pumps.
HB3320- 1995- Requires Department of Environmental Quality to establish guidelines for use of grey water and to seek approval of United States Environmental Protection Agency for guidelines.
A visitor from Corvalis, OR shared the following perspective:
Current law allows such minimal and restricted greywater use that changes should be made legislatively. Past attempts have failed, but have been only loosely organized.
(This is a message from a visitor to the Oasis web site) FYI - I was told from the On-Site Sewage Facility (OSSF) Designated Representative at the Springhills Water Management District (regulates building permits based on septic system design), that the State of Texas currently only permits the use of washing machine water in grey water systems. The state governing agency, the Texas Commission on Environmental Quality (TCEQ), formally known as the Texas Natural Resources Conservation Commission (TNRCC), requires kitchen and bathroom basin water as well as bath and shower water to be treated in a septic system. Blackwater obviously has to go to the septic system, but composting toilets are allowed. The installation of a composting toilet will allow a slight reduction in required size of the drainfield, but never for the elimination of the septic tank. TCEQ regulations are found on their website http://www.tceq.state.tx.us but I have not yet found the exact chapter and verse regarding Texas grey water prohibitions.
Study (pdf) done by Texas A&M university that puts the Texas Administrative Code concerning on-site grey water systems into a clear and easy to read format with good diagrams. It states that greywater from washing machines, bathtubs, and non-kitchen sinks can be used in greywater systems.
Utah Blows it on New Greywater Reg
Despite having excellent examples to follow in its neighbors Arizona and New
Mexico, Utah has instead followed in California's footsteps to enact a law which
is worse than useless. It actually outdoes California in making virtually no
practical greywater installation legal, with this section:
(ii) Surge tanks shall be:
(A) at least 250 gallons in volumetric capacity to provide settling of solids,
accumulation of sludge and scum unless justified with a mass balance of inflow
and outflow and type of distribution for irrigation...
Anyone who makes the mistake of believing the law's implication that a tank of this large size is in any way advantageous will end up convert innocuous greywater to festering, anaerobic blackwater.
This provision illustrates two basic greywater errors:
The prohibition of sub-mulch irrigation is the nail in the coffin for all greywater technologies other than branched drain to infiltrators or subsurface drip irrigation, both a stretch for single family homes.
The provision that local jurisdictions have to request certification and demonstrate that they have the resources to process greywater permits is a novel one. Not a bad idea if there was any reason whatsoever to build a greywater system with a permit, but just a bad joke considering that there isn't.
Predicted result: Less than ten permits will be pulled for greywater systems under this law in the next five years. Illegal installations will continue unabated, and professionals will not be able to get involved in installing sensible systems due to their illegality.
Washington State grey water factsheet (PDF, 450k)
H301: This bill proposes to require the use of gray water for toilet water in state buildings. DID NOT PASS
There is information on greywater in Australia in the Builder's Grey Water Guide (book).
Jordan is working with people from Arizona on a new greywater policy. They've issued a report, as well.
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