SUMMARY OF GOOD/BAD BITS
Good news: The proposed code allows people to install a greywater system
with out a permit so long as the system produces less than 60 gallons per
day and follows guidelines
The bad news: Local areas are allowed not to adopt the code if they don't
feel like they have enough funding, only septic installers and engineers
can design some types of greywater systems, only tanks and pumps designed
for greywater are allowed to be used (there are none), and all types of
clay soils are banned (sandy clay, silty clay, etc.)
If you live in the state of Washington, you can give input on the new
state code. Or, send this to friends,families,colleagues that do, or even
if you don't live in Washington but want to encourage them to have a
functional code, you could also write in.
* Background *
The state of Washington is creating guidelines for subsurface irrigation
of greywater, through a committee I participated in over the past year.
Most of the people in the group were from the septic system, health, or
engineering fields, and very few had any practical experience with
greywater as a source of irrigation water. A few months ago draft code was
created and circulated, and two public meetings were held. I did not
realize that written feedback was also accepted until I saw the summary, or
else would have send this email during this time. There were many written
comments, almost entirely from the regulatory field and almost none from
home owners, environmentalists, or other affected/interested parties. I
think the state would like to hear comments from people who would be
impacted by this code and have not yet participated in this process.
The code was amended to include many of the previous comments, in my
opinion making it worse than it was before. Even though this is not an
official comment period, I encourage you to send them input, which has not
been heard and hopefully it could help move the code in a more constructive
If local environmental health departments do not change the code to make
it more restrictive, which they are allowed to do, the new code will allow
a homeowner to install a two "Tier 1" systems (a greywater system that
produces less than 60 gallons/day and does not include a pump) without
getting a permit. The legal requirements are reasonable. The largest areas
of concern are for the "Tier 2" systems (any system that includes a pump
and/or ismore than 60 gallons/day). Many aspects of the new code will make
it economically infeasible for most homeowners to install a legal Tier 2
system, unless they have a very greywater friendly environmental health
department. A friendly environmental health department could allow a
homeowner to install/design a Tier 2 system, but they also could require a
"qualified professional" do do this. The current definition of "qualified
professional" is very limited and excludes the natural greywater installers
(people who know about plumbing and plants) . If this is not changed, I
predict that Washington will have very little compliance with this code in
the Tier 2 section, as California did until it changed its code last year.
Link to the draft document:
These are some points you may want to include in a letter:
(personalizing it a bit would be great!, add in what you do, why you care,
where you live, etc.)
To: "Lopez, Lilia (DOH)" <firstname.lastname@example.org>,
Dear Lilia Lopez,
I am writing in regards to the draft greywater code proposed for the state
of Washington. I am encouraged that the state is working on a new
code to facilitate legal means for people to conserve water by reusing
greywater. Overall I think the new code is a great step in the right
direction. There are however, some critical changes that need to be made
for this code to meet its goals. I am concerned that as it stands,
requirements for legal greywater reuse are economically unfeasible for the
average person, and so will lead to minimal code compliance (as
experienced by other states with restrictive greywater laws).
Some specific points follow.
1) -"A local health board may choose not to implement and enforce this
chapter if adequate resources are not available."
This should be removed from the draft code. Health boards already have
means to modify codes to serve local needs, and this section seems to
encourage localities to avoid this positive step forwards. Local health
boards should have to alert their residents if they don't want to follow
the code to allow for public debate about the decision.
2) -The definition of "qualified professional" means an on-site sewage
treatment system designer or a professional engineer..."
This definition needs to be changed. For the mid-level greywater systems,
the natural greywater installers and designers ("qualified
professionals") should be plumbers, contractors, and landscapers. On-site
sewage treatment system installers are trained to view greywater
as equivalent to (feces-containing) sewage, and so are very unlikely to
understand and implement the goals of greywater reuse. Engineers are
needed for larger systems, but not for the smaller residential systems.
Furthermore, the cost associated with hiring an engineer to design a
residential system will make it economically unfeasible for most people to
have a greywater system. I urge you to change the definition of
"qualified professional" for Tier 2 systems to include landscape
contractors, plumbing contractors, and general contractors.
3) Storage and pump tanks must be ... (i) designed for greywater use
There are no existing tanks or pumps designed for greywater use, so this
requirement should be removed. The tanks and pumps should be designed to
meet the demand (pumps should be designed to pump dirty water ie. an
"effluent pump", and tanks should be water tight and able to be cleaned.
Even manufactured systems marketed for greywater have adapted existing
tanks and pumps, not designed for this purpose. This requirement for
having components "designed for greywater use" makes no sense.
4) Storage and pump tanks must be ... (v) provided with an overflow
pipe.... that flows by gravity to approved sewer or septic.
This section should be removed. Sewage ejection pumps are not required to
have an overflow going to the sewer/septic. Why should greywater? If
someone's greywater plumbing is located below the sewer line and they have
a sewage ejection pump for the greywater, this would mean they could not
legally reuse the greywater since its impossible
to have a gravity connection to the sewer.
5) Soil types of "sandy clay, clay, [or] silty clay" are considered "not
suitable" for greywater irrigation
This should be removed. Other states allow clay soil to be irrigated with
greywater and do not have problems with ponding or runoff. Irrigating clay
soil requires a larger dispersal area than other types of soil, but should
not be banned. In Arizona, Texas, and New Mexico all soil types are allowed
to be irrigated so long as there is no "ponding or runoff". In California
clay soils are allowed to be irrigated and require a larger irrigation
field size. Why should Washington ban all types of clay soil when other
states don't and there is no evidence that greywater irrigation of clay
soils is a problem?
8) Soil and site evaluation required for Tier 2. Only qualified
professionals or local health officers may perform soil and site
evaluations. Soil scientists may perform soil evaluations.
The code should allow for a simple and low cost way to analyze the soil,
such as sending a sample into a lab. Please expand to read: "Soil
scientists may perform soil evaluations, this includes sending soil
samples into a laboratory for analysis".
Thank you for your time and hard work in creating this code. Please finish
the process by removing and amending the current components of the code
that will make legal greywater unfeasible for the average person.