Graywater Discussion

Hi all,
Based on my involvement in this Graywater code revision process, I am finally compelled to offer up a few of my thoughts and experiences to those of you on several of our local listserves concerning with this new and exciting turn of events for making simple graywater systems more accessible, permittable and affordable for the people of CA!

Indeed, the latest ³emergency² passage of new CA State Graywater Standard for the CA Plumbing Code is all very exciting. This newly revised code language still needs to be formally adopted and a comment period will likely begin near the end of August see Art Ludwig¹s comments below. There is a listserve for the many graywater activists statewide that we use to network and keep in touch on this fast moving process here is the link to sign up if you wish to participate –

I was lucky enough to be part of the historically large crowds of people from many parts of the state that attended both of the HCD public meetings in Sacramento to comment on and help develop this new language. Here is a link to the HCD site where you can read the Chapter 16 Part I language that was approved for yourself –

I have been a member of the Sonoma County Graywater Working Group (SCGWG) since it¹s inception back in summer of 2008. I am also honored to be on the advisory board of the Statewide Greywater Alliance, which is certainly composed of the most progressive graywater posse in the state!

The SCGWG group has been convened/facilitated by PRMD staffer James Johnson and attending are other key PRMD staff and Well & Septic and Health Dept., SCWA, City of Santa Rosa, as well as a number of private contractors, engineering firms, and a couple public educator/demonstration based orgs., (Daily Acts & OAEC WATER). The SCGWG just met two weeks ago to re-commence the process of trying to understand what are the implications of this new proposed State graywater code language and how will the County and Cities wish to officially adopt and locally apply the new code? There is a general desire with this group to move this process along quickly, so maybe we can get something official out by early winter??? The big unknown monkey wrench possibly in the works is actually being wielded by the Regional Board, who is talking about Waste Discharge Requirements or WDR¹s??

What seems plausible for what the County may do, (who knows really???) based on the discussions in the SCGWG meeting, is that they would adopt the new State code as written, which I believe then means we do not need a specific Board of Supes resolution for a new ordinance? Then additionally, depending on the size and complexity of any newly proposed graywater system,  for the most basic systems instead of needing an expensive ³construction permit² with associated design costs, you would only need to get a basic ³plumbing² permit ($70 bucks??) due to the fact that you will be cutting into the plumbing and also at a minimum we would also be asked to provide a Œplot plan¹ for where the graywater disposal/reuse discharge points would be to verify that certain setback conditions are honored.

The key part of this whole process with the new state level language, that will hopefully be left intact by the county/cities, that I think is worth bringing to everyone¹s attention has to do with a specific exemption that we got passed dealing with the fact that NO CONSTRUCTION PERMIT will be required for anyone to install either a Laundry to landscape systems or a single fixture system from say your shower or bath sink. There are however 12 conditions that must be met for you to be able to do this and, again, the county has all the authority to add further hoops and such as it sees fit!

Below I am going to paste in the specific Chapter 16 section language on this part, because I think that based on the banter below Zeno, Rue & Denny about the “hodge podge” of likely existing systems out there, a read of the 12 points will be instructive? Most of us who participated in this re-write process are clear that by a long shot the majority of folks who will benefit immediately from the new much looser code language will be those currently scofflaw DIY homeowner folks wanting to do simple systems that discharge less than 250 gallons/day from their clothes washers and showers/sinks, etc. If you want more complicated/expensive systems (tanks, pumps, filters, pressurized, re-plumbed into house for toilets etc), then most folks should probably be working with some professional designer/installer anyway! This is how the new code looks at it as well.

A key area where there is a lack of consensus is on the spelling is it Graywater or Greywater!!?? Ha Ha!

If you want to help move the ball forward then, comment to the state process as outlined below. Call up your County Supervisor and/or City Council members and ask them to fully support implementing the new code revision conditions in a manner fully in keeping with the spirit of the new code language intended to make graywater affordable & accessible Statewide! Also, some may need to talk with folks they know at the Regional Board to get clear on how they will be helpful here as well?

So stay tuned, as soon as we get a final/formal process finished by the county

– then OAEC¹s WATER Institute will certainly be offering hands-on installation and demonstration workshops and tours for what will be the two most common simple/affordable and LEGAL systems Laundry to Landscape and Branched Drain Shower/sinks!! I think that these two systems will benefit more people, help save/resue water, reduce energy use, improve aging rural septic system performance and thus hopefully also mitigate many potentially existing water quality issues associated poorly functioning or ill-designed/installed “gray”water systems!!

Mostly Water,

The following is an excerpt from the attached HCD Emergency Chapter 16A where it states clearly to me and others in the Sonoma County Graywater Working Group at the meeting last week that by ³ Exception: A construction permit shall not be required for a graywater system supplied only by a clothes washer system and/or a single fixture system in compliance with the requirements of Section 1603A.1.1. ³

1603A.0 Permit.

It shall be unlawful for any person to construct, install, or alter, or cause to be constructed, installed, or altered any gray water system in a building or on a premises without first obtaining a permit to do such work from the Authority Having Jurisdiction. 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.

Exception: A construction permit shall not be required for a graywater system supplied only by a clothes washer system and/or a single fixture system in compliance with the requirements of Section 1603A.1.1.

1603A.1 System Requirements.

1603A.1.1 Clothes Washer System and/or Single Fixture System. A clothes washer system and/or a single fixture system in compliance with all of the following is exempt from the construction permit specified in Section 108.4.1 and may be installed or altered without a construction permit:
1. If required, notification has been provided to the Enforcing Agency regarding the proposed location and installation of a graywater irrigation or disposal system.

Note: A city, county, or city and county or other local government may, after a public hearing and enactment of an ordinance or resolution, further restrict or prohibit the use of graywater systems. For additional information, see Health and Safety Code Section 18941.7.

2. The design shall allow the user to direct the flow to the irrigation or disposal field or the building sewer. The direction control of the graywater shall be clearly labeled and readily accessible to the user.

3. The installation, change, alteration or repair of the system does not include a potable water connection or a pump and does not affect other building, plumbing, electrical or mechanical components including structural features, egress, fire-life safety, sanitation, potable water supply piping or accessibility.

4. The graywater shall be contained on the site where it is generated.

5. Graywater shall be directed to and contained within an irrigation or disposal field.

6. Ponding or runoff is prohibited and shall be considered a nuisance.

7. Graywater may be released above the ground surface provided at least two (2) inches (51 mm) of mulch, rock, or soil, or a solid shield covers the release point. Other methods which provide equivalent separation are also acceptable.

8. Graywater systems shall be designed to minimize contact with humans and domestic pets.

9. Water used to wash diapers or similarly soiled or infectious garments shall not be used and shall be diverted to the building sewer.

10. Graywater shall 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.

11. Exemption from construction permit requirements of this code shall not be deemed to grant authorization for any graywater system to be installed in a manner that violates other provisions of this code or any other laws or ordinances of the Enforcing Agency.

12. An operation and maintenance manual shall be provided. Directions shall indicate the manual is to remain with the building throughout the life of the system and indicate that upon change of ownership or occupancy, the new owner or tenant shall be notified the structure contains a graywater system.

Art Ludwig writes:
Dear Graywater Stakeholders:
There are a lot of questions floating around about how to comment on the new California Greywater standard adopted August 4th.

Here’s the deal:
The comment period is anticipated to start on August 28, and you can submit comments on HCD or BSC’s web sites then.

Formal notice indicating the beginning of the comment period and directions on how to comment will be included with a copy of the Express Terms.

This initial comment period will last for 45 days.

Comments submitted before then will not go into the official comment process.

Subsequent comment periods may be necessary if HCD proposes to make revisions to the Express Terms based on comments received during the initial 45 day comment period. If necessary these comment periods will be either 15 or 45 day comment periods, depending on if the changes are minor or substantive.

During the initial 45 day comment period a hearing to provide verbal comments may be requested. If a hearing is requested, it is not the same as a focus group meeting or a building standards commission meeting. There is no discussion of fact. HCD listens to comments and the hearing is closed.

At the conclusion of the comment period, or periods, and after all comments have been evaluated, HCD will summarize and respond to all comments in a Final Statement of Reasons (FSOR) that will be available on the HCD website with the final express terms.

This process satisfies the public participation requirement contained in the California Rulemaking Law. After the close of the comment period, HCD will certify to the California Building Standards Commission that they have complied with the rulemaking requirements and the regulations will become permanent.

I think the Windsor development was double plumbed on the exterior only, for recycled tertiary beneficial reuse on lawns, plants, etc. Maybe Deb can give us some clarity here. I do know that the project was the first in northern CA to include a purple pipe component, but I do not believe it included the interior of the houses, as greywater was taboo at the time of this planning (about 7 years ago).

“The good people who are using greywater now, are mostly doing it independant of permits – let alone support from jurisdictions.”

Ah yes, us West County folk who have gardens and cabins and small septic tanks have come up will all sorts of creative and useful greywater contraptions. I wonder how we might get some of these folks to investigate what the best practices are and how could the county help people conform and create for the future a new and better ³greywater code², rather than the hodge podge that is in existence today.


Hi there,
Santa Rosa’s BPU held a study session on greywater use. The cities and county need to revise their codes to allow (encourage) greywater use in order to get anything meaningful going. The good people who are using greywater now, are mostly doing it independant of permits – let alone support from jurisdictions.

Windsor has a development that was double plumbed. It would be great to have existing homes using greywater. There are a lot more existing water users than new construction or uses.

We must push for code updates in all the jurisdictions.

Have a great weekend! Rue

This is good news indeed.

What needs to be done to make this a widely used option in Sonoma County?

– Zeno

Good news folks!


Responding to the increasing pressures on our state’s water supplies, last month the California Building Standards Commission (CBSC) approved new standards that facilitate the use of graywater in homes and voted to make the standards effective on August 4th, 2009 rather than waiting until 2011.

The new standards will make it much easier to reuse water from bathtubs, showers, sinks, and washing machines for outdoor irrigation while protecting local water quality and public health.

Senator Alan Lowenthal’s successful <legislation launched this revision of the graywater standards.

Landscape designer Bernadette Balics applauds the move. “My clients have always been interested in using graywater systems for irrigation, but were wary about negotiating the permitting uncertainties. The new standards make it easier for homeowners to reuse their graywater simply, safely, and legally.”
Graywater provides a cost-effective and reliable source of water that can be implemented quickly and helps guard against water shortages in future drought years.

While the new standards are a great leap forward, they don’t yet tap the full potential for graywater. Clean Water Action’s Jennifer Clary notes that “the big missing piece is indoor reuse, specifically hooking systems up for toilet flushing or laundry.” While using graywater for irrigation serves only seasonal demands in many parts of the state, expanding the standards to include indoor uses of graywater would provide year-round water savings across California.

In February, the Governor also responded to the water shortage by issuing an emergency proclamation. However, as we’ve reported, the proclamation has been used primarily to avoid environmental review under the California Environmental Quality Act (CEQA) and advance policies that do not provide environmental benefits or long-term drought protection.