HomeMy WebLinkAboutREDfergusonss3RECEIVE D
MAY182010
SLO CITY CLER K
From :Jenny Ferguson[SMTP :JENNY@WATERSMART .BIZ ]
Sent :Tuesday, May 18, 2010 11 :27 :38 A M
To :Council, SloCity
Subject :Rainwater Harvesting report on tonight's agend a
Auto forwarded by a Rul e
Dear Council Member s
Please find attached my response to the report on the agenda for tonight's Council meeting .I
apologize for the late submission, but I only found out about the report yesterday . I was not
contacted about it by SLO City . I emailed John Mandeville and Tim Girvin with my comments thi s
morning and Tim contacted me this morning to explain that overlooking my involvement in th e
report was not intended and that an error had been made . He also reiterated that the intention i s
to develop guidelines in consultation with the community (not just Health and SLO GB).I
suggested that that be reflected in the recommendation and that an adjustment be made t o
anything Council signed off on .
I'm also very happy to see the progression of Rainwater Harvesting for the city . Thank you ver y
much for your support to achieve this .
Jenny Ferguson
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RED FILE
- MEETING AGEND A
DATE 5//4/b ITEM #
Et-HR DIR
There are some key issues that should be highlighted during the study session (I believe Counci l
members may make comments after reading through the agenda).
If The mayor directed that I be involved in the process . I was not . The recommendation of the repor t
continues to exclude me from the process as it directs that 'staff ..collaborate with SLO Green Build
and the San Luis County Environmental Health Department .' (This contrasts with the statement on th e
last page of the report which describes an intention to hold relevant stakeholder meetings). It i s
crucial that the process be transparent and open for it to be successful . Ownership and support by th e
community is vital . This should be reflected in the statement signed off on by the Council .
2/ The implementation of the Awahnee Principles is as important, if not of greater importance tha n
actual generating a commitment to them . We need to learn from the lesson of Greywater laws in Ca .
Laws that were so difficult to comply with they resulted in little uptake - illegal systems flourished .
("Only one in 10,000 of the 1 .7 million systems in the state have a permit ."
http ://www .oasisdesign .net/greywater/press/index .htm)The Council should keep one eye o n
public safety concerns and the other on ensuring that ordinances and policy supports rainwate r
harvesting and encourages it to flourish - not discourage it with legislative disincentives . Here is
where the document is failing in that regard :
Legislative disincentive s
1."due to the health issues associated with (indoor use of rainwater)..we would require thes e
systems to be designed by a licensed design professional such as an architect or a
Mechanical engineer "
NEGATIVE RESULT : excessive additional cost to rainwater harvester ; higher barrier to desig n
submittal than a house .
o This is a common response to something 'unusual' like rainwater harvesting :
prescriptive measures are put into place that create a higher bar than even applies t o
building a house . I am not a licensed architect, and I just put through a building permi t
application for a home which will fully rely on rainwater in King county . An engineer
signed off on my design . Neither does the SLO building permit process requir e
submittal of a building permit application by a licensed architect or Mechanica l
engineer. Typically, cities such as in OR and WA require that submitted rainwate r
harvesting system designs "comply with plumbing code and building code" in orde r
that safety concerns be addressed . They will often specify particular situations tha t
might require engineer sign off on an aspect of the application . Eg . In OR : required t o
be engineered only if on top of a building or on a sloping site . I AM AWARE OF N O
OTHER RAINWATER HARVESTING JURISDICTION THAT REQUIRES THIS .(eg
WA : prov 6 .1 of their guidelines does not require single family dwelling rainwate r
harvesting systems to be engineered )
2."incorporate reference to prescriptive guidelines "
EXTREME CAUTION : every extra prescriptive measure adds cost (for applicant and city to monitor )
and reduces flexibility in design . Balance between safety concerns and functionality of code is critical .
o Every prescriptive measure should be carefully considered . Is it doubling up o n
standards already in place? Eg . I have seen some jurisdictions require a certain slop e
on a gutter for rainwater harvesting systems & also require it for the building permit .
This means two separate inspections on the same criteria . Applicant pays double, cit y
spends double time monitoring . Instead : refer to existing codes and standards – suc h
as the plumbing and building code . Keeps it simple for applicant, less expensive .
ONLY ADD WHAT IS MISSING AND CRUCIAL .
Misinformation
1 . "cisterns ..(are).."typically buried underground"
NEGATIVE RESULT : underground cisterns are a higher health risk due to the possibility of runof f
from soil entering the system if cracks in cistern or flaws in seals develop (greater measures of
protection are associated with them in other developing countries – eg . Backflow preventio n
measures are more stringent). They are also difficult to 'de-sludge' because of lack of access t o
bottom (which must be done every 1-2 years). Underground cisterns should be 'atypical '
2."the use of a cistern (rather than a rain barrel)..requires annual maintenance activities tha t
are more vigorous" (not described what is meant).
NOT CORRECT : De-sludging the bottoms of numerous small barrels, as opposed to one large r
cistern is much more 'vigourous'! Each opening of the many small barrels must be checked to ensur e
animals and mosquitoes can't enter . This claim that more 'vigorous' maintenance is required o n
larger cisterns is the foundation for call that a permit be required for these systems . OTHE R
JURSIDICTIONS, SUCH AS WA and OR DO NOT REQUIRE PERMITS IF WATER IS USED FO R
LANDSCAPING IRRIGATION .
3."water quality could be of concern due to prolonged storage time "
NOT CORRECT : this is not backed by scientific data . Water cisterns have a microecology that utilize s
naturally occuring sedimentation and flocculation processes which result in a higher quality of wate r
after being in a tank than that falling on the roof .
4."Lack of maintenance or poor management of harvested rainwater could lead to deterioratio n
of neighbourhood conditions ...insect infestation, microbial health hazards, improper drainage ,
or contamination of the city's waterways"
• Without specifics it is difficult to know what is being referred to as a potentia l
'contamination of the city's waterways '. Simply put, harvested rainwater is coming off
a roof and into a tank . Normally it is flowing directly into the storm water system .
Nothing is added . Higher quality water comes out of the tank than falls on the roof. I t
is about using it before it washes away down the street . Rainwater tanks are n o
greater a risk for insect infestation than ponds, dog dishes, buckets an d
wheelbarrows left upturned in the yard and should be viewed the same. Good
maintenance practices on all these items reduce this risk . Drainage issues should b e
accounted for in the design – the risk is therefore nullified through the permittin g
process . I'm not sure what is meant by the additional risk of 'microbial health hazards '
posed by rainwater harvesting systems .