The URL can be used to link to this page

Home My WebLink About05/18/2010, SS3 - RAINWATER HARVESTING REPORT ON TONIGHT'S AGENDA '� • From: Jenny Ferguson[SMTP:JENNY@WATERSMART.B[Z] RECEIVED Sent: Tuesday, May 18, 2010 1127:38 AM MAY 18 2010 To: Council, SloCity Subject: Rainwater Harvesting report on tonight's agenda SLO CITY CLERK Auto forwarded by a Rule Dear Council Members 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 this morning and Tim contacted me this morning to explain that overlooking my involvement in the report was not intended and that an error had been made. He also reiterated that the intention is 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 to anything Council signed off on. I'm also very happy to see the progression of Rainwater Harvesting for the city.Thank you very much for your support to achieve this. Jenny Ferguson oY G�'l�.b-it I V"�OUNCIL [?Cc[) DIR = RED FILE rTc-Ao C"146e 2rFIN DIR — MEETING AGENDA 31Z40AW6"nr<c 3'FIRE CHIEF O-ATTORNEY Zp pw DIR DATE4/OL ITEM # -953 p CEEB HEADS RECICE CHF F!-- P1(5 ZOUTIL DIR Nov-nm� �CCU AtV& 'U�1 m6Q, i ' There are some key issues that should be highlighted during the study session(I believe Council members may make comments after reading through the agenda). 1/The mayor directed that I be involved in the process..I was not.The recommendation of the report 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 the last page of the report which describes an intention to hold relevant stakeholder meetings). It is crucial that the process be transparent and open for it to be successful. Ownership and support by the 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 than 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." hqp://www.oasisdesign.net/greywater/press/index.htm) The Council should keep one eye on public safety concerns and the other on ensuring that ordinances and policy supports rainwater harvesting and encourages it to flourish-not discourage it with legislative disincentives. Here is where the document is failing in that regard: Legislative disincentives 1. "due to the health issues associated with(indoor use ofrainwater)..we would require these 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 design 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 to building a house. I am not a licensed architect, and I just put through a building permit application fora home which will fully rely on rainwater in King county.An engineer signed off on my design. Neither does the SLO building permit process require submittal of a building permit application by a licensed architect or Mechanical engineer.Typically, cities such as in OR and WA require that submitted rainwater harvesting system designs"comply with plumbing code and building code"in order that safety concerns be addressed. They will often specify particular situations that might require engineer sign off on an aspect of the application. Eg. In OR: required to be engineered only if on top of a building or on a sloping site. I AM AWARE OF NO OTHER RAINWATER HARVESTING JURISDICTION THAT REQUIRES THIS.(eg WA: prov 6.1 of their guidelines does not require single family dwelling rainwater 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 on standards already in place?Eg. I have seen some jurisdictions require a certain slope 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, city spends double time monitoring. Instead: refer to existing codes and standards—such as the plumbing and building code. Keeps it simple for applicant, less expensive.. ONLY ADD WHAT IS MISSING AND CRUCIAL. Misinformation 1. "cistems..(are).."typically buried underground" u f NEGATIVE RESULT: underground cisterns,are a higher health risk due to the possibility of runoff 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 prevention measures are more stringent). They are also difficult to'de-sludge' because of lack of access to 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 that are more vigorous"(not described what is meant). NOT CORRECT: De-sludging the bottoms of numerous small barrels,as opposed to one larger cistern is much more'vigourous'! Each opening of the many small barrels must be checked to ensure animals and mosquitoes can't enter. This claim that more'vigorous' maintenance is required on larger cisterns is the foundation for call that a permit be required for these systems. OTHER JURSIDICTIONS, SUCH AS WA and OR DO NOT REQUIRE PERMITS IF WATER IS USED FOR 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 utilizes naturally occuring sedimentation and flocculation processes which result in a higher quality of water after being in a tank than that falling on the roof. 4. "Lack of maintenance or poor management of harvested rainwater could lead to deterioration 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 potential '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. It is about using it before it washes away down the street. Rainwater tanks are no greater a risk for insect infestation than ponds, dog dishes, buckets and 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 be accounted for in the design—the risk is therefore nullified through the permitting process. I'm not sure what is meant by the additional risk of'microbial health hazards' posed by rainwater harvesting systems.