Every drop counts

Sept. 10, 2012

Researching rainwater harvesting systems last month was close to overwhelming, to say the least, but in a good way. It’s a very interesting topic, which I plan to follow closely, but there is so much information on the topic, including subtopics, that I had to pull the plug on my research unless I was going to turn the feature article into a thesis. Besides finding a plethora of information on rainwater harvesting, I also came across information on graywater harvesting, stormwater mitigation, water rate increases, water wars, water shortages, water quality, the history and drivers of rainwater harvesting, including the drought, etc. I’m sure you get the point — anything involving water conservation is becoming a hot topic, and will continue to get hotter.

From all my research, it seems to be commonsense that we should use rainwater harvesting technologies to conserve water supplies, and it is apparent that it is possible to successfully use rainwater for at least non-potable uses (the feature article showcases many projects in the U.S. that are doing this). And as I write this blog, I continue to come across more and more information regarding the topic! It’s never ending as you can see.

States differ

American Rainwater Catchment Systems Association Vice President Billy Kniffen is utilizing every drop of rainwater he collects at his home.

While talking with him about rainwater harvesting, he mentioned that the area he lives in, Central Texas, gets less than 20 inches of rainfall per year, yet his family is able to live off of it without a backup supply. The family uses the rainwater supply for everything… drinking, showering, irrigating, etc. 

According to the National Conference of State Legislatures, Texas HB 3391 of 2011 is one of the most far-reaching and comprehensive pieces of legislation regarding rainwater harvesting in recent years. Click here to review a map of rainwater harvesting laws.

“Texas’ new law says every state building now has to have rainwater capture, that is universities and all state construction,” explained Kniffen. “This is helping to move the industry forward.”

In Illinois, House Bill 4496, which amends the Illinois Plumbing License Law, was passed recently. Now the Metropolitan Planning Council is meeting with stakeholders for input to the Illinois Department of Public Health on possible changes to the plumbing code. The last meeting held on June 27 regarding the states plumbing code revision centered on adopting a use-focus approach instead of a source-focused approach for non-potable water for reuse, among other items.  

“What is important is how you are going to use the water, and depending on this you will use a certain treatment method,” explained John R. Bauer, president of Water Harvesting Solutions Inc. (Wahaso), Hinsdale, Ill.  Bauer is part of a committee of nearly 50 interest groups all helping to craft state codes with the Illinois Department of Health for water harvesting.

“The source is also important but it’s the use that drives how clear the water has to be, how it’s been sanitized, and other concerns on how it will be stored and maintained and pressurized,” explained Bauer. “For example, using water for cooling tower makeup will be different than water being used for subsurface irrigation vs. water being used for toilet flushing. Any number of sources can be used for any of these end-uses that might affect how you are designing a system.”

The stakeholders also discussed risk mitigation and needing a code that will allow for technological advances. The stakeholders’ recap document noted that enabling widespread reuse of treated non-potable water is two-fold: to provide another set of tools to conserve potable water and to reduce stormwater runoff, and to create a market place for these technologies in the state by allowing skilled labor, manufacturers, architects, designers, engineers, etc., to meet its growing demand; and that the product must also be cost effective.

Jurisdictional uncertainty was also discussed since it is not clear as to who is doing what regarding the aspects of the design, building, installing, operating, maintaining, and inspecting components of these systems.  As you can see, there is much to figure out.

According to Shawn Martin, director of PMG Industry Relations at the International Code Council, who I talked with about state and local legislation, a handful of issues have held the rainwater industry back in the U.S. Standards are one since they haven't been clear to certify catchment systems, but now these systems are certified by a third party. One has been the lack of standards for rainwater harvesting systems and components.  Without that, product manufacturers have not been able to get their products certified, a key requirement of plumbing codes.  Another issue has been that state and local regulations in some states have either made rainwater collection illegal (such as in Colorado) or have heavily limited the practice.

“In some parts of the country it was illegal to collect and reuse water from washing machines; in Colorado it has been illegal to collect rainwater because of water rights laws,” said Martin. “There has also been a lack of guidance in the codes — some codes didn’t say anything about rainwater — but that is changing rapidly now.”

The drought this year has also pushed rainwater harvesting closer to front and center.

“Today jurisdictions are being driven by droughts to consider new sources of water,” said Martin. “There are many groups studying rainwater harvesting in several states, and if all these task groups come out with guidance and encouragement for local government to do this, it will push rainwater harvesting to a tipping point. As the use goes up, costs go down because there is more innovation. When you are looking at a situation, where there is no water available, the return on investment gets big pretty fast. I think we will see a tipping point coming in the near future especially if widespread drought conditions continue.”

Martin mentioned that California is a state to watch closely. California Assembly Bill 1750 would enact the Rainwater Capture Act of 2012 and explicitly authorize residential, commercial and governmental landowners to install, maintain, and operate rain barrel systems and rainwater capture systems.

The California Department of Public Health is citing concerns.

“They are saying if it is put in a building, they are responsible for public health safety and they are nervous about the idea that people are collecting their own water and may or may not be maintaining it properly,” said Martin. “As a result of these concerns they were successful getting some amendments into the bill that started to treat rainwater almost like graywater.” Most of that concern seems to be about residential systems.

Graywater can be reused if it is not treated, but the key is that it can’t come in contact with humans and as a result it can only be used for subsurface irrigation.

“The caveat in this is that graywater shouldn’t be stored in a tank for more than 24 hours if it’s untreated,” said Martin. “If you leave it in there longer it becomes septic and a public health hazard. If rainwater is treated just like graywater you have a source of clean water, which according to experts this can be stored for a long period of time without becoming septic. However, if rainwater too is subjected to the 24 hour limitation, it will limit its ability to be used. So if rainwater is constrained to a 24-hour retention time it’s a huge problem. It changes everything.”

Martin added that there should not be this kind of constraint on rainwater.

“This could be a harmful precedent to treat rainwater, which is very clean, like a much more contaminated source, which is certainly not the case,” said Martin.

Martin also pointed out that the Department of Public Health is also seeking to establish their role in the design, permitting and approval process.

“Rainwater necessarily has both building and public health implications, and in California different departments are responsible for these two areas,” added Martin. “The challenge is to determine the roles and responsibilities of those with jurisdiction to ensure that permitting and operation go smoothly.”

Alf W. Brandt, principal consultant, Assembly Select Committee on Regional Approaches to Addressing the State’s Water Crisis, said that State Assemblyman Jose Solorio is continuing to work with the chair of the Senate Environmental Quality Committee to see if there is a way to resolve this issue.

“He understands the opposition from a wide range of parties and the concerns that it raises about requiring the Building Standards Commission to go to the Department of Public Health. He’s trying to work it out and to overcome the concerns of the Senate while addressing concerns of the people who support this.”

“Right now there are a number of provisons in the bill that are not acceptable to the rainwater industry and run counter the ICC International Green Construction Code (IgCC),” continued Martin. “The IgCC has a strong section on rainwater harvesting that has already been adopted by several jurisdictions around the country.”

At the same time, the California Plumbing Code is set to be updated with new chapters covering non-potable rainwater and graywater. These are going through a public review process, and would put in place regulations for rainwater harvesting practices,

“While we have been going through this legislative process with AB 1750, another effort on the regulatory side is set to roll out  code requirements for non-potable rainwater and graywater,” said Martin. “In the end, we’re hoping that California will end up with a strong set of codes that advance safe, effective rainwater systems there.”

Building bridges

Martin believes the key issue regarding rainwater harvesting policies is coordination between health officials and building officials.

“This needs to be worked out at state and local community levels,” explained Martin. “We have to build bridges between these two groups because they should have a shared jurisdiction over these systems (just as they do with swimming pools).

Martin pointed out that just recently a MOU was signed between ICC, the U.S. Centers for Disease Control and Prevention and the National Environmental Health Association with the intent of better coordinating the roles of building and health officials.

“We are working actively with them on first on swimming pools,” said Martin. “But as we progressed, it became clear that we need to tackle many other areas of shared interest like rainwater.

“We are building bridges between building officials and health officials,” added Martin. “What we are seeing is we can’t sit in departments and ignore each other. We need to get serious about working together. We have a shared mission of public health and safety, but we just have different pieces of it.”

So what is your position on rainwater harvesting? Are you yea or nay?

I’ll be blogging more about this topic in upcoming months, and maybe I will turn this into a thesis, so stay tuned…

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