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Thursday, April 8, 2010

Greywater Grifting - The Big Fleecing

Recall that there was some discussion of site testing during the March meeting of the Graywater Advisory Committee in previous postings.  The concept included potentially using some of Oregon's existing site evaluation practices under the On-site and Underground Injection Control programs.  The On-site program requires a site evaluation per lot in a subdivision.  Now let's explore the issue of applying this to what might be the number of potential participants in Oregon.

California estimates about 14% of the homes in the state are active greywater users or 1.4 to 1.7 million homes.  By comparison, the latest census in Oregon determined there are about 1.3 to 1.4 million homes. For the sake of discussion, let's assume that Oregonians do not adopt greywater reuse as enthusiastically as California, say 10%.  That is about 140,000 homes.  Now let's assume each home needs a site evaluation report using the On-site standards - that is two pits spaced 75 feet apart.  That is about 280,000 pits or about the number of water wells exist in Oregon today.

Now let's recall the biggest threat to groundwater identified by the Oregon Department of Human Services, the Oregon rules regarding Underground Injection Control, and the greywater guru, Art Ludwig, are poorly constructed wells because the idea is to discharge greywater diffusely on the ground surface rather than more focused in the subsurface through a septic tank or UIC well. Pits and borings that are improperly abandoned come to mind as there are no standards for plugging and abandoning borings less than 10 feet deep.

And now let's consider that greywater is spread diffusely on the ground surface as opposed to injected into a well or septic tank.  When one examines Oregon's rules regarding exploratory holes under 690-240-0030 Other Holes: General Performance and Responsibility Requirements where "other holes" are constructed using a wide variety of equipment and are not typically designed to access water in order to collect subsurface information. The landowner of the property where the "other hole" is constructed is ultimately responsible for the condition and use of the other hole. That also means the landowner must abandon the "other hole" in such a manner that "...water cannot move vertically in them with any greater facility than in the undisturbed condition prior to construction of the other hole".  With respect to the suggested site evaluation process using On-site or UIC standards, the problem becomes immediately apparent - we have breached the structural, microbial, and chemical integrity of the soil and geology that we rely on to treat waste.  The "other hole" used for testing and evaluation of protecting the state's groundwater now becomes the threat to the chemical integrity of the groundwater.

But the potential revenue from the site evaluation and permitting process is where things get interesting. At the meeting it was estimated that a site evalutation report costs about $500 to $1,000 to secure the data and prepare the report.  Integrating this into the potential number of homes in Oregon that might potentially become active in greywater (say 140,000) yields $70,000,000 to $140,000,000, and that is just for the site evaluation.  No evaluation would be complete without a permit fee. Let's assume for purposes of discussion a permit fee of $100; and there is $14,000,000 that is now available to administer Oregon's graywater program or some program in a budget-challenged state.  The Oregon Water Thorn saw this early in the discussion of the Oregon Graywater Advisory Committee process as one of the primary interests for the Oregon DEQ to require a permit.

Now consider the issue of costs associated with treatment, say using a commercial treatment system like the Nubian Water Systems profiled as the Greywater Gadget of the Week.

Is all of the fuss over site evaluation and permitting for greywater reuse really "protecting the public" or just "Ponzi schemes"?


  1. Todd,

    again an interesting article. The committee has many challenges ahead to try and reach some conclusions.

    I found my visit interesting - the level of FUD was the strongest I have ever felt in a meeting.

    My overall sense is that every little risk is being evaluated separately instead of taking a holistic approach.

    IF (a big IF) Oregon took the approach of requiring best practice graywater irrigation, then the FUD element could almost be stripped away.

    I dont know the ETo values for the region are (do you have them?), but as an example if the ETo was 6" in July, the optimum irrigation area for 100 gallons of graywater (eg 4 people) is 1,629 sq ft. (refer to this calculator to try different values http://www.graywatergardening.com/ETo.html)

    With average soil, this would involve about 400 linear feet of dripperline, which involves 400 emitters, each irrigating .25 gallons per day.

    This then allows the top 3-4" of soil containing the most bacteria and microorganisms to do its job in treating the water.

    Apart from encouraging excellent plant growth, this approach takes away almost all of the risks:

    Graywater is cleansed before it makes it near groundwater; - even is the groundwater level is only 2 feet below the surface;
    The potential for graywater to bypass the topsoil via well entry is significantly reduced with the vast majority of emitters being some distance from the well;

    From an outsiders' perspective, this would mean no soil tests are required, a simple shovel test to make sure groundwater is at least 2' below natural ground level.

    From a permitting perspective (getting back to the ponzi scheme), the householder could be required to calculate the graywater generated on a daily basis, perform an ETo calculation to calculate the optimal irrigation area, then provide a lot plan showing the planned irrigation area (irrigated area must be at least as big as the calculated area).

    I hope the committee will understand that if the permitting process is too severe then people will just revert back to buckets / barrels of graywater irrigated manually, creating pockets of intense irrigation that the soil cannot handle effectively, and simply passes through (high risk of contamination) into the groundwater.

    To summarize an overly long post, if the graywater is irrigated efficiently, then the soil can do its job properly, and remove the risk, taking away most of the committee's concerns.

    ps. I am assuming homes with graywater re-use have the common sense (education?) to deactivate them over winter when additional irrigation is not required. I dont believe this is as big an issue as one or two committee members suggest it is.

  2. Paul:

    I concur with your sense of Fear, Uncertainty, and Doubt (FUD) that the majority of the Graywater Advisory Committee continues to harbor. I don't share it, but I also sensed that much of the FUD was fueled by DEQ, hence the reason for my resignation from the committee to pursue the outreach and education avenue that you wisely suggest. Your counsel on greywater matters is appreciated. Thanks for relocating some of your greywater manufacturing operations to Oregon. I am hopeful to locate more venues to show your products and share your knowledge.