Breaking Down Policy Barriers for Residential Greywater ... · - G. Wade Miller, Executive Director, WateReuse Association Preface and Introduction New York City’s policy on greywater

Shane McCabe

Pratt Institute/ PSPD Environmental Systems

Management Capstone

5/2/2013

Breaking Down Policy Barriers for

Residential Greywater Installation and

Usage in New York City

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Dedicated to:

The love of my life, Yafreisy Carrero, for love and support

My friends, for guidance and understanding

My family, for always being there no matter what

My Professors and Program, for giving me the chance to learn and grow

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Table of Contents:

I. Preface and Introduction Page 1

II. Introduction to Greywater in New York City Page 4

III. New York City Law on Greywater Page 8

IV. Case Study: Arizona as a Best Practice Page 13

V. Case Study: California as the Historical Context to Greywater

and its Similarity to New York Page 19

VI. Case Study: Florida as the State with the Most Innovative

Water Reuse Strategy Page 24

VII. Policy Recommendation for Breaking down Policy Barriers to Residential

Greywater Page 30

VIII. Conclusion Page 37

IX. Bibliography Page 38

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A growing body of evidence suggests that water reuse will play an expanded and critical role in

water management in the 21st century, not only in semiarid western states and the “sunbelt”

states, but perhaps in all 50 states. Reusing water will be one of the essential tools of the 21st

century water utility in ensuring a safe and adequate supply for their customer base.

- G. Wade Miller, Executive Director, WateReuse Association

Preface and Introduction

New York City’s policy on greywater prevents residential units from recycling their water back

into their homes. They should not only allow sustainable water reuse, but also to prevent unsafe,

non-permit holding systems from causing harm. There are two ends to water recycling,

conserving potable water and reducing sewage. Water recycling is important for conservation,

sustainability, affordability, and environmental protection. The drier parts of the United States

are able to better appreciate this because of the conditions in which people need to live to

survive. Other areas have a low water table, which is the depth at which water resides in the soil.

This causes local and state governments to institute claims, rights, and laws that prevent people

from either or in some cases both withdrawing and/or keeping water. When the used water is

returned to the ground then local laws can still be abided by and the water table can recharge for

others to use downstream. In an area with abundant water it may seem unnecessary for someone

connected to a city pipe to consider a greywater recycling system. Consider if something were to

happen to the abundant water

supply of New York City, such

as the water not meeting the

water quality standards of the

EPA, then there would be a need

to install water treatment plant or

replace a pipe. The other end to

ponder is how much damage

Combined Sewer Overflows

(CSO’s), which is the

combination of both sewer and

stormwater in one pipe being

discharged into the canals,

rivers, and bay directly without

treatment, due to the

environment and people near

them. The image shows the

locations and capacities these

WWTP’s can handle at any one

time. Greywater recycling can

prevent and/or reduce these

issues significantly, and at the

very least help a building reduce

its water bill while making sure

its water is fully used. (wwsystem.pdf, page 21)

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New York City water comes from reservoirs upstate; these are manmade lakes that detain water

so they may be piped downstate into the city. The reason why the City does not have to clean its

water is because it is already protected from contaminants so well that the city received a waiver

from the United States Environmental Protection Agency (EPA) to allow untreated water into the

public’s faucets. While it is still regulated, but there need not be any extraneous freshwater

treatment plants, which, along with other factors, helps to keep the water bills affordable.1

Consider the problems from the incoming water which, according to an article in (Water

(Conservation Report 2012 on page 27-29)

The New York World, in the Catskill-Delaware system would cost New York City almost $10

billion dollars to clean up to keep water potable; which in turn would put the individual

household’s water bill at an additional average of $157 per year.1 New York City receives most

of its water from two tunnels the stretch to the middle of the State, and has a third one in

construction. The water upstate is piped down using gravity through two different pipes leading

from the reservoirs all the way to Staten Island. There are repeated turbidity offenses in the upper

reservoirs. Future issues come into play with the closing of water tunnels 1 and 2 for repairs

upon completion of water tunnel 3, which has been under construction for a number of decades.

City Tunnel 3 will have to take on all the water for the entire City’s 1.5 billion gallons of water

per day needs. This is hard considering the average household uses 80,000 gallons yearly.2 The

water will be piped to mostly residential prominent areas of the City, as seen in the above figure.

If the upstate New York climate changed to a drier one, there would be water shortages and

reevaluations of how much the City’s water would need to cost. The New York State Department

of Environmental Conservation states, “[w]hile most of New York has an abundant supply of

water, population density and growth in some areas of the state are beginning to exert stress on

1 Malo, Sebastien. “Sandy stirs up trouble for a city drinking water”. March 6, 2013.

http://www.thenewyorkworld.com/2013/03/06/sandy-drinking-water/

2 New York City Department of Environmental Protection. “New York City 2011 Drinking Water Supply and Quality Report.” 2011.

http://www.nyc.gov/html/dep/pdf/wsstate11.pdf

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local supply infrastructure and potable water sources.”3 There are many chain reactions that can

stem from the threat and occurrence of terrorist attacks, large storms, malfunctioning pipes,

droughts, population growth, and other water related incidents that the government cannot ignore

if they wish to remain safe in the long run.

Most homes, offices, municipal buildings, and industrial sites use water once, drain it

down a pipe, and then never see it again. Because of this, it is easy to not think about what

happens to water after it goes down the drainpipe, but it really is a journey that is only half done.

The water then continues down pipes to the relatively nearby wastewater treatment plant

(WWTP). The WWTP then cleans the water and safely discharges it back into an adjacent body

of water. New York City has a combined sewer system, which allows for the collection of both

stormwater and wastewater to be taken and treated before safely discharging. The main issue

with a combined sewer systems arises out of the length and intensity of the rain during a storm.

The New York City sewer system is very old and can only handle so much water at one time;

therefore to relieve the stress and prevent backlogged water flowing out of toilets, sinks, and

sewers, the addition of a CSO was added. The combined sewer outfall is the discharge point for

both waste and stormwater which then flows directly into an open body of water, completely

untreated. This is a reminder to never flush your toilet during storms because of the sheer amount

of pollution it causes!

The addition of water recycling can help to reduce the overall amount of water in the

sewer during normal times and storms. Water recycling can replenish the local water table, and

clean dirty water in a more ecological method. Combined sewer overflows are such a serious

problem that the New York State Department of Environmental Conservation has a Long Term

Control Plan (LTCP)

in place to address

and reduce the

amount of discharged

wastewater.4 The

issue with the LTCP

is they do not really

address water

recycling directly,

only certain parts are

required to have a

fully functional

greywater system

such as a holding

tank, but those are necessary (Conservation Report 2012 on page 27-29)

for bigger scale systems like the skyscraper type residential or commercial buildings. The

average person only uses about 15 water cooler bottles per day, as pictured in the above figure,

and the multifamily buildings use up to 77 gallons per day which is not much, but adds up to be

expensive during storms.CSO water savings usually run in the hundreds of millions of dollars

3 New York State Department of Environmental Conservation. “Potential Reuses of Greywater and Reclaimed Wastewater in New

York State.” November 2010. http://www.dec.ny.gov/about/859.html

4 New York Department of Environmental Conservation. Long Term Control Plan (LTCP) Requirements. 2013.

http://www.dec.ny.gov/chemical/48595.html

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such as the Jamaica Bay CSO High Level Storm Sewer Separation project; which achieves a

savings of $418 million dollars and reduces the discharge by 224 million gallons per year.5 This

shows that any method that can help reduce the overall CSO problem in the future is worth its

costs in taxpayer dollars upfront; particularly since it’s more expensive to fix city scale disasters

versus being proactive. With hundreds of millions of dollars, millions of gallons of potable water

and the health of New Yorkers at stake, greywater and water recycling in general is a new best

practice for every building. Grey water can be utilized by building units and can provide a

combined CSO reduction that the city needs to help comply with the LTCP.

New York City has a lot of great examples of water recycling already within their city

limits. They even have water recycling laws written into code since 2007, even though a number

of large Manhattan buildings were already being developed with different forms of water

recycling prior. The science and the code that has been put into place, which will be discussed

later, has a lot of development, but definitely could use a boost from more recent scientific study

findings and other states code changes. Since there are also alternatives to the current greywater

regulations that even New York State has noticed, then the city should take it upon them to make

changes. Their current regulations are a good start, but water recycling has so much more to offer

that it requires a deeper understanding to create a better future for New Yorkers.

Introduction to Greywater in New York City

When it comes to water recycling greywater is the most prominent resource. Greywater

Action defines greywater as, “water from your bathroom sinks, showers, tubs, and washing

machines. It is not water that has come into contact with feces, either from the toilet or from

washing diapers.”6 What that entails is that greywater comes from almost every drainpipe in your

home, and instead of never seeing it again it will be used it will be repurposed for toilet and

subsurface irrigation systems. The water itself is not safe for consumption and therefore labeled

as non-potable, but it is able to have the secondary uses as described previously. The greywater

itself is actually full of nutrients, due to its pre-usage, and can help by irrigating the landscape.

However, once the greywater is used in the toilet it is considered blackwater, and must be

disposed of in the regular sewage drain pipe. An example of this is in the figure below.

Furthermore, if the water is to be used in conjunction with plants such as fruit trees and

vegetables, sub surface irrigation must be utilized in order to prevent a possible direct

contamination, because it’s still reused water and can be dangerous to ingest afterwards.6 The

best reasons for having greywater installed are to save water in your building and to help irrigate

the landscape and replenish the water table all while saving money on the monthly water bill.

5 Mahoney, Keith. “History of Consent Program and Comparison of 2005 and 2011 Order.” 11/9/2011.

http://www.dec.ny.gov/docs/water_pdf/csomod2011.pdf

6 Greywater Action. February 18, 2013. March 14, 2013. http://greywateraction.org/content/about-greywater-reuse

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If an average residential building/homes have

the normal water and sewage pipe set of connections,

and use the average 80,000 gallons of water per year,

with a family of 4, then the addition of a greywater

system can save them 38,569 gallons per year.7 This

amount of greywater consists of 50-80% of the water

used in a home and the system can be scaled up and

down as necessary because of the ability to use the

normal drainpipes instead of the greywater pipes.8 The

systems themselves consist of pipes leading from the

individual sinks/shower/laundry machines to either one

of two pipes; the sewer pipe or the greywater holding

tank and/or direct irrigation line as seen in the figure on the right. The process starts out with the

installation of either extra pipes for the purpose of direct drainage, or by using a hose/bucket to

siphon/collect the water wherever possible, such as in a sink or tub. The water that drains

through the pipes through the walls of the building and goes down to the basement where it is

either distributed to a single pipe that carries the liquid into a filtration system/holding tank, or it

is directly distributed via hose or subsurface pipe into the ground. If it is a simple drainage

system that directly irrigates the ground then the process ends here, and will only need basic

upkeep to make sure there isn’t any blockage, but if there is a filtration system then it is able to

be pumped back into the house.

The filtration tank, as seen

in the right figure, takes out the

pathogens, the large dirt and hair

clumps, and the chemicals in some

systems, and then transfers the

liquid to a holding tank where it is

dyed blue or green and then

pumped back to the toilet for

reuse. The filtration systems can

range from as little as $100 and go

up to $3000 for full installation,

and when they are more

complicated, they can make the

whole system less efficient

through loss of pressure.6 The key

is to find the right size system for the building. If there a lot of people in a smaller house without

low flow fixtures then there will be a need for a larger system. A good example of the complete

greywater system is the Solaire, which is helping to expand the use of greywater to lower

Manhattan as a best practice.

7 Universal Pumps. March 14, 2013. Copyright 2011. http://www.universalpumps.com.au/grey-water-systems/grey-water-faq.html

8 Oasis Design. Indoor Gray Water Reuse, Cascading, Gray Water Heat Recovery, and Rain Water Harvesting. March 2013. March 15,

2013. http://oasisdesign.net/greywater/indoors/

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The Solaire is a large residential

building in Battery Park City; it contains 293

apartments and is 27 stories tall. The

wastewater that comes from the lavatory

sinks, showers, laundry, and other non

kitchen water fixtures is piped into the

basement where it’s collected and treated.

The subsequent 25,000 gallons per day, that

is an average of 85 gallons per unit per day,

of greywater is then pumped back to the

building to be used as toilet water, air

conditioning makeup water, and as irrigation

water for its greenroof and park. They use

48% less potable water than a building of

^(p60/73-106) similar size such as Tribeca Green Building, and because of the addition 33

of the

low flow faucets and green philosophy they discharge 63% less sewer water per apartment on

average compared to New York City. The pipes

collect both greywater and blackwater, but it can also

switch to potable city water when needed. To help

clean the water, there are multiple processes to filtrate

it included a UV filter, oxidation, and suspended

solids/ phosphorus/ nitrogen removal. The whole

process including New York City’s 25% discount on

reuse reduces the water bill to around 38% of what it

would be normally. The expenses are then collected

through rent. The difference in how the Solaire is able

to do this is because it was built before there were any

major regulations on greywater in New York and

because they got a Non Potable Water Supplier permit

from the NYC Department of Buildings. The

Department of Health and Mental Hygiene

(NYCDOHMH) had to regulate the subsurface

irrigation system and the entire system ran while being intensively monitored for ^ (p60/73-106)

any issues that might surface during normal usage. Then the DEP required them to maintain a

minimum of 25% water savings per year when compared to a similar building.9 An interesting

part of the Solaire is the actual subsurface irrigation. It provides for its small roof garden because

greywater is actually a great way to not only water plants, but also disperse water into the soil

instead of the sewer.

9 Zavoda 2005. Zavoda 2006. The Solaire: http://www.thesolaire.com/

Casa Sustentavel. “The Solaire.” 6/20/2008. 4/12/2013. (p60/73-106) http://eficienciaenergtica.blogspot.com/2008/06/solaire-i.html

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Greywater is 10

>

a great source of nutrients for

vegetation to utilize, and it is

constantly supplied every day

which allows for growth each

week. The soil benefits from

the extra nitrogen and

phosphorus that come from

the many household cleaning

products that are used every

day. When using recycled

water on plants it is important

to make sure the water has the

ability to drain away completely, because if it is allowed to pool it will start to smell, attract

insects, and possibly create a health hazard. The best way to distribute this liquid is via an

underground irrigation such as a drip system, flood irrigation, and a capillary irrigation system as

long as there isn’t any standing water created in the process.11

When there is too much greywater

coming from the house and no plants to help control the inundation, a small wetland or rain

garden could help to remediate and redirect the water away from the home. As previously stated,

with most vegetables, as long as the greywater is not sprayed directly upon the edible part of the

fruit or vegetable, it is possible to prevent direct contamination, and then the garden can remain

safe and productive.12

Greywater is becoming a more

necessary part of sustainable minded business

practices. But, who exactly would want to own

a greywater recycling system? The answers

vary from those who may feel that water is too

precious, too expensive, or maybe just want to

be more sustainable. It lowers the water bill,

can ease a failing septic tank, rejuvenate

topsoil, recharge groundwater, irrigate gardens,

and brings about a sort of awareness and joy in

taking care of the land directly.13

While this

mainly used by someone who is located in a

much drier climate, it does not have to be the only area that has one. The Solaire in New York

City is a wonderful example because it not only is located in a climate where rain and water are

10 Swann, Jessi. The Start of Something Good. “Enjoy the end just as the beginning.” 5/31/2011. 4/12/2013.

http://jswannatkibbutzlotan.blogspot.com/2011_05_01_archive.html

“Connecting the irrigation tubing.” Copyright 2013. 4/12/13. http://greywateraction.org/content/connecting-irrigation-tubing





13 Ludwig, Art. “Why to use grey water; how to choose, build and use grey water reuse systems, regulations, studies, science and

examples.” 2013. March 17, 2013. http://oasisdesign.net/greywater/index.htm

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abundant, but also because they did it for the sake of being more sustainable. The selling point,

however, is the reduction in the water bill each month as it is cut in half permanently. Also since

many states have environmental rebates, grants, and tax abatements related with water recycling

to hand out for taking action, such as New York City’s 25% rebate for green infrastructure from

the DEP, there are a lot of opportunities in which to take part.14

In New York City there are a few buildings that have greywater systems as a part of their

infrastructure. As previously stated the Solaire in Battery Park City is certainly among the more

famous of the East Coast buildings with greywater, and they are forward thinking enough to

continue expanding to their neighboring buildings Laundromats and general park maintenance.

The Helena Building, Goldman Sachs Building, The Visionaire Building, One Bryant Park, and

The Tribeca Green Building, all located in Midtown and Downtown Manhattan, are large

commercial buildings which have some form of greywater toilet flushing, water recycling, or sub

surface irrigation.15

The newest one is the Cooper Union Building which is located in the East

Village of Manhattan, and is a part of a school that is looking to build up its reputation in

sustainability. The school building has already installed renewable energies, so the use of

greywater made sense to them as a means in which to further their green infrastructure prowess.

Another green building to look to is Lehman College’s new LEED Platinum Science Building. It

collects rainwater from the roof as well as greywater from lavatory sinks and then treats them in

the manmade wetland for reuse to flush toilets. Water consumption is displayed to the public in

real time to let everyone know what is going on with the building, whether it is sustainable or

not.16

The buildings in New York City that contain greywater systems are all large and open to

the public in some form. The pattern that arises stems from New York City law on greywater.

New York City Law on Greywater

The current New York City Plumbing Code, PC C101, states:

C101.1 General. Water recycling systems shall receive storm water captured from roofs

and balconies, condensate reclamation systems, gray water discharge only of lavatories

from public restrooms in commercial office buildings, and the treated effluent from an

approved black water treatment system as regulated by Department of Health and Mental

Hygiene. Recycled water shall be utilized only for flushing water closets and urinals,

cooling tower makeup and irrigation systems that are located in the same lot as the water

recycling system. Recycled water shall be considered non-potable. Such systems shall

comply with sections C101.2 through C101.12.

C101.2 Definitions. The following terms shall have the meanings shown herein.

BLACK WATER. Waste water discharged from water closets, urinals and any other

fixtures discharging animal or vegetable matter in suspension or solution.



15 Tnemec. “New York, New York Onward and Upward.”Copyright 2012. March 20, 2013

http://www.tnemec.com/news/NewYorkUpward.aspx

16 Michler, Andrew. “Perkins + Will’s LEED Platinum Lehman College Science Building Nears Completion. 9/30/12. March 18, 2013.

http://inhabitat.com/nyc/perkins-wills-lehman-college-leed-platinum-science-building-nears-completion/

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GRAY WATER. Waste water discharged from lavatories, bathtubs, showers, clothes

washers and laundry sinks.

C101.3 Installation. All drain, waste and vent piping associated with gray or black water

recycling systems shall be installed in full compliance with this code.

C101.4 Reservoir. Water captured for recycling purposes shall be collected in an

approved reservoir constructed of durable, nonabsorbent and corrosion-resistant

materials. The reservoir shall be a closed and gas-tight vessel. Access openings shall be

provided to allow inspection and cleaning of the reservoir interior. The holding capacity

of the reservoir shall be a minimum of twice the volume of water required to meet the

daily flushing requirements of the fixtures supplied with recycled water, but not less than

50 gallons (189 L).

C101.5 Filtration. All water entering the reservoir shall pass through an approved filter

such as a media, sand or diatomaceous earth filter. Filter may be installed in a sidestream

arrangement sized to filter the entire volume of the tank at a rate equal to four times the

recycled water in a one-hour period.

C101.6 Disinfection. Recycled water shall be disinfected by an approved method that

employs ultraviolet or one or more disinfectants such as chlorine, iodine or ozone.

C101.7 Makeup water. Potable water shall be supplied as a source of makeup water for

the recycled water system. The potable water supply shall be protected against backflow

in accordance with Section PC 608. There shall be a full-open valve on the makeup water

supply line to the reservoir.

C101.8 Overflow. The collection reservoir shall be equipped with an overflow pipe of

the same diameter as the influent pipe for the captured water. The overflow shall be

directly connected to the building house drainage system.

C101.9 Drain. A drain shall be located at the lowest point of the collection reservoir and

shall be directly connected to the sanitary drainage system. The drain shall be a minimum

of 4 inch (102 mm) diameter and shall be provided with a full-open valve.

C101.10 Vent required. The reservoir shall be provided with a vent sized in accordance

with Chapter 9 based on the size of the reservoir influent pipe.

C101.11 Coloring. The recycled water shall be dyed blue or green with a food grade

vegetable dye before such water is supplied to the fixtures.

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C101.12 Identification. All recycled water distribution piping and reservoirs shall be

identified as containing non-potable water. Piping identification shall be in accordance

with Section 608.8.17

(p. 192-194)

Notice how greywater is stated, on page 192, to legally be “gray water discharge only of

lavatories from public restrooms in commercial office buildings.”18

The law purposely excludes

residential and industrial buildings. This means that only public restrooms, such as the Cooper

Union, and Lehman College Science Building types are the only ones capable of having this,

because they have the space, the legal backing, and the funds to back it up. The Department of

Buildings Office of Technical Certifications and Research put out a clarifying document to

update its stance on water recycling systems as a 5 phase process of certification, maintenance,

and water quality testing that would take months to complete. The testing wouldn’t actually end,

because it needs to meet a certain health and safety standard. These tests cost money, hundreds to

thousands of dollars annually depending on the size, and could be a problem for most residential

owners to fund.19

Any building considered residential like the Solaire was constructed before the NYC

greywater law came into place. Because people are more likely to spend time in their home

bathrooms than a public bathroom, the laws require monthly testing that can shut down the water

recycling system if it does not meet code. There are no recorded cases of people getting sick and

dying from greywater, and the fact it is dyed blue or green and pumped through purple pipes

would deter most people from trying the already slightly dirty looking water anyway.20

People

who are trying to achieve LEED Platinum or Gold standards, such as the Lehman College

Science Building who used greywater/ wetlands, would most certainly be interested in being

recognized for going the extra mile. Also office buildings that are looking to save up to 40-60%

on their water bills, such as the Solaire, would definitely support an idea that cuts down on bills,

especially ones who use a lot of water on a daily basis. The Solaire was built before the current

greywater laws went into practice, which allowed the units the full use of greywater onsite, but,

sadly, this most likely would not be possible had it been constructed today.

The greywater laws were written to be selective about what building would be allowed to

have greywater because they feel it is a safety hazard. The problem is before the law was

instituted greywater was not addressed yet because it was deemed unimportant. The issue likely

started with some droughts in New York State, and water rationing was instituted in some

counties. People started to build their own greywater systems for their house to help water their

lawns or fields as a back-up system. The current buildings in Manhattan worked with both the

City and State government in order to make sure everything stayed safe. Regulation was deemed

necessary shortly after the Solaire’s construction, but the laws took a step back from what the

building had and stated that only public bathrooms in office or commercial buildings may have

17 New York City Plumbing Code Chapter 1: Administration. PC C101 Water Recycling Systems.

www.nyc.gov/html/dob/downloads/pdf/plumbing_code.pdf


www.nyc.gov/html/dob/downloads/pdf/plumbing_code.pdf 19 Price, Allen. NYC Buildings Department Office of Technical Certification and Research. Buildings Bulletin 2010-027 OTCR. “Water

Recycling Systems.”

20 Design. Indoor Gray Water Reuse, Cascading, Gray Water Heat Recovery, and Rain Water Harvesting. March 2013. March 15,

2013. http://oasisdesign.net/greywater/indoors/

Page | 11

greywater to flush toilets to keep it out of private residences hands. Furthermore, the City

government created a monthly and yearly testing process to make sure the water that was being

reused continued to stay safe, and for some reason made it seem as if greywater needed to be

nearly potable. The problem is greywater is not clean, or potable; that is why it is called

greywater. That is also why it is colored blue/green and pumped through a purple pipe labeled as

non potable. It is good that it is being regulated, but to keep it out of people’s hands through

costs and building use restrictions is a missed opportunity in the long run. The real safety issue

would come from not having enough water to satiate the entire city in case of emergency. The

city is putting a lot on the line safety wise for only three tunnels, and their ever more scrutinized

water sources, in the name of lower pricing. There should be no problem considering how many

years the Solaire/Visionaire/Tribeca Green have allowed its residents to use their greywater to

flush their toilets, and without any incidence or fault since the system water first turned on.

Seeing as there are greywater systems in place, though, they are supported by the New York City

and State through policy and benefits.21

In New York City’s Plan NYC 2030: Water Supply Section, it’s stated that there should

be a safe use of greywater, removal of barriers in building codes, and incentives should be

provided where appropriate. The Implementation section advocates for the development of

comprehensive greywater reuse standards, but it is the only time this is mentioned in the entire

Plan.22

It mentions how the Water Reuse Report, that the State has since produced, will tell what

the State should ultimately do. The State’s report recommended expanded use of greywater with

reduced barriers to access permits for them for everyone, and strongly supports and is refuted by

that statement as well.23

The New York City Green Codes Task Force also made a similar

statement in saying to, “[f]acilitate the use of rainwater and recycled water by tailoring protocols

according to incoming water quality and end use, and expand the permitted uses of such water.”

They even add steam condensate to the list of approved sources of greywater, which could help

expand the usage of other systems such as co-generation which creates both heat and power for a

home. Also a lot of older buildings in NYC use steam radiators, according to the NYC GCTF,

which helps to further expand the usage possibility as well.24

Most interestingly they stated,

The potential for objective decision-making was limited by the absence of testing data on

pathogens that may exist in rainwater (carried from a roof) and may pre-exist in toilets

and urinals. One approach is water quality must be high because people can drop objects

in toilets and, if untreated, pathogens may grow when water sits in storage or toilet tanks.

Another approach is that toilets and urinals are so inherently unclean and pathogen-laden

that rainwater could not cause any appreciable increase in health risk. We should also

avoid the unnecessary addition of chemicals to water that is eventually released into

waterways. Moreover, the city does not require a large number of practices that would

likely have a much more significant impact on the cleanliness of toilets, such as cleaning

toilets and limiting the use of harsh chemicals or chlorine pucks inside toilets.17 25

21 Brooks-Church, Gennaro. Gray Water Use in New York. August 19, 2011. 3/20/13. http://ecobrooklyn.com/gray-water-york/

22 PlaNYC 2011 Full Report. April 2011. 3/20/13. http://www.nyc.gov/html/planyc2030/html/theplan/the-plan.shtml

23 State of New York Department of Environmental Conservation. “A Report for Potential Reuses of Greywater and Reclaimed

Wastewater in New York State.” November 23, 2010. March 20, 2013. www.nyc.gov/html/dep/pdf/waterreuse.pdf

24 Green Codes Task Force. “WE 4: Facilitate Use of Recycled Water.”January 2010. March 20, 2013.

http://www.urbangreencouncil.org/downloadfiles/we4_pdf

25 State of New York Department of Environmental Conservation. “A Report for Potential Reuses of Greywater and Reclaimed

Wastewater in New York State.” November 23, 2010. March 20, 2013. www.nyc.gov/html/dep/pdf/waterreuse.pdf

Page | 12

This is also in support of and refutes the direction this paper is suggesting be taken, but

these sources never directly address the type of building that should be allowed to access the use

of water recycling. They only suggest that the type of uses and that it should expand in general,

which only allows for toilet flushing in a public restroom in a commercial/office building. So,

the overall policy on greywater in the State and City of New York is to expand the uses and type

of recycled water should be included in future law. The current law states that pumping water

from the inside to the outside, or from the roof to the outside is okay, but it cannot go back into

the building or secondary fixture such as a toilet. 12 (p. 192-194)

New York State also has a slightly different take on greywater in their plumbing code

law. The State created the Comprehensive Water Reuse Program in 2004, it has since been

considered for discontinuation in favor of an incentive program for investment purposes, and

over 5 buildings in the City have taken advantage of it since its inception. This savings occurs at

a rate of discounted water based on how much a building saves with greywater or blackwater.

The City is a lot stricter with its water reuse than the State, but it will be required, through the

comprehensive standards set by New York, to comply with future programs, remove barriers,

and establish long term management and maintenance requirements.26

They allow residential

units to have greywater as long as they meet the 25 and 15 gallons per day (gpd) per occupant of

the household depending on the fixture type. Other than that the law is more in depth as to what

the system can be made out of, the engineering/ building standards, and it goes over what

consists of greywater as well.27

This is shown in the figure below with different bars, but notice

how the amount of water that the commercial office buildings use does not compare to

residential buildings. Think if this were to become offset with illegal water recycling systems, it

would have too large an impact compared to the commercial and industrial sectors. New York is

very supportive of new projects involving water recycling, and they are making sure that the

entire State moves towards a more sustainable direction in the future, albeit in a case by case

basis.

New York State has at least 20 different instances of water reusing buildings within its

borders. Many of those are Waste Water Treatment Plants, individual buildings, and golf

courses. These function under the State Pollutant Discharge Elimination System or SPDES,

which helps regulate projects like these on a case by case basis. The waste water treatment plants

such as: Riverhead WWTP, Albany South WWTP, Oneida WWTP, Village of Lake Placid

WWTP, and the Village of Canton WWTP did water recycling to remove certain pollutants and

receive the water rate incentive. The individual buildings introduced greywater into their

plumbing through a combination of the water rate incentive and their overall green philosophy.

These cases show that New York is willing to work hard to create sustainability and foster a

sense of growth towards a more water efficient future for the whole State, no matter how much

water is or isn’t in abundance.28

26 Department of Environmental Protection. “Water Conservation Report: Annual Update.” June 2012. March 20, 2013.

www.nyc.gov/.../dep/.../conservation/water_conservation_report2012

27 International Code Council. “2010 Plumbing Code of New York State. January 2010. March 20, 2013.

http://publicecodes.cyberregs.com/st/ny/st/b900v10/st_ny_st_b900v10_appc_sec001.htm



Page | 13

(Conservation Report 2012, page 29)

Case Study: Arizona as a Best Practice

Arizona is in an incredibly dry area of the United States and thus would consider the idea

and practice of greywater to not only be good for the town sustainably, but also as a necessity

every home should take part in. The grey water laws there were once more limiting, but in

January of 2001, after realizing an incredibly small amount of permits versus greywater systems

illegally being put in place, they changed their policy to allow most residential buildings to

install one with extreme ease. Their change was in the form of the Type 1 General Permit for all

residential units.29

The biggest differences between these NYC and Arizona are that Arizona

houses are more adapted to a dry climate where it is dustier, hotter year round, and receives very

little rain. New York City is surrounded by water, being located on three islands and a peninsula,

and has access to one of the greatest resources for potable water in the world via the

Adirondacks. The biggest difference is in space; Arizona has a lot, New York City does not.

Most people in New York City will not have to clean their cars or water there lawns/gardens all

the time because it rains more, there’s less dust, and potable water is a lot less expensive

regardless for when they do use it. In New York City you will most likely have to travel to see a

truly natural area, while in Arizona land is more rural and suburban. Another big difference is in

the verticality of NYC with its sheer glass and steel walls, and while Arizona has its share of city

space, there just is not the same dense necessity to shove living space upwards. Therefore, when

Arizona put out its three tier permitting system they recognized that the average home wouldn’t

need to use as much water as a 25 story residential housing tower.

29 Ludwig, Art. “Gray Water Policy Center.” Copyright 2013. 3/22/13. http://oasisdesign.net/greywater/law/index.htm#arizona.

Page | 14

The standard/first tier they set with their program was that the residential unit (a house

with up to 5 bedrooms would be allowed according to the law) to only use less than 400 gallons

per day (GPD), and they must use a short list of best practices in order to obtain any permit.

Second tier systems process over 401 GPD, and cannot meet the first tier requirements will

require a standard permit; which has more hoops to jump through in order to obtain a greywater

system. Third tier systems are over 3000 GPD and are permitted on a case by case basis. The

systems are required to meet performance goals, which aren’t specific on purpose, because the

only thing that matters is how well they work in order maintain levels safety.30

The chart below

describes what kind of system is required through the differing scales of water usage.

No. of

Bedrooms

Design

Flow

(gallons

per day)

Minimum Interceptor Size (gallons)

Kitchen Wastewater Only

(All gray water sources are

collected and reused)

Combined Non-Toilet

Wastewater

(Gray water is not

separated and reused)

1 (7 fixture units or

less) 90 42 200

1-2 (greater than 7

fixture units) 180 84 400

3 270 125 600

4 330 150 700

5 380 175 800

6 420 200 900

7 460 225 1000

(http://oasisdesign.net/greywater/law/arizona/index.htm#tierone)

Their three tier system helped to regulate over 50% of new and already built greywater

systems. This is an increase from the almost 0% that took place prior to the passing of these

laws. The best practices laws for greywater were passed readily, and were capable of being

overwritten or updated even easier than the plumbing code itself can. It is even listed in the

Arizona Greywater Brochure for the public to adhere to. Its laws include:

R18-9-711. Type 1 Reclaimed Water General Permit for Gray Water

A. A Type 1 Reclaimed Water General Permit allows private residential direct reuse of

gray water for a flow of less than 400 gallons per day if all the following conditions are

met:

1. Human contact with gray water and soil irrigated by gray water is avoided;


http://www.oasisdesign.net/greywater/law/history/index.htm#blanket

Page | 15

2. Gray water originating from the residence is used and contained within the

property boundary for household gardening, composting, lawn watering, or

landscape irrigation;

3. Surface application of gray water is not used for irrigation of food plants,

except for citrus and nut trees;

4. The gray water does 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;

5. The application of gray water is managed to minimize standing water on the

surface;

6. The gray water system is constructed so that if blockage, plugging, or backup

of the system occurs, gray water can be directed into the sewage collection system

or onsite wastewater treatment and disposal system, as applicable. The gray water

system may include a means of filtration to reduce plugging and extend system

lifetime;

7. Any gray water storage tank is covered to restrict access and to eliminate

habitat for mosquitoes or other vectors;

8. The gray water system is sited outside of a floodway;

9. The gray water system is operated to maintain a minimum vertical separation

distance of at least five feet from the point of gray water application to the top of

the seasonally high groundwater table;

10. For residences using an onsite wastewater treatment facility for black water

treatment and disposal, the use of a gray water system does not change the design,

capacity, or reserve area requirements for the onsite wastewater treatment facility

at the residence, and ensures that the facility can handle the combined black water

and gray water flow if the gray water system fails or is not fully used;

11. Any pressure piping used in a gray water system that may be susceptible to

cross connection with a potable water system clearly indicates that the piping does

not carry potable water;

12. Gray water applied by surface irrigation does not contain water used to wash

diapers or similarly soiled or infectious garments unless the gray water is

disinfected before irrigation; and

13. Surface irrigation by gray water is only by flood or drip irrigation.

B. Prohibitions. The following are prohibited:

1. Gray water use for purposes other than irrigation, and

2. Spray irrigation.

C. Towns, cities, or counties may further limit the use of gray water described in this

Section by rule or ordinance.21

Compared to New York/ City, Arizona’s greywater recycling laws are a lot more open-

ended and readily accessible to the public. Their brochure is easy to obtain off the government’s

website, compared to New York City whose laws need to be found via the City plumbing code in

a relatively unmentioned area. Also the law allows sub surface irrigation for residential,

commercial, and municipal units unlike New York City, which only allows commercial units to

use public toilets and subsurface irrigation. In comparisons it may even seem like NYC is giving

Page | 16

the better deal, but the truth is, they are very limiting on who can use greywater, what system

they use, and how it can be used on the property/building. Arizona allows its permit holders to

return the water to the earth through subsurface or flood irrigation as well, but they only require a

general, and rather easy to obtain, permit for most residential homes. This difference is what

allows for the majority of greywater users to actually consider obtaining the permit instead of

overlooking it and secretly building a possibly hazardous system anyways. 31

The Arizona permit requires performance standards the same as NYC, but theirs doesn’t

also require monthly, yearly, or setup tests that can all prevent the use of the greywater recycling

system. Their system is based in trust, not only in the public, but also for the sustainability of

their environment and society. The permit only really has two requirements to meet before a

greywater systems may be put into a home. These requirements include: that the permit is to be

used for a private resident only, greywater may only be generated and disposed of within the

same property line in a non accessible area, only drip or flood irrigation are allowed, and

greywater flow cannot exceed 400 gallons per day. That is all, and yet it doesn’t require

notification, review, or approval to anyone for any reason. They are purposefully loose with their

laws and regulations to maximize the amount of permits, so that at least everyone can have the

system they would build are the absolute best, meaning safest, they can be.

This kind of trust is put into residential units because there would be no real way to

enforce this kind of ruling anyways, which Arizona Department of Environmental Quality

(AZDEQ) obviously recognizes. The 400 GPD is not an arbitrary maximum, but one that has

been researched to also maximize the amount of permits acquired. Everything AZDEQ is trying

to do is all about safety, awareness, best management practices as a way of best governance, and

the maximization of these systems usage in a place where water is already scarce. Also, there are

no formal permission permits, as long as the 13 best management practices are upheld,

everything is legal. This further puts trust into the public’s hands and drives home the idea that

everyone should take part in having their own greywater system, because their water is not going

to become any cheaper or more abundant in the future with climate change.32


32 Arizona Department of Environmental Quality. “Using Gray Water at Home: Arizona Department of Environmental Quality’s

Guide to Complying with the Type 1 General Permit.” Publication No. C07-01.

Azdeq.gov/environ/water/permits/download/graybro.pdf

Page | 17

33 The best management practices, such as those in the brochures pictured above, of

anything are considered the most up to date scientific and professional methods of doing and

thinking about something. In short it means if you take these steps properly, then the owner and

the government should nothing to worry about. In context with greywater, AZDEQ has listed

thirteen best management practices listed earlier, for everyone to follow. This is also written into

the Plumbing Code, under R18-9-711 Type 1 Reclaimed Water General Permit for Gray Water,

and is accounted for in writing to make sure they meet the minimum government set standards

for how this is to be built, operated, maintained, and in some case dismantled.33

New York City

does not have any best practices listed, nor does it allow for a general non review or approval

needing permit for any residential buildings. They clearly stated public restrooms in commercial

buildings are the only ones who get this, and they must meet the minimum standards set by the

NYC Plumbing Code, which is also at a higher standard than the New York State Plumbing

Code. However, New York City has to comply with the new requirements set forth by the state

which requires it to address water reuse within the next decade. Otherwise the building must

receive a variance from the DOB or DCP to install water recycling systems onsite.

New York City answered this with Local Law 86 in 2005, which states that all projects

that receive City funding must achieve a minimum of 20-30% water use reduction below what

the United States Environmental Protection Agency (EPA) and a Leadership in Energy and

Environmental Design (LEED) silver rating. This requirement can be met with only the

installation of low flow toilets and faucets. It should, however, also promote the 50% reduction

in potable water usage that LEED credits to developers, which would have given greywater reuse

a leg up that it needs.34

Also since Arizona requires less than 400 GPD and the per capita

consumption rate of residential buildings in NYC is all less than 80 GPD as seen in an earlier

figure, it means that greywater is actually feasible for a majority of residential buildings to fall

under anyways. This kind of thinking allowed Arizona to pass its laws to produce what some

consider the best management practice of the USA on greywater. This would not have happened


34 Department of Environmental Protection. “Water Conservation Report: Annual Update.” June 2012. March 20, 2013.

www.nyc.gov/.../dep/.../conservation/water_conservation_report2012

Page | 18

if there were not major organizations helping to not only create the policies, but also use science

to prove greywater is safe for everyone to use.

Water Conservation Alliance of Southern Arizona is an

organization that focused its efforts on greywater and water recycling

for their state. They have been around for more than 14 years,

constantly striving to make sure greywater is safe and effective for

anyone who wishes to use it. They are an amalgamation of many

different groups around Arizona into one bigger force of political

power. Their members include: “Community Water Company of Green

Valley, Flowing Wells Irrigation District, Town of Marana Water

Department, Metropolitan Water Domestic Improvement District,

Town of Oro Valley Water Department, Voyager Water, and their

newest member, Farmers Investment Co.”35

Their services include

political policy advocacy, scientific research, and education. They buy

low flow faucets and aerators in bulk for their members to distribute as well, they build minimal

water use rain gardens, and they distribute educational services and information to anyone who

requests it. 36

In public policy advocacy they have worked on highly meaningful hearings and

committees such as the National Testimony to Improve Water-Use Efficiency and Conservation

in 2007 which helped to shape the USA’s policy towards water recycling. They’ve also done

extensive work on Drought Planning, Revisions for Conservation Regulations, and Arizona’s

Tax Credits for Water Conservation Systems, which helped to make it cheaper and easier to

access and develop greywater systems within the State for residents.37

Water CASA contributed many different forms of scientific research, which stands as

proof for both the Local, State, and National Level that greywater conservation works and is

safe. The Lower Flows (incentive) Program introduced low flush toilets and greywater systems

into 3 neighborhoods in Tucson, AZ. The data from those fixtures was collected over time, and

was used to compare pre and post incentive program implementation to see how successful it is.

The (Evaluation of M&I Water Conservation Measures through Actual Water Savings &

Cost/Benefit Analysis or ECoBA project measures water savings versus the costs set up by

utility services and expenses for the systems, and was successful in convincing many politicians

on the importance of water conservation/reuse. The Residential Greywater Reuse Project they

conducted looked into the health and water quality of greywater systems. They found that there

were no health issues with the quality of water for the residential units, which in turn helped push

AZDEQ to pass the Type 1 General Permit into law. Two other programs measure indoor versus

outdoor water use metering on different types of residential homes. They also developed a web

based portal in which their customers can access and see how much water they are using and

saving with their greywater/water conservation systems in place. They have then used this

35 Water Conservation Alliance of Southern Arizona. The First 14 Years. Copyright 2013. March 25, 2013.

http://www.watercasa.org/about/the-first-14-years/





http://www.watercasa.org/research/ecoba/

Page | 19

information and reached out to every community, person, trade show, organization, politician,

and builder and tried to better educate them on the subject. 38

New York City could do with their

knowledge what Arizona did, and create real change.

New York City doesn’t have an equivalent organization like Water CASA to draw this

kind of information from, but has received a lot of help from their Department of Environment

Conservation as well as universities and individual developments. If the City and/or State would

consider Water CASA’s scientific study on water quality as equal to its own, or if they could use

buildings in Manhattan such as the Solaire, Helena Building, Goldman Sachs Building, The

Visionaire Building, One Bryant Park, and The Tribeca Green Building as testing grounds for

greywater installations.39

There are enough apartments and people that use these buildings to be

able to perform a full sized study. Their various locations around the City also help to make this

case. If it takes this kind of research and data collection to prove greywater is safe in NYC for

residential units then it should be done. There will definitely be ways to fund this study and take

care of the processing of information; even making it a university based study would help push

this into something that is able to bring residential greywater closer to reality.

However, Water CASA did this already, and it helped push Arizona into creating their

current permitting process for residential buildings. This information is already out there as

proof, and other states such as California, Montana, New Mexico, Texas, and Wyoming have

already followed in Arizona’s footsteps by passing similar laws on greywater and residential

usage, meaning this same study that sparked one change inadvertently led to others.40

New York

State/ City should work to understand this information better; some of which was already

produced in their Potential Reuses of Greywater and Reclaimed Wastewater in New York State

report. Arizona’s best management practices and flagship status for greywater was actually

derived from what was going on in California; which is the birthplace of the USA’s greywater

recycling revolution.

Case Study: California as the Historical Context to Greywater and its Similarity to New

York

In 1989, Santa Barbara California passed what would become some of the first greywater

laws in the United States. These laws weren’t perfect and have been improved dramatically from

what they originally were. The county, being the first to start this idea of water recycling in the

US, became one of the drivers for the entire state, even though the number of unpermitted

greywater systems far outweighed the legal ones. They received a letter which asked them to

define greywater as separate from blackwater, so they separated kitchen sinks and certain kinds

of laundry out from the rest of the house’s output. Greywater wasn’t even addressed again until

two years later when five other cities/counties establish their own greywater ordinance. Santa

Barbara publishes a guide on using greywater around this time. The following year California

adopted the Uniform Plumbing Code, but it didn’t allow for greywater. There was a block on the

actual use of greywater, but it was overwritten the following year with the passing of AB3518



39 Tnemec. “New York, New York Onward and Upward.”Copyright 2012. March 20, 2013



Page | 20

which recognized the importance of greywater in its entirety. Later that year greywater laws

were passed in 17 other Uniform Plumbing Code having western states with relative ease.

Greywater started to pick up in Arizona after it was addressed in California on both positive and

negative sides. California state code was then revised to allow other building types to use

greywater for irrigation.41

Years later, in Arizona, greywater policy and law was written in its current form and gave

the freedom and responsibility to the general public to install their systems legally. New Mexico

followed suit two years later with an incredibly similar code and policy, and Texas soon passed

similar codes thereafter. In 2007, California wrongly instituted an older version of the greywater

part of the code which severely limits its ability to be permitted, but it was discovered and

labeled as incorrect which allowed people to follow the previous version instead. Later that year

Montana adopts the international definition of greywater sources which includes kitchen sink

water; they are the first in the US to do so. California, in 2008, lets its government know they

need to address both indoor and outdoor uses of greywater systems. Later on, Nevada adopts the

Arizona style of greywater codes as well.42

California has faced many issues as far as not only how to allow greywater to operate, but

also getting the actual laws passed in order to approve it in the first place. From dealing with anti

greywater activists to facing laws that negate current ones, California has come a long way from

the first days of their greywater laws. The biggest issues they have faced include the simple act

of the amount of time it took to even address everything in the first place. New York City works

in a similar fashion in that about 6 buildings were either developing or already built by the time

the greywater laws were put into place. It takes a long time for the government to address the use

of something new and untested, and erring on the side of safety is always a good practice in

order to avoid any liability issues. The fact is, and California faced this fact directly after the

laws in Arizona were changed, which were tested and reasoned to be safe enough to not worry

about on such a grand scale. 43

There need not be any more time spent worrying about whether or not this will hurt

greywater systems owners on account of the lack of evidence that it will. There are

overwhelming amounts of people who are in favor of greywater being safe as provided by other

states and organizations like Water CASA. The biggest change that came out of California was

born out of the big change in Arizona which in turn was born out of the water recycling

revolution in Santa Barbara. California state government took this into consideration when they

bolstered their current laws because of the loose regulations Arizona and New Mexico allowed

there citizens. New York should also take the rest of the United States decision to allow ease to

obtain permits for residential greywater systems because of the exact same reasons. New York

City has enough problems with waste water becoming combined sewer outflow in their water

body’s to not push this forward, especially with their forward thinking requirements already set

41 Ludwig, Art. “History of Greywater Regulation.”2/2/2009. 3/30/13. http://oasisdesign.net/greywater/law/history/index.htm



Page | 21

in place. When changing California Plumbing Code, New York State/City should consider the

other codes as a step in the process44

California has a rather in depth law on their greywater systems that go down to the

methods of various forms of installation, and the amount of greywater flow per person per day

(40 per person per day). This section is 12 pages alone, but the important information is as

follows:

1601A.0 Graywater Systems – General

(A) Except as otherwise provided for in this chapter, the provisions of this code shall be

applicable to gray water installation. The provisions of this part shall apply to the

construction, alteration, discharge, use, and repair of graywater systems. The graywater

system shall not be connected to any potable water system without an air gap or other

physical device which prevents backflow and shall not cause the ponding or runoff of

graywater. 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.

(B) The type of system shall be determined by the location, discharge capacity, soil type,

and ground water level. The system shall be designed to handle graywater discharged

from the building and may include tank(s) and other appurtenances necessary to ensure

proper function of the system. Note: It is not the intent of this section to require that all

graywater must be handled by an irrigation field or disposal field. It is acceptable for

excess graywater to be diverted to the building sewer through the overflow required

pursuant to Section 1609A.O (E).

(C) No graywater system or part thereof shall be located on any lot other than the lot that

is the site of the building or structure that discharges the graywater, nor shall any

graywater system or part thereof be located at any point having less than the minimum

distances indicated in Table 16A-1. Exception: When there exists a lawfully recorded

perpetual and exclusive covenant to an easement appurtenant and right-of-way between

adjoining land-owners of two or more contiguous lots to discharge graywater from one

lot to an adjoining lot.

(D) No construction permit for any graywater system shall be issued until a plot plan with

appropriate data satisfactory to the Enforcing Agency has been submitted and approved.

When there is insufficient lot area or inappropriate soil conditions to prevent the ponding

or runoff of the graywater, as determined by the Enforcing Agency, no graywater system

shall be allowed. Exception: A construction permit shall not be required for a clothes

washer system which does not require cutting of the existing plumbing piping provided it

is in compliance with Section 1603A.1.1.

(E) All graywater systems shall be designed to allow the user to direct the flow to either

the irrigation or disposal field or the building sewer. The means of changing the direction

of the graywater shall be clearly labeled and readily accessible to the user.


Page | 22

(F) Water used to wash diapers or similarly soiled or infectious garments or other

prohibited contents shall be diverted by the user to the building sewer.

(G) Graywater shall not be used in spray irrigation, allowed to pond or runoff and shall

not be discharged directly into or reach any storm sewer system or any surface body of

water. Certificate of Compliance with Final Express Terms Filed with the Secretary

of State on January 27, 2010 (2007 CPC, Title 24, Part 5, Chapter 16A, Part I –

Nonpotable Water Reuse Systems)

(H) Human contact with graywater or the soil irrigated by graywater shall be minimized

and avoided, except as required to maintain the graywater system. The discharge point of

any graywater irrigation or disposal field shall be covered by at least (2) inches (51 mm)

of mulch, rock, or soil, or a solid shield to minimize the possibility of human contact.

(I) Graywater shall not be used to irrigate root crops or edible parts of food crops that

touch the soil.

1603A.0 Permit

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 clothes washer system which does not require cutting of the existing

plumbing piping provided it is in compliance with Section 1603A.1.1.

1605A.0 Inspection and Testing

(A) Inspection. A graywater system for which a construction permit is required shall be

subject to inspection by the Enforcing Agency and such construction or work shall

remain accessible and exposed for inspection purposes until approved. At the time of

final inspection, 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

upon change of ownership; the new owner shall be notified the structure contains a

graywater system

(B) Testing.

(1) Tanks shall be filled with water to the overflow line prior to and during inspection.

Seams and joints shall be left exposed, and the tank shall remain watertight.

(2) A flow test shall be performed through the system to the point of graywater irrigation

or disposal. Lines and components shall be watertight.

1606A.0 Procedure for Estimating Graywater Discharge

(A) Single Family Dwellings and Multi-Family Dwellings. The graywater discharge for

single family and multi-family dwellings shall be calculated by estimates of graywater

Page | 23

use based on water use records, calculations of local daily per person interior water use,

or the following procedure:

1. The number of occupants of each dwelling unit shall be calculated as follows: First

Bedroom 2 occupants, each additional bedroom 1 occupant

2. The estimated graywater flows of each occupant shall be calculated as follows:

Showers, bathtubs 25 GPD (95 LPD)/occupant and wash basins Laundry 15 GPD (57

LPD)/occupant

3. The total number of occupants shall be multiplied by the applicable estimated

graywater discharge as provided above and the type of fixtures connected to the

graywater system.

(B) Daily Discharge – Graywater systems using tanks shall be designed to minimize the

amount of time graywater is held in the tank and shall be sized to distribute the total

amount of estimated graywater on a daily basis. Exception: Treated graywater systems

when approved by the Enforcing Agency.45

They also allow the indoor use of greywater as long as it follows guidelines and is

inspected and treated properly. The code even intentionally does not label which building may or

may not have it. New York does not hold this policy at all, and does not go into the same form

and depth that California has, even though New York City plumbing code has three different

sections on greywater with many benefits. They do not list out a gallon per day quota, indoor

plumbing with less testing overall, and the California Code is written in a manner that actually is

indicative of creating a greater chance of increasing permits within the state. New York is

definitely not taking this route, and they may end up facing some of the similar illegally created

water recycling systems as California had done inadvertently. This is something that ironically

New York and California share, in that they both are tightly wound around their need to be as far

reaching and complete in their safety and compliance that it feels as if they are asking for people

to choose the non permitted alternative. Permits in both cases require registration, which could

mean people will have their systems looked at in the future. Perhaps both the State/City’s codes

could redirect the registration to come out of failed systems, or through the companies that help

to install them instead of the owners directly, in order to improve compliance rates. Other

methods for improvement in New York City’s Plumbing Code along with discussions as to why

it should be done will be discussed later on in this paper. The biggest changes and/or differences

from New York are not in the code itself, instead it lies within California’s willingness to look at

other surrounding states and consider their alterations as additions to its own. 46

Another force that helped California drive for change in water recycling efforts is an

organization called Water Action. They consist of many of individuals from a variety of

backgrounds coming together to empower people to build sustainable water culture and

infrastructure. “Their teaching tools include interactive models of composting toilets and

greywater systems, theater, and design and installation workshops. With workshops and

presentations, they have educated hundreds of people about the process of greywater system

design and construction, and built greywater systems at dozens of houses in cities around

45 Department of Housing and Community Development. “2007 California Plumbing Code: Nonpotable Water Reuse Systems.”

2/2/2010.

46 Department of Housing and Community Development. “2007 California Plumbing Code: Nonpotable Water Reuse Systems.”

2/2/2010.

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California and beyond.” 47

This organization was started by Laura Allen and

Cleo Woelfle-Erskine back in 1999 and was for the purpose of usage of

greywater within the home. They eventually published an E-magazine

called the “Guerilla Greywater Girls Guide to Greywater” which instructed

people on the proper construction and maintenance and expanded to

workshops and in person community projects that did the same as their

magazine proclaimed. They eventually grew to gain financial backing, and

have since gained more members to help educate and inform people on

greywater systems. 48

This organization, unlike the major science and politically based Water CASA, is

working directly with the residential and commercial owners to educate them on the best

management practices of installing and maintaining a greywater system, even if they may be

illegally unpermitted. They will even help you install one directly within your own home, with

the help of volunteers. Taking the time to help out people who are going to want to do this kind

of work anyways is the bottom up approach that keeps people from possibly making huge

mistakes with their systems that could possibly end up being health hazards for them or the

environment. The information is free, and the organization is more than open about the whole

process from start to finish. They do advocacy work, but their main focus is education for the

general public. Hopefully New York City will gain a group like this in the future to help educate

the many people who will wish to create a greywater system of their own. This will help people

gain the knowledge and confidence to in turn advocate for more open and hopefully “Arizona

like” permit systems. 49

Case Study: Florida as the State with the Most Innovative Water Reuse Strategy

Florida not only allows for greywater for both indoor and outdoor use, but they also allow

anyone to obtain the permit in order to do so. Their plumbing Code actually looks pretty similar

to most other states in the same caliber of greywater use as well, but the main difference comes

from their having the highest reuse rate of water in the USA even though they are not considered

in a dry or drought prone area. The most recent 2010 Florida Plumbing Code is as follows: 50

SECTION C101 GENERAL

C101.1 Scope.

The provisions of this appendix shall govern the materials, design, construction and

47 Greywater Action. About Us: Greywater Action- For a Sustainable Water Culture. March 2013. March 31, 2013.

http://greywateraction.org/content/about-us





50 2010 Florida Building Code: First Printing. “Appendix C – Gray Water Recycling Systems.” January 2010. 4/2/13.

http://ecodes.cyberregs.com/cgi-

exe/cpage.dll?pg=x&rp=/indx/ST/fl/st/b900v10/st_fl_st_b900v10_appc.htm&sid=2013040211454252391&aph=0&cid=iccf&uid=iccf

0002&clrA=005596&clrV=005596&clrX=005596&ref=/nonindx/ST/fl/st/b900v10/index.htm

Page | 25

installation of gray water systems for flushing of water closets and urinals and for

subsurface landscape irrigation (see Figure 1).

C101.2 Definition

The following term shall have the meaning shown herein.

GRAY WATER

As defined by 381.0065(2) (b) and (d) Florida Statutes, "Graywater” means that part of

domestic sewage that is not blackwater, including waste from the bath, lavatory, laundry,

and sink, except kitchen sink waste. "Blackwater” means that part of domestic sewage

carried off by toilets, urinals, and kitchen drains.

C101.3 Permits Permits shall be required in accordance with Section 105 of the Florida Building Code,

Building.

C101.4 Installation In addition to the provisions of Section C101, systems for flushing of water closets and

urinals shall comply with Section C102. Except as provided for in Appendix C, all

systems shall comply with the provisions of the Florida Building Code, Plumbing.

C101.5 Materials

Above-ground drain, waste and vent piping for gray water systems shall conform to one

of the standards listed in Table 702.1. Gray water underground building drainage and

vent pipe shall conform to one of the standards listed in Table 702.2.

C101.6 Tests Drain, waste and vent piping for gray water systems shall be tested in accordance with

Section 312.

C101.7 Inspections Gray water systems shall be inspected in accordance with Section 110 of the Florida

Building Code, Building.

C101.8 Potable water connections Only connections in accordance with Section C102.3 shall be made between a gray water

recycling system and a potable water system.

C101.9 Waste water connections Gray water recycling systems shall receive only the waste discharge of bathtubs, showers,

lavatories, clothes washers or laundry trays.

C101.10 Collection reservoir Gray water shall be collected in an approved reservoir constructed of durable,

nonabsorbent and corrosion-resistant materials. The reservoir shall be a closed and gas-

tight vessel. Access openings shall be provided to allow inspection and cleaning of the

Page | 26

reservoir interior.

C101.11 Filtration Gray water entering the reservoir shall pass through an approved filter such as a media,

sand or diatomaceous earth filter.

C101.11.1 Required Valve

A full-open valve shall be installed downstream of the last fixture connection to the gray

water discharge pipe before entering the required filter.

C101.12 Overflow

The collection reservoir shall be equipped with an overflow pipe having the same or

larger diameter as the influent pipe for the gray water. The overflow pipe shall be trapped

and shall be indirectly connected to the sanitary drainage system.

C101.13 Drain A drain shall be located at the lowest point of the collection reservoir and shall be

indirectly connected to the sanitary drainage system. The drain shall be the same diameter

as the overflow pipe required in Section C101.12.

C101.14 Vent required

The reservoir shall be provided with a vent sized in accordance with Chapter 9 and based

on the diameter of the reservoir influent pipe.

SECTION C102 SYSTEMS FOR FLUSHING WATER CLOSETS AND URINALS

C102.1 Collection reservoir

The holding capacity of the reservoir shall be a minimum of twice the volume of water

required to meet the daily flushing requirements of the fixtures supplied with gray water,

but not less than 50 gallons (189 L). The reservoir shall be sized to limit the retention

time of gray water to a maximum of 72 hours.

C102.2 Disinfection

Gray water shall be disinfected by an approved method that employs one or more

disinfectants such as chlorine, iodine or ozone that are recommended for use with the

pipes, fittings and equipment by the manufacturer of the pipes, fittings and equipment.

C102.3 Makeup water Potable water shall be supplied as a source of makeup water for the gray water system.

The potable water supply shall be protected against backflow in accordance with Section

608. There shall be a full-open valve located on the makeup water supply line to the

collection reservoir.

C102.4 Coloring The gray water shall be dyed blue or green with a food grade vegetable dye before such

water is supplied to the fixtures.

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C102.5 Materials Distribution piping shall conform to one of the standards listed in Table 605.3.

C102.6 Identification

Distribution piping and reservoirs shall be identified as containing nonpotable water.

Piping identification shall be in accordance with Section 608.8.

SECTION C103 SUBSURFACE LANDSCAPE IRRIGATION SYSTEMS

RESERVED 51

They are different from New York City first and foremost because they do not mind which

building recycles its water. They require every system to be fully permitted, inspected, and approved of

by the government, no matter how small or large. That makes the majority of the water recycling

section actually similar to NYC in function and law right down to the purple pipes and dyed

water. How Florida views water reuse actually stems from their policy and business acumen

towards greywater.52

Florida has taken into consideration many different areas of water reuse and conservation

from residential, to industrial, and even commercial uses. These fall under the irrigation and

toilet flushing as well as composting and rainwater collection. While some other states may not

have greywater defined yet, Florida already set up an award winning water reuse plan that helps

them make money and save countless gallons per year. They have 16 strategies to help promote

greywater use as a resource to be taken into contemplation including ones such as:

1. Encourage metering and volume-based rate structures.

2. Implement viable funding programs.

3. Facilitate seasonal reclaimed water storage (including aquifer storage and recovery).

4. Encourage use of reclaimed water in lieu of other water sources in the agricultural

irrigation, landscape irrigation, industrial/commercial/institutional, and indoor water use

sectors.

5. Link reuse to regional water supply planning (including integrated water resource

planning).

6. Develop integrated water education programs.

7. Encourage ground water recharge and indirect potable reuse.

8. Discourage effluent disposal.

9. Provide water use permitting incentives for utilities that implement reuse programs.

10. Encourage reuse in Southeast Florida.

11. Encourage use of supplemental water supplies.

12. Encourage efficient irrigation practices.

13. Encourage reuse system interconnects.

14. Enable redirecting of existing reuse systems to more desirable reuse options.




0002&clrA=005596&clrV=005596&clrX=005596&ref=/nonindx/ST/fl/st/b900v10/index.htm\




0002&clrA=005596&clrV=005596&clrX=005596&ref=/nonindx/ST/fl/st/b900v10/index.htm

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15. Use reclaimed water at government facilities.

16. Ensure continued safety of water reuse.53

While these sound like they are just starting points, it is still growing throughout the state as

more counties and cities adopt the strategy. Florida also addressed a number of legislative,

rulemaking, and research strategies that help shape their water recycling prowess. Today Florida

has the highest water recycling rates in the entire country, of which the different uses can be seen

in the figures below, and they have a water reuse system that sells treated greywater back to its

citizens for irrigation uses.28

(http://www.dep.state.fl.us/water/reuse/activity.htm)

Different cities within the state are taking full advantage of water reuse by promoting

installation with money, and in the case of St. Petersburg and Miami, charging for the use of it.

They actively encourage and pipe the used water back to buildings after treating it for outdoor

irrigation use. The rates are charged in a per acre basis. In St. Petersburg they built the world’s

first wastewater recycling system which, “[. . .] provides more than 37 million gallons per day to

over 10,600 customers primarily for lawn irrigation.”54

This program started construction in the

1970’s and after around 16 years of testing, it helped to influence the rest of Florida to change its

standards to allow everyone to use the system, including residential units. They lowered their

potable drinking rates, but grew their greywater rates significantly, all while still making money

back. The water itself is good for irrigation because it contains, “aluminum, chromium, lead,

molybdenum, zinc, phosphorus, boron, copper, zinc, magnesium, nickel, calcium, iron,

53 Reuse Coordinating Committee and the Water Conservation Initiative Water Reuse Work Group. “Water Reuse for Florida:

Strategies for Effective Use of Reclaimed Water.” June 2003. www.dep.state.fl.us/water/reuse/docs/valued_resource_FinalReport.pdf

54 Water Resources Department Reclaimed Water Division. “Reclaimed Water.” Copyright 2013. 4/4/13.

http://www.stpete.org/water/reclaimed_water/index.asp

http://www.stpete.org/water/wwater_collection_and_maintenance.asp

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manganese, potassium and nitrogen.”55

This also prevents its usage as potable water, but with a

new or existing irrigation system in place anyone can use it. They even provide the proper hose

or sprinkler systems if need be. It takes 6 wastewater users to generate the 30,000 gallons of

wastewater per month necessary for watering a common residential lawn which means it is

impossible to irrigate everyone’s property year round. They devised a system of even and odd

days in which people are allowed to use their waste water systems instead. St. Petersburg is

thorough on taking care of these systems, provides multiple tips for maintenance, and ways to

contact the city if there are any problems with the systems. New York City could benefit greatly

by having this system in place.56

Their savings rates can be seen in the figure below.

Household Water Use and Potential Savings

(gallons per person per day)

Results of Residential End Use Study, Water Wiser 1999.

Water Use Without

Conservation

With Conservation Savings

Toilets 20.1 9.6 10.5

Showers 12.6 10.0 2.6

Baths 1.2 1.2 0

Faucets 11.1 10.8 0.3

Clothes Washers 15.1 10.6 4.5

Dishwashers 1.0 1.0 0

Leaks 10.0 5.0 5

Other Indoor Uses 1.5 1.5 0

Indoor Total 72.6 49.7 22.9

(http://www.stpete.org/water/water_conservation/index.asp)

With the mandatory CSO reduction in place, New York City needs a way to minimize

their outflow. By taking wastewater and repackaging it as a useful product they can not only

avoid polluting waterways, but also extend their service with a new source of income. Since the

city is large, but most lots are small, there would need to be a study done to determine the best

way to charge for the use of this waste water, including the possibility of increasing water bill

prices. Great places to use it would be in City Parks, Privately Owned Public Spaces,

Greenroofs, Rooftop farms, community gardens, farmland, and maybe even consider exporting

some of it to long island through Queens for both of their extensive residential neighborhoods

and cemeteries. The idea is to generate whatever money is lost from potable water use back from

greywater use, and since most of the greywater using buildings in New York City have indoor

toilet flushing then it makes sense to include indoor usage as well. Florida runs off of ground

water, about 90% of public water is groundwater based, but NYC pipes water from upstate.

Groundwater can create more of a need for recycling, yet there only need be three damaged pipes


http://www.stpete.org/water/reclaimed_water/index.asp http://www.stpete.org/water/wwater_collection_and_maintenance.asp



Page | 30

to put the City in a severe crisis. Recycling water is not a question of how to do it, but of when to

start taking action.57

Policy Recommendation for Breaking down Policy Barriers to Residential Greywater

The current policy on greywater in New York City is that it is accepted, but due to safety

concerns it is actually a highly restricted process. The only buildings that allow this are

commercial buildings and the few residential towers that managed to develop before the law was

fully in place. With multiple state and city and non-governmental organization reports all aiming

to push for expanded usage of water recycling systems there is more than enough support to

create the changes necessary. Yet, because of the various City agencies inner workings, and slow

process to address the subject, this is being prevented. The issue rests within the mindset behind

New York City’s water; it is extremely abundant, clean, and will stay that way for the

foreseeable future. Water recycling was incorrectly defined as a safety problem which has lead to

the wrong solution. By putting security before knowledge the City is preventing a grand

opportunity to keep them safer in the long run. They could be protected from drought, pollution,

and even save money/budgets if they would look at water recycling differently.

New York City should start working with developers and other organizations to generate

a plan of action for water recycling. The City has already worked to promote rain barrels for

homes, but that will never have the direct impact that greywater has going for it.58

New York

City should embrace greywater recycling systems, both indoors and out, for all buildings. The

laws need to be altered further in order to allow more users. Although New York City has an

abundance of water; it still has issues with combined sewer overflows and an overall lack of any

form of water recycling from their end. This could be addressed by amending the current

plumbing code and possible building code policy and allowing residential building/ home owners

take action and are able to safely, inexpensively, and correctly install a greywater system for

their toilets and gardens. The plumbing code would need to be updated to follow other States

footsteps such as Arizona and California who were both in the same position as New York at one

point by not allowing greywater on a grand scale even though private owners were still installing

them illegally. With each of its strengths, weaknesses, opportunities, and threats cultivate a

chance for revolutionizing New York City.

Strengths of greywater include a variety of environmental, economical, and sociological

benefits. Passing new legislation which allows all buildings to easily and officially install lowers

the chance for illegal systems being put into homes and buildings. It is a long term investment

that could be brought into the mainstream and given the attention water recycling issues deserve.

This attention would help benefit the environment by sparking ideas on how to better save and

use water on an everyday basis. Also greywater will help make a case for financial assistance

from private and governmental entities for developers and individuals by encouraging long term

savings and resiliency. Greywater has a lot of monetary savings with buildings that can save

around 40-60% on their water bills. Being able to comply with the federal mandate for NYC to

reduce their CSO’s also manages to not only make the City look good environmentally, but

57

Water Resources Department Reclaimed Water Division. “Reclaimed Water.” Copyright 2013. 4/4/13.




Page | 31

become a guiding force for other non drought prone cities to take action as well which in turn

brings more money to the government through direct and indirect means.

Weaknesses of greywater have to deal with an already built environment and the actual

expenses it takes to pay for them. Each system is still relatively expensive to install, as stated by

oasis design earlier about $100 - $3000, and will still require testing for larger buildings. General

plumbers might not know how to fix greywater storage tanks or certain pump systems. It will

require a lot of government cooperation to pass a change in plumbing code because of the

“safety” issue.

Opportunities for greywater exist in many forms, whether through support or funding

there are a lot of ways to help spread the idea/system. Greywater can help lower the chance for a

combined sewer overflow and increase the amount of home grown garden foods. Water is

always a hot topic for debate. There are interested parties, Water Action/ Eco Brooklyn/ other

local all the way up to the developers, looking to change greywater laws. Hurricane Sandy has

brought the issue of resiliency to the table; of which greywater would definitely help make a

building more islandable in case of emergency.

Threats exist many forms of threats to greywater systems, most of which reside within

the governmental system. This requires multiple city agencies to agree upon a change in the

current code. Department of Buildings may have the main control over the City Plumbing Code,

but they are also bound by the rules of Department of Environmental Protection and Department

of Health and Mental Hygiene (DOHMH) and tend not to do anything without their input if it

can become a health problem. The DOHMH does not have direct control over the use of

greywater; however their role allows them to prevent its implementation due to the possible, but

grossly overestimated, health concerns. The DEP is in charge of the environment and natural

resources of New York City; which is why it has domain over water albeit from the supply and

disposal end. Further, the DEP has dominion on the outdoor use of greywater, but the laws that

are put in place already address most of the issues they would have with greywater regardless,

even though they are also beholden unto the DOHMH. From the supply end, the DEP also

wouldn’t want to have too much reuse because that may mean less income from their distribution

of water to the public. These agencies all claim a general lack of safety currently and don’t

communicate very well between themselves. They also tend to resolve by putting the subject off

for the future or saying it is just easier to keep the code to its current status. However, all of these

threats can be overtaken by the simple fact that any of the opportunities and strengths can

overturn any of the threats if considered too great a benefit to consider.

New York City should incorporate a “best of” combination of California, Arizona, and

Florida’s laws on greywater into an updated Plumbing Code through the DOB OTCR. One of

these best parts includes Arizona’s three tier system and Phase 1 General Permits for anyone

under 400 gpd, which would still be fine for most residential buildings in NYC. The California

way of thinking is what should be adopted in the form of not being afraid to pioneer and review

other states work, especially scientific data, and adapt it for personalized policy/law. Since

Florida has the most water recycling of any state, by far, New York City should adopt their

allowing anyone to receive a permit, and in the future put in infrastructure or develop a way for

greywater to be piped by to customers so they may use it again, and be charged for it at a

reduced rate. Also NYC should adopt the funding strategies of each of these states to benefit the

most people. With these laws and policies combined into the most innovative plumbing code in

Page | 32

the US, there can be a new revolution for residential unit owners and developers who are looking

to be sustainable and savvy with their money. To do this the Plumbing Code would need to be

changed to resemble these three aforementioned states.

The Code should be updated to look more like this:

C101.1 General. Water recycling systems shall receive storm water captured from roofs

and balconies, condensate reclamation systems, gray water discharge only of lavatories

from public restrooms in commercial office buildings, and the treated effluent from an

approved black water treatment system as regulated by Department of Health and Mental

Hygiene. Recycled water shall be utilized only for flushing water closets and urinals,

cooling tower makeup and irrigation systems that are located in the same lot as the water

recycling system. Recycled water shall be considered non-potable. Such systems shall

comply with sections C101.2 through C101.12.

A. A Type 1 Reclaimed Water General Permit allows private residential direct reuse of

gray water for a flow of less than 800 gallons per day if all the following conditions are

met:

1. Human contact with gray water and soil irrigated by gray water is avoided;

2. Gray water originating from the residence is used and contained within the

property boundary for household gardening, composting, lawn watering, or

landscape irrigation;

3. Surface application of gray water is not used for irrigation of food plants,

except for citrus and nut trees;

4. The gray water does 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;

5. The application of gray water is managed to minimize standing water on the

surface;

6. The gray water system is constructed so that if blockage, plugging, or backup

of the system occurs, gray water can be directed into the sewage collection system

or onsite wastewater treatment and disposal system, as applicable. The gray water

system may include a means of filtration to reduce plugging and extend system

lifetime;

7. Any gray water storage tank is covered to restrict access and to eliminate

habitat for mosquitoes or other vectors;

8. The gray water system is sited outside of a floodway;

9. The gray water system is operated to maintain a minimum vertical separation

distance of at least five feet from the point of gray water application to the top of

the seasonally high groundwater table;

10. For residences using an onsite wastewater treatment facility for black water

treatment and disposal, the use of a gray water system does not change the design,

capacity, or reserve area requirements for the onsite wastewater treatment facility

at the residence, and ensures that the facility can handle the combined black water

and gray water flow if the gray water system fails or is not fully used;

Page | 33

11. Any pressure piping used in a gray water system that may be susceptible to

cross connection with a potable water system clearly indicates that the piping does

not carry potable water;

12. Gray water applied by surface irrigation does not contain water used to wash

diapers or similarly soiled or infectious garments unless the gray water is

disinfected before irrigation; and

13. Surface irrigation by gray water is only by flood or drip irrigation.21

B. A Type 2 Reclaimed Water General Permit allows a gray water irrigation system if

1. The general permit described in C101.2A does not apply,

2. The flow is not more than 3000 gallons per day, and

3. The gray water system satisfies the notification, design, and installation

requirements specified in subsection (B).

C. A Type 3 Reclaimed Water General Permit allows a gray water irrigation system if:

1. The general permit described in C101.2B does not apply,

2. The flow is more than 3000 gallons per day, and

3. The gray water system satisfies the notification, design, and installation

requirements specified in subsection (C).

4. The notification shall be determined on a case by case basis under the

regulations set by subsection (D)

B. A person shall file a Notice of Intent to Operate a Gray Water Irrigation System with

the Department at least 90 days before the date the proposed activity will start. The

Notice of Intent to Operate shall include:

1. The name, address, and telephone number of the applicant;

2. The social security number of the applicant, if the applicant is an individual;

3. A legal description of the direct reuse site, including latitude and longitude

coordinates;

4. The design plans for the gray water irrigation system;

5. A signature on the Notice of Intent to Operate certifying that the applicant

agrees to comply with the requirements of this Article and the terms of this

Reclaimed Water General Permit; and

Page | 34

6. The applicable permit fee specified under C103.

C. The following technical requirements apply to the design and installation of a gray

water irrigation system allowed under this Reclaimed Water General Permit:

1. Design of the gray water irrigation system shall meet the onsite wastewater

treatment facility requirements, except the septic tank is not required if

pretreatment of gray water is not necessary for the intended application;

2. Design of the dispersal trenches for the gray water irrigation system shall meet

the onsite wastewater treatment facility requirements for shallow trenches

specified in C102;

3. The depth of the gray water dispersal trenches shall be appropriate for the

intended irrigation use but not more than 5 feet below the finished grade of the

native soil; and

4. The void space volume of the aggregate fill in the gray water dispersal trench

below the bottom of the distribution pipe shall have enough capacity to contain

two days of gray water at the design flow.

D. The Department may review design plans and details and accept a gray water

irrigation system that differs from the requirements specified in subsection (C) if the

system provides equivalent performance and protection of human health and water

quality.21

C101.2 Definitions. The following terms shall have the meanings shown herein.

BLACK WATER. Waste water discharged from water closets, urinals and any other

fixtures discharging animal or vegetable matter in suspension or solution.

GRAY WATER. Waste water discharged from lavatories, bathtubs, showers, clothes

washers and laundry sinks.

C101.3 Installation. All drain, waste and vent piping associated with gray or black water

recycling systems shall be installed in full compliance with this code.

C101.4 Reservoir. Water captured for recycling purposes shall be collected in an

approved reservoir constructed of durable, nonabsorbent and corrosion-resistant

materials. The reservoir shall be a closed and gas-tight vessel. Access openings shall be

provided to allow inspection and cleaning of the reservoir interior. The holding capacity

of the reservoir shall be a minimum of twice the volume of water required to meet the

daily flushing requirements of the fixtures supplied with recycled water, but not less than

50 gallons (189 L).

Page | 35

C101.5 Filtration. All water entering the reservoir shall pass through an approved filter

such as a media, sand or diatomaceous earth filter. Filter may be installed in a sidestream

arrangement sized to filter the entire volume of the tank at a rate equal to four times the

recycled water in a one-hour period.

C101.6 Disinfection. Recycled water shall be disinfected by an approved method that

employs ultraviolet or one or more disinfectants such as chlorine, iodine or ozone.

C101.7 Makeup water. Potable water shall be supplied as a source of makeup water for

the recycled water system. The potable water supply shall be protected against backflow

in accordance with Section PC 608. There shall be a full-open valve on the makeup water

supply line to the reservoir.

C101.8 Overflow. The collection reservoir shall be equipped with an overflow pipe of

the same diameter as the influent pipe for the captured water. The overflow shall be

directly connected to the building house drainage system.

C101.9 Drain. A drain shall be located at the lowest point of the collection reservoir and

shall be directly connected to the sanitary drainage system. The drain shall be a minimum

of 4 inch (102 mm) diameter and shall be provided with a full-open valve.

C101.10 Vent required. The reservoir shall be provided with a vent sized in accordance

with Chapter 9 based on the size of the reservoir influent pipe.

C101.11 Coloring. The recycled water shall be dyed blue or green with a food grade

vegetable dye before such water is supplied to the fixtures.

C101.12 Identification. All recycled water distribution piping and reservoirs shall be

identified as containing non-potable water. Piping identification shall be in accordance

with Section 608.8.59

(p. 192-194)

This could work for everyone because it keeps the bigger water users in check, such as

industrial and large commercial buildings with a lot of water needs, but will help the residential

buildings cut back, and aim to lower their water usage to obtain the type 1 permit. Perhaps by

setting up a goal for individual metering for buildings with the capability to speed permits and

other paperwork if they maintain these water standards and then increase their savings by adding

tax rebates for the greywater reuse in gallons each year. The government could take heed of the

multiple papers and projects conducted by organizations, state departments, and private

consultants into account. California has done this to benefit their citizens given that there has yet

to be a case where greywater has caused any harm on anyone in the USA. Since the CSO’s are

being dealt with, greywater reuse pipes could be put into the ground, when the pipes are being

replaced anyways due to old age, as a secondary use of waste water. As long as the pipes go back

to the waste water treatment plants they could fully meter the usage of greywater for each



Page | 36

building. Other revolutionizing areas would be to give wider encompassing funds for the

installation of these systems based on gallons saved. A state and city funding system could be

put in place with the aim to offset the amount they would need to pay for the environmental

damage done by CSO’s and non compliance with the federal mandate to reduce them. This

would only be able to be furthered by the use of good policy from a government who is willing

to listen.

There are multiple reports discussed earlier that go over how to best attack the issue of

not having enough greywater in the city. By fully understanding what they wrote to the city and

State there could only be benefits in the short and long run, even if some of them do not advocate

to the level this paper does. For the current buildings, they should extend the current water

savings that were planned on being eliminated and allow for an additional percentage off their

current water bill on grounds that they continue usage and begin to promote greywater to other

buildings as well. For new developments, more weight could be emphasized in the AASHRAE

and LEED rating systems to help the developers take the costs and realize the benefits of saving

about 40 – 60% on a water bill is worth it.60

Good policy from the government will help to benefit everyone as well. There doesn’t

seem to be too great of a mention of greywater anywhere useful to the public on any government

website in New York City. The policy that would help people the most is the open promotion

from the DEP, DOB, DOHMH, and especially the Mayor. They could each accept the overall

policy that it is better to allow for greywater for New York water bodies as well as the

groundwater within these islands. Specific policies could include a bigger part within PlaNYC

2030, which would be visible to everyone including the goal makers of other departments.

Another area to include the policy would actually take a step above the city level and put it in the

State’s hands with their Department of Environmental Conservation, and then hand it down as

mandate to NYC. Overall, it would take time, a lot of education, and some good marketing to put

greywater systems on par with energy savings and building efficiency, but if it is given the

respect it deserves, it will become integrated with them as well.

As a second, third, and fourth provision Arizona, New Mexico, and Florida plumbing

codes should be taken into consideration in their entirety for a variety of reasons, but mainly

because they are definitely a step farther in the right direction. Arizona allows greywater from a

majority of residential units and because of this they have a higher permit rate than other states.

This kind of thinking would not only help the irrigation to recharge the groundwater, but opens

these systems up to a larger number of New Yorkers. The New Mexico Plumbing Code is similar

to the Arizona one because they used it as the template and therefore would provide the same

benefits and costs with their code. Florida’s Plumbing Code takes a different approach to

greywater in that they are wholly accepting of everyone having it, but they need to go through an

official review and testing process much the same as New York City does. Florida also took it

upon them to create the infrastructure necessary to help not only create funding for greywater

use, but also to create and encourage a mind-set centered on it. That base function of changing

the way people think is almost more important than the funding for greywater because it creates

a demand where there was not one before. These sources of inspiration can also help to bring

New York City into the new generation of water based sustainable directives for widespread use.

60 Zavoda 2005. Zavoda 2006. The Solaire: http://www.thesolaire.com

Page | 37

Conclusion:

With the passing of these laws, a new thought process could take place that could end up

generating a real form of water recycling revolution in an area that has abundance of it. The

residential home owners and developers would turn to water recycling as a means of lowering

their bills, all while helping to reduce water use and lowering the chance for CSO’s during

storms. Residential home owners could now be proud owners of their own greywater systems.

This would inadvertently push them to use cleaner products in their home, and cause them to

think twice before putting anything down their pipes. The CSO’s themselves would be reduced

because a lot of irrigation and greywater/flushing would reduce or detain the overall amount of

water from within the sewers, and help the City comply with their federal mandate. The

developers and building owners would receive money for their installing of new water recycling

systems for a number of years until it would be deemed either no longer necessary, or only

necessary for low income persons and organizations. The DEP would still generate money after

they install the greywater reuse pipes from the WWTP’s. Using this system they push forward

with other ways to generate monetary gains from other sources they haven’t previously looked at

thanks to this. New York State, the rest of the United States, and even the world would be able to

look to New York City as a beacon of sustainable water usage. This will drive people to their

government and organizations for answers, benefitting everyone in the City overall. The

greywater revolution is coming with a new way to view sustainable water usage that society will

refocus around, and this will help drive New York City into a safer and more resilient way of

life.

Page | 38

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