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15-Day Notice and ET (2007 CPC "Graywater Emergency" and 2010 CPC) |
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Written by Editor •
Tuesday, 24 November 2009 19:40
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To: Graywater Stakeholders
As most of you are aware, the two 45-day public comment periods for the graywater regulations closed in mid-October. The Department of Housing and Community Development (HCD) received numerous comments. We have completed our evaluation of all comments received and, as a result, we believe some modifications are necessary. Our intent is to keep the changes to a minimum. It is anticipated that the proposed revisions will be made public beginning November 25, 2009.
The rulemaking process allows us to make modifications that are substantially related to our original proposal provided the revisions are then vetted in a 15-day public comment period. The time between the closing of the 15-day comment period and the time HCD must submit its final package to the California Building Standards Commission (CBSC) in order to make the January 2010 agenda is very short.
We believe that the regulations developed during our focus group meetings are very progressive and will serve to promote and encourage the legal use of graywater in the future. During the CBSC meeting, we heard very galvanized and pointed concerns about permit exemptions. Fortunately, we prevailed and HCD's regulations were approved as an emergency for 180 days. During the 45-day public comment period, which is a necessary part of the process to make the approved emergency regulations permanent, we received additional and expanded comments regarding the permit exemption.
Due to strong opposition, we are concerned that we will not be successful getting the regulations in place on a permanent basis. If the regulations are not made permanent, they will expire the first week of February 2010, and all the work done will be lost.
Basically, HCD would need to start over.
Currently, we feel the risk of losing the complete rulemaking package outweighs the gain in keeping the entire permit exemption; therefore, HCD is proposing a modification to exclude the single fixture systems from the permit exemption. Our proposal will continue to include an exemption for a clothes washer system, provided the existing plumbing is not cut, and all of the other beneficial amendments submitted in the code.
Attached please find the "15-Day Notice of Post-Hearing Modifications" and Revised Express Terms HCD is proposing for both the emergency (2007 CPC) and regular (2010 CPC) rulemaking packages, which are identical. For your convenience, the documents are being forwarded in both PDF and Word.
Please be assured that HCD will continue to think progressively; however, at this time, we believe this is the most prudent choice in order to preserve all of the hard work that has gone into this project. While we understand that some of you may be disappointed, keep in mind that these regulations represent the foundation upon which we hope to build and expand in the future, with your knowledge and input.
Sincerely,
Doug Hensel
Assistant Deputy Director
California Department of
Housing and Community Development
Division of Codes and Standards
(916)445-9471 ~ fax: (916)327-4712
This e-mail address is being protected from spambots. You need JavaScript enabled to view it
15-Day_Notice_and_Emerg_ET_11-09.pdf
15-Day_Notice_and_2010_ET_11-09.pdf
NOTICE_15-Day_Emerg__11-09.doc
NOTICE_15-Day_2010_CPC__11-09.doc
ET_15-Day_Emerg_11-09.doc
ET_15-Day_2010_CPC_11-09.doc
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