Calhouns Can(n)ons

Onsite Wastewater Treatment Info – a must read for Denizens of Sewerville

This is a long piece, but well worth the time to read it for those in Los Osos (and anywhere else, for that matter) who are interested in advanced “onsite” septic treatment systems. Since AB885 is making it’s way into law, ANYONE in this county on a septic system and within hailing distance of an “impaired” watershed (just about the whole state, the way things are going) needs to be aware of changing regulations. With the passage of AB885, they will come under the gun of their Regional Water Quality Control Boards.

For those living within the prohibition zone of Los Osos who are thinking about investing in individual, advanced onsite systems, this is a must read. Until AB885 comes on line, I suspect it will be impossible to get any information or clear direction from our local RWQCB vis a vis the “legal” status of these systems within the prohibition zone.. I have asked our local Board staff and get tautology or no answers back. I have sent an inquiry up to the State Water Board staff and, to date, have received no answer either.

So, before anyone goes galloping off on an On Site System Scheme, I would recommend reading the following:



OFFSITE
with the Waterguy

by David Venhuizen, P.E.


Who Can We Trust?

A while back, a colleague asked for my thoughts on arrangements for managing on-lot systems that provide enhanced pretreatment prior to dispersal. These are becoming increasingly common in his jurisdiction to blunt the impacts of on-lot wastewater systems on local water resources, in this case Chesapeake Bay. He proposed that they not actually oversee system management, instead that they create a web site that provides information to homeowners, such as: the environmental and financial benefits of the systems and of assuring proper maintenance; complete descriptions of the types of systems installed; links to contacts for replacement parts for the systems; recommended changes to systems if appropriate; and, a list of contractors willing to provide maintenance on each type of system. He also suggested, “The owners could be e-mailed when recommended maintenance is due.” This strategy presumes that, armed with this information, homeowners would unilaterally assure that O&M is consistently, reliably and competently applied without any further management effort on the part of the regulatory system.

My response was that I saw two flaws in that approach. One – He is assuming that all homeowners would be responsible. Two – He is assuming that all homeowners would be competent. I have to wonder if more than a small percentage is likely to be either, consistently and reliably enough to hang a management system on that premise. Understanding that these enhanced pretreatment systems represent a considerable investment to their owners, one could reasonably assert that they could be expected to be responsible and competent in their efforts to protect that investment, simply out of self-interest. So why can’t we universally trust them to unilaterally carry out this function?

I would argue first that this ignores basic human nature. Yes, theoretically, my colleague had a very nice idea—for a perfect world where people always competently address all their responsibilities, where they always serve their long-term self-interest, no matter what the short-term costs. But, by and large, people do not act that way, at least not consistently. They are pulled in a thousand different ways by the forces in their lives. Tending to a wastewater system, and learning how to do it well, generally does not make it very far up on their priority list. Anything that is inherently out-of-sight, out-of-mind—like an on-lot wastewater system—will not typically command their attention on a routine basis. And when it does get their attention, will they really be competent to understand the system operation, to recognize the nature of a problem, and to understand how to respond? Can they get all this from a web site?

My colleague thought that homeowners would opt to engage a maintenance contractor. A wealthy person—the sort who has a maid, a gardener, etc.—would indeed "farm out" this function as well. But most people would avoid this expense if they were not required to keep a maintenance contract in force. Here in Texas, where maintenance contracts are required, assuring they are kept current is an on-going problem for the regulatory system. So the maintenance contractor would only be engaged when the homeowner observed a problem. Such a “reactive” management system would be of highly questionable effectiveness.

And then we have the question of whether all maintenance contractors would be consistently responsible and competent. Might that depend on whether anyone was “riding herd” on them? In Texas, due to lax oversight, maintenance contractors failing to perform even their routine surveillance duties, much less keeping the systems in top operating condition, is a rampant problem. Then too, if maintenance contracts are optional, would there be a sufficient market so that many contractors would be in that business, and so would be readily available when the homeowner did perceive a need for their services?

The nature of the job is a critical factor. For high quality pretreatment systems, this is the level of treatment actually attained. In my colleague’s case, inadequately treated effluent seeps into the Bay, with no one being the wiser until impacts on the Bay ecology become apparent, way too late in the game to be responding. If problems were to become immediately obvious to the homeowner, such as a hydraulic failure resulting in surfacing effluent, while you might expect quick action, that brings us back to the circumstances of the homeowner. Many, strapped for cash, put off repairing the system, fearing that they would be looking at a big expense they can't afford. How much less likely would they be to recognize and respond quickly to a treatment failure, a condition that is not “in the face” of the homeowner?

This highlights that wastewater management is the ultimate community function. The actions of—or inaction by—any one person can have consequences to the whole community. That is why this function is regulated in any way to begin with. Often the consequences are to "the commons", like Chesapeake Bay—which eventually become consequences to the community—so you can see this is a function in which the entire community, not just the individual user, has a stake. This calls into question the very concept that wastewater system O&M should be the sole responsibility of each individual owner of the property served by each system, to be executed if and as they will.

Yet, like my colleague’s agency, the controlling institutions all over the country are loathe to take on a management role, by default investing management in the individual whims of the homeowners. Probably a major reason that such institutional inertia persists is the lack of a "body count"—few recognize either a public health or environmental crisis, so why input more public resources to this function when there are so many other needs that vie for them? But as those who examine ecosystems like Chesapeake Bay are seeing, the impacts are there, if you just look. This should be a clue to what is going to happen as more and more high quality pretreatment systems are installed in more and more intense development. Where high quality pretreatment has been deemed necessary to protect public health and environmental values, if it fails to function as planned, impacts will accrue. And they would accelerate if this method of management continues to proliferate and densify. So there would eventually be a "body count"—hopefully not dead people, but greater incidence of disease and damage to ecosystems, including an actual body count of other organisms.

Society can wait for this crisis to “mature” before considering how to combat it—its "normal" mode of operation—or it can take considered action now, as the seeds of crisis are being sown. This could take the form of “sewering up”—and the consequent loss of business opportunity for the decentralized industry. Or we could maintain the viability of decentralized systems by treating ALL forms of wastewater management as a community function—including running on-lot management much more similarly to how a municipal system is run. There, maintenance is not left to the whims of the individual users, or to contractors beholden only to the individual users. Someone who is accountable to the community is charged with this responsibility. A major organizing principle for all management systems must be a chain of accountability to the entire community.

The most basic requirement for society to "get" this principle is to understand that on-lot systems (or any system not "community owned") are not just odd pieces of regulated private property, rather they are collectively an integral part of societal infrastructure, necessary components of our societal efforts to maintain the integrity of our watersheds. As the on-lot system has transformed and proliferated from a method of addressing wastewater in very low density rural housing using only simple, passive systems to a method used in essentially urban settings, often entailing more complex systems, this intellectual leap has not been made. The major barrier to effective management systems is this “dichotomy view” that sequesters on-site/small-scale systems into an entirely separate category from “wastewater systems”.

Once we recognize the need for “organized” management, we are back to the basic question—who can we trust to faithfully execute it? Where are the proper links in the chain of accountability? There is presently an active debate over whether the sort of public health agencies in which on-lot system regulation is typically vested is the proper place for this function to reside. As in the case of my colleague’s agency, their “culture” is antithetical to engaging in active management. In any case, to do so these agencies would require a quantum leap in the resources available to them. Given that those agencies don’t appear very motivated to take on this task, is that the “right” place to focus those resources?

An emerging idea is that wastewater management should be addressed within a “watershed approach” by an agent with the ability to organize and run systems at the watershed level. One effort to proliferate this idea is a workshop being prepared for the 2006 WEFTEC, focusing on how to integrate centralized and decentralized strategies into a watershed-wide management system. Such efforts are needed to explore and answer some basic questions. Who would those watershed-wide agents be? How would they be created, or how would existing agents be transformed—and empowered—to take on this responsibility?

I urge you all to join in that discussion. Deriving and implementing effective management organizations is a major key to the proliferation of decentralized wastewater systems. And that, in turn, is a key to enhancing and expanding the economic opportunities for the people who are the audience of this magazine. Indeed, we must answer the central question about management – Who can we trust?
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David Venhuizen is a professional engineer based in Austin, Texas. You can read his views on the decentralized concept on his web site at http://www.venhuizen-ww.com/. Comments, suggestions, and your own anecdotes about this field can be sent to him at waterguy@venhuizen-ww.com.