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By David Venhuizen
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 ensure 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 assumes that all homeowners would be responsible. Two,
he assumes 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 lists. 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 and a gardener—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 ongoing
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, 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 such as a hydraulic
failure resulting in surfacing effluent were to become immediately
obvious to the homeowner, 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 wastewater management as the ultimate community
function. The actions of—or inaction by—any one
person can have consequences for 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
for 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 loath 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 address 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 grasp this principle
is understanding 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 or other 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—whom 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 style is antithetical to engaging in active
management. To do so, in any case, 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: Whom can we trust?
DAVID VENHUIZEN is a professional engineer based in Austin,
TX. Comments, suggestions, and your own anecdotes about this
field can be sent to him at waterguy@venhuizen-ww.com.
OW
- January/February 2006
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