More on the gray (legal) area of dumping the gray tank

In an Ask BoondockBob post in the RV Travel newsletter awhile ago, a reader asked about dumping gray water onto or into the ground rather than driving to a dump station when boondocking. Judging from the response to the question and having written about this practice before, it appears that the question (and lack of good answers) is still paramount in many RVers’ minds, especially boondockers.

As an example, Tommy commented, “Just about everyone dumps grey water from time to time” and “I hook to my dump hookup and if there’s a nearby ‘rabbit hole’, there goes the grey.” Wolfe wrote, “It is mildly acceptable to drip water at a rate that IMMEDIATELY soaks in, provided your grey water is not chunky with grease or stinky food debris. Never leave significant food debris at the surface.”

If you have stayed at Forest Service campgrounds you may have also seen designated gray water dumping places in the campground. Unfortunately, the rules for dumping gray water can vary among public lands managers like the Forest Service and Bureau of Land Management, and also among states.

To understand the discrepancies and legality of gray water dumping I wrote to Carrie Templin, the Public Affairs Specialist at the Bureau of Land Management in Arizona. Here is her reply [emphasis added]:

Dear Mr. Difley,
Thank you for your recent questions regarding recreational vehicles (RV) and dispersed camping on BLM lands in Arizona. The answers to your questions are more complicated than originally thought. Although the Code of Federal Regulations (CFR) found at 8365.1-1 (3) generally excludes “wash water” from BLM’s prohibition against draining or dumping, it can be specifically prohibited by Supplemental Rules issued for a specific area. This applies equally to RVers and tent campers.

TITLE 43–PUBLIC LANDS: INTERIOR
CHAPTER II–BUREAU OF LAND MANAGEMENT, DEPARTMENT OF THE
INTERIOR
PART 8360_VISITOR SERVICES
Subpart 8365_Rules of Conduct
Sec. 8365.1-1 Sanitation.
(3) Drain sewage or petroleum products or dump refuse or waste other than wash water from any trailer or other vehicle except in places or receptacles provided for that purpose;

There are two locations in Arizona where draining wash water is specifically prohibited by Supplemental Rules that have been established and were published in the Federal Register. They are the Long Term Visitor Areas outside of Yuma, Arizona, and Hot Well Dunes Recreation Area east of Safford, Arizona.

A note of caution to your audience: Under State laws and regulations in Arizona, “wash water” or “gray water” from a kitchen sink or dishwasher is classified as sewage. If discharging it onto the ground from a RV or camper might cause it to enter an aquifer, the visitor could be subject to violation of State of Arizona regulations unrelated to BLM regulations. Even if the gray water is from a clothes washer, bathroom sink, shower, or bathtub, it can only be discharged if done so according to the “General Permit” practices that would apply. The practices are explained at the Arizona Department of Environmental Quality.

In addition, if the gray water creates a hazard or a nuisance a Law Enforcement Officer can cite (or in extreme circumstances arrest) an individual. This would go beyond simple gray water dumping, and the citation would likely be for some other offense related to degradation of resources or public health and safety issues. Law Enforcement Officers in the field have discretion in applying the laws and regulations as necessary and appropriate to protect the natural resources on the ground.

Thank you for your patience, while BLM researched the issue in order to provide accurate answers for your audience,

Carrie Templin

At the Arizona Department of Environmental Quality (ADEQ) I found this definition: “Gray water is defined as wastewater, collected separately from sewage, that originates from a clothes washer, bathtub, shower or sink, but not from a kitchen sink, dishwasher or toilet. Gray water is distinguished from ‘black water,’ which is wastewater from toilets, kitchen sinks and dishwashers.” (emphasis added)

The ADEQ also stated that a citation could occur in a situation that went “beyond simple gray water dumping, and the citation would likely be for some other offense related to degradation of resources or public health and safety issues.”

That may be about as clear an interpretation of the rules as we’re going to get. But the bottom line seems to be that if you follow an environmentally safe protocol you will be unlikely to receive a notice to stop or a citation. But remember also that a lot depends on the individual ranger whether to ticket or not, so your common sense behavior and civility may be the deciding factor.

Suggested Gray Water Dumping Guidelines
• Scrape all food bits off dishes, pots, pans and cooking utensils into the garbage before washing.

• Wash and rinse dishes in dishtubs and take several yards away from campsite and dump on plants (no water goes into the gray tank). Empty tub at a different place each time.

• If you do fill up your gray tank, dump only as much as necessary to avoid gray water rising up into your bathtub before you are able to visit a dump station.

• Dump your tank into a freshly dug hole as slowly as possible to allow water to soak into soil and not overflow onto the ground.

• NEVER dump your black tank into anything other than a dump station or sewer connection.

• Consider using a portable waste tank (Amazon.com) and/or a macerator (article).

Check out Bob’s Kindle e-books about boondocking at Amazon.

##RVT802