The new draft NPDES (National Pollutant Discharge Elimination System) for the City of Atlanta combined sewer system was posted for public comment on December 31, 2020. The 30-day comment period expires February 1, 2021. This permit, once approved by Georgia EPD, will regulate how Atlanta’s combined sewer system will be managed for the next five years. This permit contains a number of major changes from the previous 2015 NPDES permit that highlight existing water quality issues and will have huge implications for water quality in Intrenchment Creek and the South River.
Please send a comment to GA EPD and demand at least a 30-day extension of the public comment period. Below are a few points for your consideration. No need for a long comment, simply highlight one issue and put it in your own words.
Send comments to EPDcomments@dnr.ga.gov., NPDES Permit No. GA0037168.
1) Constructing valid and defensible comments (which is required if there is any expectation that EPD will act upon those comments) requires access to and review of information such as sampling plans and data related to implementation of the 2015 NPDES permit. Securing these data requires time consuming open records requests in addition to lengthy analysis. The public requires as much consideration as was given the City of Atlanta in the development of their draft permit.
2) The December 31, 2020 timing for the release of the draft comment could not have been more insensitive to the potential negative impacts of other competing and equally important demands on the time and attention of individuals who otherwise would have likely participated in this important public comment opportunity.
3) The current 2015 permit expired on September 1, 2020 and has been administratively extended since that date. Atlanta’s 2005 NPDES permit was administratively extended from 2010 to 2015, five years. There is no defensible reason why the public comment period cannot be extended for at least an additional 30-days.