September 27, 2006
Director, Environmental Protection Division
Departmental of Natural resources
2 Martin Luther King Jr. Drive SE
Floyd Towers East

Atlanta, Ga., 30334

Reference:

1. NPDES Permit No 0038130 for Hill Plant Discharge of 40 MGD into Lake Lanier
2. Public meeting on September 21^st at Gwinnett County Justice center

The following comments are submitted from the Lake Lanier Association with regard to the referenced permit. This is in addition to our verbal comments (V. M. Perry, Jr. – executive vice president of the LLA) at the referenced meeting.

1. The Lake Lanier Association (LLA) is a 1750 membership (4000 members) organization dedicated to keeping the Lake clean and full in support of its economic value and contribution to the State of Georgia. The Lake contributes over $5 billion of economic benefit to the State. Annually there are over 8 million visitors to the Lake for recreation. Lanier is the drinking water supply for over 65% of Georgians. Clearly Lake Lanier is one of the finest natural resources in the State.
   
   
2. The LLA is supportive of issuing the NPDES permit to Gwinnett County. After an extended (5+ years) legal battle, and extensive negotiations with Gwinnett County executives, we reached agreement on the pollutant specifications and the discharge location into Lake Lanier. That agreement included the specifications outlined in the permit draft and the location of the outfall over 100 feet deep, and running over 1 mile at that depth in order to have the effluent temperature reach the same temperature of the receiving water, causing the pollution to avoid the photic zone and remain at the lower depths of the Lake. This will make it impossible for algae to grow (phosphorous mixing with sunlight) and harm people and fish.
   
   
3. The LLA also wishes to acknowledge Gwinnett County executives for their forthright handling of the permit negotiations. After the agreement between Gwinnett and the LLA, was concluded (in April 2005), the Georgia EPD changed the rules for issuing sewage discharge permits. Those changes relaxed the requirements for degrading high quality waters, by eliminating the requirement for using the “best available” sewage treatment technology. Gwinnett County demonstrated their integrity by maintaining their agreed upon specifications and did not try to avail themselves of the less strict EPD anti-degradation guidelines.
   
   
4. The LLA, while protecting the water quality of Lake Lanier, acknowledges that there may be other municipalities desiring to discharge sewage into the Lake in order to foster growth in Georgia. We are convinced that in order to protect this water quality, that any new discharge into Lake Lanier should be at least as clean as the Gwinnett permit requires, and should avoid the photic zone by having a cold and deep discharge location. The LLA has requested (officially requesting here) that the Georgia EPD describe the appropriate operational permit procedures for Lanier sewage discharges to insure that the Gwinnett permit represents the minimum acceptable specifications for new Lanier sewage discharge permits.

We appreciate the opportunity to submit these comments to the Georgia EPD.

Sincerely,

V. M. Perry, Jr.,
EVP, Lake Lanier Association

Cc: Charles Bannister, Frank Stephens, J Joseph, Jeff Larson (EPD), Andy Thompson, John Heard