Best Practices for Commenting on Wastewater Discharge Permits

When opposing a wastewater discharge permit, the most effective arguments typically focus on environmental, public health, legal, and economic impacts.

These arguments should be supported by robust scientific data, expert opinions, legal precedents, and comprehensive economic analyses to strengthen the case against the wastewater discharge permit.

Here are key points to consider:

### Environmental Impact

1. 1. **Water Quality Degradation**:

  – Argue that the discharge will introduce pollutants (e.g., nutrients, heavy metals, organic matter) into the receiving water body, leading to water quality degradation.

  – Provide data showing how the discharge could increase levels of contaminants like nitrogen, phosphorus, or harmful bacteria.

1. 2. **Ecosystem Damage**:

  – Highlight potential harm to local ecosystems, including the destruction of aquatic habitats, the decline of fish populations, and adverse effects on wildlife dependent on the water body.

1. 3. **Threats to Endangered Species**:

  – Identify any endangered or threatened species in the area that could be adversely affected by the discharge, supporting arguments with evidence from environmental studies or expert testimonies.

### Public Health Concerns

1. 1. **Drinking Water Safety**:

  – Demonstrate how the discharge could contaminate sources of drinking water, leading to potential health risks for the local population.

1. 2. **Recreational Use**:

  – Point out the negative impacts on recreational activities such as swimming, fishing, and boating, which can be compromised by poor water quality and increased health risks.

### Legal and Regulatory Issues

1. 1. **Non-Compliance with Standards**:

  – Argue that the permit does not comply with existing water quality standards, regulations, or the Clean Water Act. Highlight specific violations or shortcomings in the permit application.

1. 2. **Failure to Consider Cumulative Impacts**:

  – Point out if the permit fails to account for cumulative impacts from multiple discharges in the area, which can collectively degrade water quality.

1. 3. **Inadequate Environmental Review**:

  – Emphasize any deficiencies in the environmental impact assessments or reviews conducted as part of the permitting process.

### Economic Impacts

1. 1. **Negative Economic Consequences**:

  – Argue that the discharge could harm local economies dependent on clean water, such as tourism, fishing, and real estate values. Provide data on potential economic losses.

1. 2. **Cost of Clean-Up and Remediation**:

  – Highlight the potential future costs associated with cleaning up pollution or restoring damaged ecosystems, which could be a financial burden on the community.

### Technical Feasibility and Alternatives

1. 1. **Feasible Alternatives**:

  – Present viable alternatives to direct discharge, such as advanced treatment technologies, water recycling, and reuse, or land application systems. Show how these alternatives could achieve similar or better environmental outcomes.

1. 2. **Technological Shortcomings**:

  – Critique the proposed treatment technology if it is outdated, insufficient, or not suitable for effectively treating the specific types of pollutants expected in the discharge.

### Community and Stakeholder Concerns

1. 1. **Lack of Community Involvement**:

  – Argue that the permit process did not adequately involve or inform the local community and stakeholders, leading to a lack of transparency and consideration of local concerns.

1. 2. **Public Opposition**:

  – Demonstrate significant public opposition through petitions, public comments, and testimonies at hearings, showing that the permit does not have community support.