The National Pollution Discharge Elimination System (NPDES) Permit
A century ago, it was common for communities, industrial facilities, mines and farms to dump waste into the nearest waterway without regard to people or other living things downstream. As populations and commercial activities grew, toxins and pathogens like bacteria and viruses in the waste began taking a toll in human health and the environment.
The self-interest of polluters clashed with the public’s interest in clean water, leading to governmental intervention, including the requirement of wastewater treatment.
The Detroit Water & Sewerage Department (DWSD) processes wastewater for nearly 4 million people in more than 70 communities over an area of 900 square miles.
A major wastewater treatment plant like Detroit’s is responsible for (1) managing combined sewer overflows, (2) controlling pathogens and toxins, (3) removing and disposing of suspended solids, including nutrients like phosphorus, and (4) supervising industrial pretreatment, which takes place at individual industrial plants.
All of these functions are mandated by state and federal laws, primarily the federal Clean Water Act (CWA) and the Michigan Natural Resources and Environmental Protection Act (NREPA). These laws are supplemented with rules developed by various governmental agencies.
Fundamental to the regulation of pollutants in the nation’s surface waters is the National Pollution Discharge Elimination System (NPDES) permit.
Any facility or “point source” of surface water pollution must obtain an NPDES permit, which limits pollution by providing for progressive reductions over time.
In Michigan, the permits are issued by the Department of Environmental Quality (DEQ) on behalf of the U.S. Environmental Protection Agency (EPA).
To understand the permit, it’s important to learn what the terms and acronyms mean. Like all technical subjects, this one has a language of its own, made up in part of chemistry, biology and engineering.
Each permit begins with a cover page describing the regulated facility and establishing the starting date of the five year period for which the permit applies. Next is Part I, which contains provisions for the specific facility and its receiving waters. Part II sets out general provisions that apply to all such facilities and their receiving waters.
We’re fortunate in Michigan to have available an excellent handbook on the subject, A Citizen’s Guide to Water Quality Permitting. Written by Ellen J. Kohler and published by the Tip of the Mitt Watershed Council, the booklet can be downloaded at:
The importance of public participation in the regulatory process can’t be emphasized too much. Citizens can take part individually or in groups. To be effective in promoting good water quality, it’s helpful if the participant learns as much as possible about the different types of wastewater treatment, the economics involved, the regulatory process and political considerations.
Kohler’s handbook should be on the reading list of everyone who cares about clean water. Please pass along this important reference to your friends and colleagues.