Permitting Strategies & Reasonable Potential Analysis

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Water quality based limitations (WQBLs) are imposed in wastewater permits when it is determined that technology based limitations are not sufficient to protect water quality (40 CFR 125.3). These limitations are based on state and federal water quality standards, as well as the assimilative capacity of the receiving stream.

EPD has developed a number of permitting strategies and reasonable potential analysis procedures to aid in the determination of effluent limitations in NPDES wastewater permits. More information on the development of limitations may be found on the Water Quality Modeling page.

Download this pdf file. NPDES Reasonable Potential Procedures



Total Residual Chlorine

Whole Effluent Toxicity

Bacteria Strategy

Bacteria Equivalency Strategy for Using the Optimal Indicator Organisms for WQS and NPDES Permitting (Bacteria Strategy)

During the 2013 Triennial Review, Georgia adopted E. coli and enterococci as the pathogen indicators for waters designated as recreation where primary contact recreational activities such as swimming, water skiing, and white-water boating occur. As part of the 2019 Triennial Review, Georgia adopted E. coli and enterococci criteria for waters designated as fishing, coastal fishing, and drinking water to protect secondary contact recreators who may inadvertently ingest water. The Bacteria Equivalency Strategy for Using the Optimal Indicator Organisms for WQS and NPDES Permitting (Bacteria Strategy) provides a framework for the implementation of the changes to the bacteria criteria for water quality monitoring, 303(d)/305(b) listing purposes, Total Maximum Daily Loads, and wastewater and stormwater permitting.

Download this pdf file. Bacteria Strategy

DRAFT Nutrient Permitting Strategy

The Clean Water Act (CWA) authorizes EPA and delegated states to develop and implement water quality standards to protect human health and the environment. In 1990, the Georgia General Assembly passed the “Lake Law” (OCGA 12-5-23.1) that authorizes the Environmental Protection Division (EPD) to establish water quality standards for each publicly owned lake or reservoir located wholly or partially within the state of Georgia that have a normal pool level surface average of 1,000 or more acres.  The law requires that a comprehensive study of each lake be conducted prior to the adoption of lake and major tributary water quality standards. Since that time, Georgia has adopted lake standards for eight lakes, evaluated all our waterbodies for nutrients, developed water quality models for our watershed, lakes, and estuaries, and issued point source National Pollutant Discharge Elimination System (NPDES) permits with permit conditions and discharge limits designed to protect these waterbodies from excessive nutrient loadings.

EPD is drafting and soliciting feedback on a nutrient roadmap for the development of a comprehensive Nutrient Permitting Strategy for point source discharges in response to communication with U.S. Environmental Protection Agency (EPA) regarding a reasonable potential analysis for total nitrogen. 

Download this pdf file. A draft copy of the Nutrient Roadmap is available for download.

EPD held the first stakeholder meeting on August 17, 2022 and the presentation is available for download here: Download this pdf file. Nutrient Permitting Strategy Kick-Off Meeting Presentation.


EPD is soliciting feedback on the Nutrient Roadmap and development of the Comprehensive Nutrient Permitting Strategy.  EPD appreciates your participation and values your feedback allowing us to protect and enhance our state's natural resources.

Please provide your comments and questions by completing the “Nutrient Permitting Strategy Meeting No. 1 survey. The purpose of this survey is to solicit feedback and obtain information for consideration during the development of the nutrient permitting strategy.  EPD will use the contact information provided in the survey for notification of targeted follow up meetings. Please complete the survey by September 15, 2022.