Water, Wastewater, Stormwater

February 23, 2018

The Importance of Water to Georgians 

Water is a life-sustaining resource essential to all Georgians and to economic growth in Georgia. Competition for this resource requires a balanced and integrated approach to efficiency, conservation, consumption, and return to a healthy ecological balance for Georgia. State Regional Water Planning Councils are tasked with providing guidance while operating under federal and state laws and regulations protecting the water supply and water quality. Over the last two decades, Georgia’s legislative body and governors have passed numerous laws to protect and enhance this finite resource.

The 2004 Comprehensive Statewide Water Management Planning Act mandated the development of a statewide water plan requiring the state to manage its water resources in a sustainable manner to support the state’s  economy, to protect public health and natural systems, and to enhance the quality of life for all citizens (O.C.G.A. § 12-5-522(a)). In 2008, the Georgia Comprehensive Statewide Water Management Plan was adopted. This plan is the leading document guiding the oversight for water, wastewater and stormwater management for Georgia. In 2010, the Water Stewardship Act was adopted, requiring water conservation in Georgia and the enhancement of water supply throughout the state.

The federal government through the Clean Water Act has set forth a framework to protect and restore water quality by maintaining the chemical, physical, and biological integrity of the nation’s waters. These programs provide for pollution control, permitting, setting water quality standards, wetland protection, and a host of other metrics addressing our nation’s water resources.

The United States Environmental Protection Agency (EPA) primarily provides oversight of the implementation of these programs, while it is the responsibility of the Georgia Environmental Protection Division (EPD) to implement the components of the federal requirements under the Georgia Water Quality Control Act and the Georgia Safe Drinking Water Act.

Additionally, there are various state regulations, policies, and acts crafted for the protection of our water resources in the state. One affecting each municipal government is the 1975 Erosion and Sedimentation Act, which addresses construction sites and the protection of soil and water resources. As an elected official, the development community will approach you as your staff apply the enforcement measures provided in the Manual for Erosion and Sediment Control in Georgia known as the “Green Book”. Furthermore, the Georgia Stormwater Management Manual (GSMM), commonly referred to as the “Blue Book,” will present additional challenges for the development community.


In Georgia, drinking water comes predominately from two sources: surface water and ground water. The pumping of raw water (untreated water) collects drinking water from the ground or from streams, rivers, or reservoirs (impoundments). The water is transferred in underground pipe systems to treatment facilities for processing and treatment for release to the distribution system for residential, commercial, and industrial use and consumption.
Regulatory Framework

Federal Level
The 1974 Safe Drinking Water Act (SDWA) is the federal law that protects public drinking water supplies throughout the country. Under the SDWA, EPA sets standards for drinking water quality. EPA provides technical and financial programs to ensure drinking water safety through the Drinking Water State Revolving Fund (DWSRF).

State Level
Under the SDWA, Georgia establishes policies, procedures, requirements, and standards to implement the Georgia Safe Drinking Water Act of 1977 (Act No. 231 O.C.G.A. Section 12-5-170 et seq., as amended), and to carry out the purposes and requirements of the Federal Safe Drinking Water Act (PL93-523).

Local Public Water Systems
Water systems in Georgia are permitted by EPD for treatment plants and distribution systems. If the local system pumps either surface water or ground water, the provider is required to obtain a withdrawal permit. As the owner of an operating permit, the public water system is required to monitor water quality, maintain records, perform periodic lab analyses, and if necessary notify customers of violations that could result in serious health effects. A Consumer Confidence Report (CCR) is required annually which provides customers information about the water sources, contaminant testing, and health concerns. The State of Georgia requires operators to be certified by the Georgia State Board of Examiners for both water and wastewater treatment and laboratory analysis. There are 13 classes of licenses which the Board governs. There is a critical need for additional operators in the state. Commissioners need to maintain competitive pay scales to retain their current staff and attract new employees.

The Safe Drinking Water Act allows smaller water systems special consideration regarding the use of treatment technologies and other resources for implementation of their program and to ensure that these systems have the technical, financial, and managerial capacity to comply with drinking water standards. All systems must assess their vulnerability to terrorist acts and other intentional acts of contamination. If you are a ground water public facility, you must comply with Rule 391-3-2, which establishes procedures to obtain a permit to withdraw, obtain, or utilize ground water. The permittee must provide information concerning the amount of ground water withdrawn, its intended use, and the proposed aquifer or aquifers of withdrawal to EPD.

Major Issues in Public Water Systems
  1. Condition of Water Infrastructure: The American Society of Civil Engineers (ASCE) ranks the condition of America’s infrastructure and awarded a grade of “D+” in its most recent report. Local municipal water systems and their governing bodies across Georgia have tough decisions to make in the next decade due to aging infrastructure and its repair. As an example, the water system in the city of Griffin will be 50 million dollars in debt by the year 2020 and will need an additional 50 million dollars to complete plant and distribution upgrades. The useful life of pump stations, raw water transmission mains, and water treatment plants has long been exceeded. These assets will present major challenges for municipal officials to address.
  2. Public Appreciation of the Value of Water: The public does not have a good understanding of water and its value. Most of us get up in the morning, turn on the faucet, and expect the water to flow. Water facilities and distribution systems are usually out of sight and out of mind. Local water system providers and local public officials have failed to fully educate the public on drinking water and its value, which is delivered daily to residential, commercial, and industrial customers in their community.
  3. Funding for Capital Improvements Projects: In a recent survey by the American Water Works Association, respondents identified financing capital improvements as the second most important issue facing the water industry (the most important concern being the renewal and replacement of aging infrastructure). Local elected officials are faced with the challenge of doing more with less while water projects are in need of funding for repair, replacement, and rehabilitation. In addition, future water supply and advanced treatment require local elected officials to make difficult decisions on ratemaking.
  4. Retiring Workforce and Its Replacement: The water world is subject to the same pressures as other industries with the retirement of baby boomers. Similar to other governmental agencies, municipal water professionals are not attracting the millennial generation for succession of its workforce. Non-competitive wages continue to plague the industry as an obstacle to recruitment. Succession planning is critical to staff treatment plants and collection systems management. Managers need to seek all avenues possible to maintain the workforce.
  5. Drought Management: Local municipal water systems in Georgia are required to have Drought Management Plans and contingencies. Water supply is not a concern until drought periods lead to declining reservoirs.
  6. Customer and Community Relations: Local water systems and public officials need to improve communication and education concerning the challenges of water stewardship. Developing public support is critical to managing water resources. Aging infrastructure and upgrading assets will require water and wastewater rates to be assessed, and rate increases may be needed to make improvements. Communicating with and educating the public can lead to reduced pushback by ratepayers when rates have to be increased.
  7. Recovering Costs for Service and Investment: In the survey cited above, 37% of systems reported that they are currently struggling to cover the full cost of providing services. Water has been—and continues to be—an undervalued service. Local governments that provide water are entitled to receive the full cost of service just as cable, power, and phone providers are.
  8. Government Regulations: Local governing bodies need to educate themselves to understand how water is regulated by the EPA and that regulatory agencies are constantly changing policies and requirements. The future top targets for regulatory change are likely to be disinfection byproducts (DBPs), pharmaceuticals, and personal care products (PPCPs). Local providers will have to invest in advanced technologies to treat water in order to comply with new water quality standards.
  9. Energy Usage and Cost: The cost of energy continues to climb. Outside of personnel costs, energy is the largest cost in utility operations budgets. Providers must continuously look to improve energy consumption by utilizing new technologies and efficiencies with new equipment and more efficient process management.
  10. Climate Change: Climatic issues are a fact. Over the last two decades, Georgia has experienced numerous droughts. These droughts have demonstrated the vulnerability that water providers have in their water supply. Drought management plans and conservation plans must be reviewed and updated on a regular basis. Local providers and government leaders must insure resiliency and sustainability to protect and enhance the precious resource of water to meet daily needs in homes, businesses, and industries. Minimizing risk and insuring resiliency is critical for each community to survive and provide economic growth.
  11. Utility Cybersecurity: In the 21st century, we experience daily hacks into the internet, operating systems, and financial institutions. Water providers need to insure network integrity. Supervisory Control and Data Acquisition (SCADA) systems operate water tanks, water treatment processes, and distribution systems. Investment in information technology (IT) is critical to protect the treatment and distribution of water in our communities.


Wastewater is water that has been used in homes, in businesses, or as part of industrial processes. The wastewater is collected and transported through a network of underground pipes and then conveyed to wastewater treatment facilities for processing. Once the wastewater is treated, it is returned to creeks, streams, or rivers. In some communities, wastewater is treated to a certain level and then land applied for further natural treatment. In other communities, septic tanks provide the treatment, and the process is located on each site.

Regulatory Framework

Federal Level
As part of environmental law, the 1972 Clean Water Act (CWA) uses two methods to protect the quality of water, both monitoring the water quality and controlling discharge from point sources (33 U.S.C. §1251 et seq.).
State Level
Residents of Georgia depend on rivers, streams, lakes, and subsurface waters for their public and private water supply, and agricultural, industrial, and recreational uses. The Georgia Water Quality Control Act (WQCA) governs the impacts on the water quantity and quality within the state (O.C.G.A. § 12-5-2). EPD is charged with establishing and maintaining the quality and quantity of Georgia’s water resources (O.C.G.A § 12-5-21(b)). It is Georgia’s policy that water resources be utilized prudently for the maximum benefit of the people, in order to restore and maintain a reasonable degree of purity in the waters and an adequate water supply, and to require, where necessary, reasonable usage of the State waters and reasonable treatment of sewage, industrial wastes, and other wastes prior to their discharge into the State waters (O.C.G.A. § 12-5-21(a)).
Major Issues in the Wastewater Industry
  1. Maintaining or Expanding Asset Life: No wastewater treatment plant and collection system is immune from the aging and deterioration of the asset. Local providers should regularly conduct condition analysis of their assets for the implementation of short-, intermediate- and long-range capital improvement. Revenue sufficiency is critical in the maintenance of the treatment and collection systems. Managers must seek to find the latest and proven technologies for the repair, rehabilitation, and/or replacement of infrastructure. In most cases, assets can be rehabilitated allowing for long-range planning and the replacement of the asset in a manageable solution.
  2. Customer Rates: Water and wastewater rate models developed by financial rate consultants can be a useful tool for planning future capital improvements and operational needs of the system. Staff and commissioners can evaluate the timing and implementation of strategic rate increases in these models. Wastewater, just like water infrastructure, is quite expensive. Again, public education and information needs to be a critical milestone in gaining public support and buy-in for understanding rate increases. As an elected official or board member, tough decisions need to be planned and promoted to the citizens on a routine basis to insure transparency and understanding when rates need to be increased.
  3. Maintaining Services While Budgets Decline: Wastewater is a direct reflection of water consumption. Utilities have seen a decline in revenues over the last several years due to water conservation rates, more efficient appliances, and a better understanding of water usage. Revenues may decline but system assets have to be maintained, and the operation of treatment facilities must still take place. Wastewater effluent must meet water quality standards in the discharging of wastewater, thus requiring a reliable revenue stream to meet water quality standards.
  4. Reducing Sewer Overflows, Infiltration, and Inflows: As wastewater collection systems begin to age, the integrity of the pipes begins to fail causing water to enter the collection system. This creates several issues for the provider. One, the treatment plant is treating unnecessary rainwater and not sewerage, which is quite costly. Second, when large amounts of water enter the collection system, it can cause sewer overflows due to the surcharge of collection pipes, resulting in sewer spills and fines for illicit discharges to the waters of the state. Repairs, rehabilitation, or replacement will be necessary and costly to improve aging infrastructure.
  5. Aging Workforce: See above in the section on water.
  6. Government Regulations: Local governing bodies need to educate themselves to understand regulatory issues passed down by the EPA. Water quality regulations are constantly changing. The future top targets for regulatory change are likely limits in ammonia and phosphorus in the effluent discharge to creeks, streams and rivers. Local providers will have to invest in advanced technologies to treat wastewater in order to comply with new water quality standards.
  7. Energy Usage and Cost: See above in the section on water.


Stormwater is water from rain and other sources, which drains to street collection systems consisting of curb, gutter, inlets or drainage swales and flows to creeks, streams, and/or river systems. In many cases, the runoff sheet flowing to these creeks, streams, and river systems never enters the engineered collection system.

Importantly, there at least two types of collection systems in municipal storm drainage systems.
The first is a collection system where storm water runoff is collected in pipes and swales and then transported to natural water systems (usually untreated). This system is known as a Separate Stormwater Separate System or MS4, which is the most common type in Georgia. The second collection system is a Combined Sewer Overflow (CSO) system where wastewater and stormwater enter into the same pipe system and are treated at a wastewater treatment facility.

Regulatory Framework

Federal Level
The 1972 Clean Water Act (CWA) uses two methods to protect the quality of water: monitoring water quality and controlling discharge from point sources. The latter method is addressed more specifically in the National Pollutant Discharge Elimination System (NPDES).

State Level
The Georgia EPD has been delegated by the EPA under Section 405 of the Federal Water Quality Control Act of 1987 (which amended Section 402) to establish regulations setting forth NPDES permit application requirements for stormwater discharges. Phase I of EPA’s stormwater program was promulgated in 1990 under the CWA. In 1999, EPA published its Stormwater Phase II Final Rule, which expanded its rulemaking to smaller communities. EPD enforces its stormwater rules under the Georgia Rules and Regulations for Water Quality Control providing for municipal, construction, and industrial permitting (O.C.G.A. § 12-5-20).

Major Issues in Stormwater Systems
  1. Stormwater Management Funding: As in most cases, funding for stormwater management is a challenge for cities in Georgia. In 1998, the city of Griffin created the first stormwater utility to address stormwater management funding. Since that time over 65 stormwater utilities have been created to address stormwater administration, operation and maintenance, environmental issues and capital improvements. For more information on existing stormwater utilities in the state, including fee structures, see the latest Georgia Stormwater Utilities Report issued by the Environmental Finance Center at the University of North Carolina and the Georgia Environmental Finance Authority (GEFA). Stormwater drainage pipes, culverts, and other assets are frequently well beyond their useful life and are in dire need of replacement or rehabilitation. The creation of stormwater utilities and their user fees have aided immensely in the efforts to address the issues mentioned above. The courts have upheld the user fee for stormwater as legitimate and defensible. Still, after 20 years, challenges to the legitimacy of their existence have lingered. Cities may apply for additional funding for stormwater capital improvements through low-interest loans from GEFA in the form of Clean Water State Revolving Fund (CWSRF) loans.
  2. Meeting Regulatory Requirements: The Clean Water Act (CWA) framework requires programs to protect and restore surface water quality. These programs are required to restore and/or maintain the chemical, physical, and biological integrity of the waters of the United States. EPD is responsible for the implementation of the NPDES MS4 Permitting Program, which provides for water pollution control permitting, water quality standards, and non-point source pollution management. The program is reviewed every five years. Changes and modifications to the program can be problematic for local governments requiring additional funding to meet the limits of the program. Stormwater management is relatively new in the water world, and local officials may find it difficult to meet all existing stormwater requirements. In many cases, these requirements affect the development community. Local officials will be challenged with charges from developers that the program requirements are affecting economic growth in the community.
  3. Erosion and Sediment Control: The Erosion and Sedimentation Control Act (O.C.G.A. § 12-7-1 et seq.) is another regulatory requirement that can result in challenges from developers to local officials. Sediment must be controlled on site for all development. When not in compliance, developers are issued stop work orders on construction projects, which delays their ability to work and can be interpreted as an impediment to economic development. The Georgia Soil and Water Conservation Commission has published a Manual for Erosion and Sediment Control in Georgia that provides additional information and technical guidance.
  4. Stream Buffers: Stream buffers are protected in the state of Georgia. A buffer of 25 feet for warm water streams and a buffer of 50 feet for cold-water trout streams are currently mandated by state law. However, there are frequent attempts in the state legislature to redefine what a stream buffer is and what can take place in the buffer. Similarly, landowners continuously complain to local elected officials that buffers in many instances are affecting what they can do with their property.
  5. Best Management Practices (BMPs): As previously mentioned, stormwater rules, policies, and regulations are relatively new. The engineering profession and Best Management Practice (BMP) design companies have a hard time defining their effectiveness and the calculated value of pollutant removal in the treatment of stormwater. The Georgia Stormwater Management Manual (GSMM)/”Blue Book” mentioned above lists and defines regulatory requirements of these BMPs. Contention starts when local stormwater programs enforce them. Developers challenge the merits of BMPs and the interpretation from local staff. Once again, local elected official are likely to encounter pushback when implementing the GSMM.

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