This blog post was written by Tyler Corby as part of the Spring 2018 UGA Urban Ecology class.
Atlanta’s watersheds occupy unique niches that demand special consideration. Downtown developments sit atop a watershed division that directs westerly runoff into the Chattahoochee River and ultimately into the Gulf of Mexico and easterly runoff into the Atlantic Ocean. Cumulatively, these watersheds impact hundreds of miles of aquatic waterways and two major marine bodies of water.
Atlanta—and many other major American cities—rely on CSO’s (combined sewer overflows) to handle both sewage and storm water runoff. Unfortunately, when runoff from excessive precipitation overwhelms the system, untreated sewage spills out of effluent pipes. Normally, this pipe would channel discharge to a waste treatment plant and ultimately a tributary of the Chattahoochee River, but when flooding occurs, untreated sewage overwhelms the system. Due to Atlanta’s proximity to the Chattahoochee River and the adjacent, low-lying areas like Proctor Creek and English Avenue, communities have faced floods exposing their community members to many feet of flood water containing untreated sewage.
In 1998, the City of Atlanta was sued by the State of Georgia and the United States of America for violation of the Clean Water Act. The resulting ordinance of 1999, known as the FACD (First Amended Consent Decree), required the city to (1) achieve full compliance with the NPDES (National Pollution Discharge Elimination System) emission levels for the WWTF’s (Wastewater Treatment Facilities) effluent. These effective pollution permits allow for and monitor pollutants—in this case nutrient loads—into bodies of water. Additionally, compliance with GWQCA (Georgia Water Quality Control Act) and CWA (Clean Water Act) water quality of the downstream section of the Chattahoochee River must be upheld. (2) The city must eliminate all unpermitted discharges; and, (3) prevent all sanitary sewage overflows. These requirements were to be completed and upheld by 2014.
Though the city of Atlanta implemented many projects, additional time and money were needed. In 2015, the city submitted an extension of the FACD to the federal government, which extended the projects’ timelines and laid out a funding scheme. The federal government approved this document, known as the Atlanta Water and Wastewater Bond, Series 2015. The bond, worth $1,237,405,000, details Atlanta’s CSO present and future actions to ensure proper emissions by 2027.
According to the bond’s outline, when the heaviest rain events occur, “flow volumes can exceed the combined treatment capacities of [WWTF’s].” When this happens, “four individual CSO control facilities are brought online as needed to provide additional treatment capacity prior to discharge to their respective receiving streams” (Wastewater Bond, 56).
Again, all CSO and WRC’s discharging into the Chattahoochee and South River basins must possess a NPDES permit, by federal law. This permit regulates acceptable levels of water quality degradation, particularly, dissolved Nitrogen and Phosphorous levels and fecal particulate matter. When left untreated, these pollutants can spread disease and damage waterways, thus impeding ecosystem services, reducing recreational fishing, and degrading drinking water.
Shockingly, Atlanta’s attempts to comply with federal pollution regulations do not protect its community members from physical inundation, disease, and impairment due to the design of CSO’s. The city has and continues to invest billions of dollars to fortify CSO operations under federal compliance, but these actions keep community members at risk. The actual solution is to separate storm water drainage systems from sewage systems. This action would ensure the safety of tens of thousands of residents.
The separating of wastewater and sewage infrastructure can be wildly expensive and cumbersome given the magnitude of construction needed in an urban environment. In the mid’90’s, however, Bremerton, Oregon successfully implemented an alternative solution to outright pipe separation. The city achieved this through, “pump station upgrades, treatment plant construction, storage and a major public involvement campaign” (City of Bremerton, 2010). The price tag including litigation, design and construction totaled $50.3 million. A PDF summarizing the city’s scheme can be found here. For comparison, the city of Atlanta’s 2018 fiscal budget approximates more than $10 billion (City of Atlanta, 2017). Thus far, the city’s revamped watershed bond has funded improvements to CSO’s, but has not created pump stations; therefore further construction may be required.
Centner, T. (2016). Environmental Law and Regulations to Protect People. University of Georgia: Cognella Academic Publishing
City of Atlanta. (2017). Fiscal Year 2018 Adopted Budget. Retrieved from: https://www.atlantaga.gov/home/showdocument?id=27831
City of Atlanta, Georgia Water and Wastewater Revenue Refunding Bonds, Series 2015. (2015). Atlanta Department of Watershed. Retrieved from: https://emma.msrb.org/EA707895-EA555714-EA952074.pdf
City of Bremerton. (2010). City of Bremerton achieves CSO Control Success. Retrieved from: http://www.ci.bremerton.wa.us/DocumentCenter/View/2090
First Amended Consent Decree. (1999). United States and State of Georgia, v. City of Atlanta, NO.l:98-CV-1956-TWT. Retrieved from: https://www.epa.gov/sites/production/files/documents/atlanta1999-cd.pdf
Upcoming Projects of 2017 & 2018-Green Infrastructure. (2017). Atlanta Department of Watershed. Retrieved from: http://www.atlantawatershed.org/default/?linkServID=3FF029AE-0845-44A4-8968048E33623650&showMeta=2&ext=.pdf
Website dedicated to comprehensive information specific to the case study’s CSO operation.
Government website organized by the Atlanta Department of Watershed Management.
This is the federal government-backed copy of the First Amended Consent Decree (FACD). This document curtails the lawsuit brought on by the EPA and Georgia EPD against the City of Atlanta, GA.
Document detailing the 2015 Atlanta Watershed Bond. Includes legislative history of Atlanta’s watersheds including the 2009 flooding of Proctor Creek.