EnviroSchool Overview: General Permits 101: The LPDES General Permitting Program

By EvanMarie Allison, LABB Volunteer Coordinator

 

Attending the DEQ EnviroSchool General Permits class gave me good insight on how the organization operates and executes permitting/regulating procedures. I was happy to receive my copy of the in-depth informational Powerpoint slideshow. Our speaker started the presentation off with what an organization would typically start off with, the mission statement.  A slide with the Louisiana Department of Environmental Quality mission statement appeared on the screen and read ‘The Department’s mission is to provide service to the people of Louisiana through comprehensive environmental protection in order to promote and protect health, safety and welfare while considering sound policies regarding employment and economic development.’ The presenter made sure to clarify what the statement really means in case we got confused by the ‘environmental protection’ and ‘protect health, safety, and welfare’ part. To break it down for us he explained, “… it’s really more about a balance with economics”. He neglected to touch on the vision of LDEQ: to be a respected steward of the State’s environment, which was also printed on the slide.  Who has time to talk about visions when you can drag on and on about how the class will get out early enough for everyone to beat lunch hour traffic? The main focus of the presentation covered specific permits under the Louisiana Pollutant Discharge Elimination System (LPDES). LPDES is a program that ‘requires permits for the discharge of pollutants/wastewater from any point source into waters of the state’.  I was thrilled to learn that permits are only required for surface waters of the state and does not include ground water. It’s very comforting to know that when Hydraulic Fracking companies inject a toxic soup of fracking fluids into our water table LDEQ doesn’t have to be busied with paperwork. Instead of potentially bruising a business partnership we find a way to bring it back to that balance with economics. The presenter generously shared with us that northwest companies can sell their reused water to the fracking industry at a profit.

Next we dove into the general permit application process. The system seems democratic enough. An initial Notice Of Intent (NOI) is submitted and posted publically on the LDEQ website for public comment. Any controversial NOI’s are pulled from the site and are required to apply for an individual permit. It is unclear to me whether individual permits are available for public comment. The presenter gave the example of a barge. “Nothing is worse than a barge cleanup operation in regards to pollution.” Things really got good when the presenter stated, “I’m sure I’ve signed a permit that should have been for a higher discharge limit but these things can sneak through the cracks.” I commend his blasé honesty.  There are three parts of an LPDES permit but don’t waste your time on all three! Take the advice of our presenter, “Someone could really bypass part three and be just fine if you abide by parts one and two. But, there is some emergency procedure info in there that as a permit holder you should know”.  Oh, you know our fire departments? They are completely exempt from having to apply for a permit. Let’s hope that the honor system is never broken.

A colleague asked if large industries can apply for variances in regards to the newly added short-term and emergency discharge permit. It was explained that large industries do apply for them and a few are granted but the application is extremely complicated. I presenter suggested speaking with the Environmental Scientist Manager for further questions. The new shot-term and emergency discharge permit was briefly covered at the very end of the presentation when we had to squeeze everything in at the last minute before going over the two-hour mark. Good thing we got out just in time to hit that lunch hour traffic we were promised that we would avoid.

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