Georgia Environmental Protection Division Regulatory and Air Permit Fees Updates

Georgia Environmental Protection Division (GEPD) has proposed multiple changes and updates that relate to both water and air medias since the beginning of 2025. These changes are in response to U.S. Environmental Protection Agency (U.S. EPA) updating the Per- and Polyfluorinated Substances (PFAS) Maximum Contaminant Levels (MCLs) and other routine updates to plans. The sections below summarize what to know about the changes or proposed changes that will impact industrial facilities operating in Georgia.

PFAS Permitting Strategy Draft

GEPD has issued a draft memorandum dated January 31, 2025 that lays out the agency’s permitting strategy for PFAS. GEPD’s memorandum follows the U.S. EPA announcement of the final National Primary Drinking Water Regulation (NPDWR) for six PFAS on April 10, 2024, including establishing MCLs for six PFAS, with compliance required by 2029. Georgia is planning to adopt the PFAS MCLs for drinking water at G.A.C 391-3-5. U.S EPA announced in a press release on May 14, 2025 that the agency will keep the MCL for PFOA and PFAS but intends to rescind the regulations and reconsider regulatory determinations for PFHxS, PFNA, HFPO-DA, and Hazard Index mixture. U.S. EPA also intends to extend the PFOA and PFOS MCL compliance deadlines to 2031 and establish a federal exemption framework. GEPD has not updated their PFAS permitting strategies based on the press release.

GEPD’s permitting strategy is going to affect both Land Application Systems (LAS) and point-source facilities with National Pollutant Discharge Elimination System (NPDES) permits. GEPD has identified potential industrial categories that this will affect. All Public Owned Treatment Works (POTWs) may have presence of PFAS in their influent and effluent due to the presence of PFAS in common household products. Industry categories known or suspected to discharge PFAS, as identified by GEPD, include:

• Organic chemicals plastics and synthetic fibers (OCPSF)
• Metal finishing
• Electroplating
• Electric and electronic components
• Landfills
• Pulp, paper, and paperboard
• Leather tanning and finishing
• Plastics molding and forming
• Textile mills
• Paint formulating
• Airports
• Centralized waste treatment systems
• Remediation sites
• Other chemical manufacturing (not OCPSF)
• Military bases

Following the finalization of the PFAS permitting strategy, renewed LAS permits for POTWs and industrial categories listed above will include quarterly effluent and groundwater monitoring requirements for PFAS. Beginning in 2029, LAS permittees will be required to meet the new MCLs in the groundwater in downgradient monitoring wells. Compliance with the MCL will be determined by an annual average of the quarterly samples.

On December 6, 2024, U.S. EPA proposed to update 40 CFR §136 to include U.S. EPA analytical methods 1633 and 1631. Once those updates to 40 CFR §136 are promulgated, GEPD will begin requiring quarterly monitoring for PFAS in renewed NPDES permits for POTWs and listed industry categories with discharges upstream from drinking water treatment plants in receiving streams with a designated use of drinking water. Annual average effluent limitations may be incorporated into permits if determined to be necessary for the protection of drinking water plants.

2025 Triennial Review

GEPD initiated the 2025 Triennial Review of its water quality standards on February 7, 2025 and is accepting public comments and recommended topics for GEPD to consider until April 1, 2026. The 2025 Triennial Review includes the following for consideration based on U.S. EPA’s national criteria recommendations: 2018 Aquatic Life Criteria for Aluminum, 2019 Recreational Criteria or Swimming Advisories for Cyanotoxins, 2021 Ambient Water Quality Criteria to Address Nutrient Pollution in Lakes and Reservoirs, 2024 Aquatic Life Criteria for PFOA, 2024 Aquatic Life Criteria for PFOS, 2024 Draft Human Health Criteria for PFOA, PFOS, and PFBS. GEPD is also considering a designated use change to recreation for Chattahoochee River in Columbus, GA and internal site-specific criteria for lakes.

Notice of Draft 2025 Ambient Air Monitoring Plan

On May 16, 2025, GEPD released the Draft 2025 Ambient Air Monitoring Plan for public comment. The major changes from the 2024 Ambient Air Monitoring Plan include shutting down monitoring sites, implementing a data alignment feature on the PM_2.5 Teledyne T640, changing sampling frequency for PM_2.5 at multiple sites, and providing a waiver for the monitoring scale for the ozone monitor at the Gwinnett Tech site.

Georgia’s Second Maintenance Plan for the Atlanta Ozone Maintenance Area for the 2008 Eight-hour Ozone NAAQS

The metro Atlanta area was designated as nonattainment in 2012 in respect to the 2008 eight-hour ozone National Ambient Air Quality Standard (NAAQS). However, the area was redesignated as attainment in 2017. GEPD’s request for redesignation to attainment in 2016 was based on three years (2013-2015) of ambient monitoring data showing attainment of the ozone NAAQS (0.075 ppm). GEPD submitted the first maintenance plan for the metro-Atlanta area on July 18, 2016. The second maintenance plan demonstrates continued attainment with the 2008 ozone standard by showing that the metro-Atlanta area will not violate the standard.

Air Permit Fees Increase

GEPD requires owners and operators of each stationary source subject to the requirements of the annual Permit fee rule to complete a fee form on Georgia Environmental Connections Online (GECO) and payment of the fees on or before September 2, 2025. GEPD has developed an Air Permit Fee Manual for fees due between July 1, 2025 and June 30, 2026 (Air Permit Fee Manual) that details who is required to pay annual fees, including:

• permit application fees,
• New Source Performance Standards (NSPS) sources that are subject to annual fees (with exceptions detailed in Section 3.3.1),
• synthetic minor fees, and
• Part 70 source fees.

Annual fees are required to be paid for emissions of criteria pollutants [volatile organic compounds (VOC), sulfur dioxide (SO₂), particulate matter (PM), and nitrogen oxides (NO_X)] with methods of calculations found in Section 4.2 of the Air Permit Fee Manual.

There is an increase in fees for all types of permit applications and annual fees between July 1, 2025 through June 30, 2026 except Title V Renewal Applications (unless the renewal includes a qualifying modification) and Off-Permit Change Requests. If you are uncertain about what course of action to take regarding changes at your facility, you can contact the Air Branch’s Stationary Source Permitting Program. The table below lists all permit application and annual fees that are increasing for July 1, 2025 through June 30, 2026.

Fee Comparison: Fiscal Year (FY) 2026 and FY2025

The Part 70 Sources minimum fee has also increased from the previous year. The minimum fee that must be paid for FY2026 (July 1, 2025 – June 30, 2026) is $5,850 plus the maintenance fee in the above table. This is an increase from FY2025 (July 1, 2024 – June 30, 2025) of $4,500 plus the maintenance fee.

Facilities that operate or own a stationary source subject to the requirements of annual permit fees can get ahead of future increases by submitting air permit modifications prior to June 30, 2026 and prepare the annual fees calculations to pay the fee prior to the September 2, 2025 deadline.

Summary

ALL4 has extensive experience with environmental permitting and compliance in Georgia. If you have any questions about the changes discussed above or need assistance with Georgia water or air permitting and compliance, please contact Michael Harris at mharris@all4inc.com.