NC0021253_CORRESPONDENCE_20071029

NPDES DOCUMENT SCANNING COVER SHEET
NPDES Permit:
NCO021253
Havelock WWTP
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Engineering Alternatives Analysis
201 Facilities Plan
Instream Assessment (6713)
Correspondence re: Modeling
Permit
History
Document Date:
October 29, 2007
This docameat is priated on reuse paper -ignore aay
ooate mt oa the reverse side

Michael F. Easley, Governor
State of North Carolina
William G. Ross, Jr., Secretary
Department of Environment and Natural Resources
Coleen H. Sullins, Director
Division of Water Quality
October 29, 20071IV 0002U j3
Mr. H. Thomas Tant, P. E.
Senior Associate
HAZEN AND SAWYER, P.C.
4011 WestChase Blvd.
Suite 500
Raleigh, NC 27607
Subject: City of Havelock Wastewater Treatment Plant
Discharge Relocation — River Modeling Approach
30906-005
Dear Mr. Tant:
The NPDES Unit and the Modeling Unit have reviewed your proposal for modeling the proposed
relocated discharge for the City of Havelock's wastewater treatment plant. The proposal, using Tetra
Tech to develop and run the model, includes all elements and parameters requested by the Division
during our August 14th meeting. The modeling proposal is hereby accepted and approved; no further
pre -modeling meeting will be required.
The Modeling Unit has requested that a brief (one to two pages) bullet type summary of the work be
provided at the completion of each of the six enumerated tasks. Where appropriate, multiple tasks could
be combined for summary. The summaries should be sent to Mr. Gil Vinzani, Supervisor, Eastern
NPDES Program. A final report and review meeting may still be required.
If there are any questions, please contact me at [phone], ext. 595, or by email at
jame§[e-mail].
Sincerely,
A,"
Jim McKay ✓
Eastern NPDES Program
CcOil Vinzani -Eastern NPDES Program
Kathy Stecker — Modeling/ TMDL Unit
N 11621
®Tn
NCDENR
North Carolina Division of Water Quality 1617 Mail service Center Raleigh, NC 27699-1617 [phone] Customer Service
1 800 623-7748

HAZEN AND SAWYER
Environmental Engineers & Scientists
September 24, 2007
Mr. Gil Vinzani
Supervisor, Eastern NPDES Program
Division of Water Quality
NPDES Unit
1617 Mail Service Center
Raleigh, North Carolina 27699 — 1617
Dear Mr Vinzani:
Hazen and Sawyer, P.C.
4011 WestChase Blvd.
Suite 500
Raleigh, NC 27607
[phone]
2 [phone] (Fax)
SEP 2 5 2001 Di
DENR - WATER QUALITY
POINT SOURCE BRANCH
Re: City of Havelock Wastewater Treatment Plant
Discharge Relocation — River Modeling Approach
30906-005 A 1 C00 91 2),s3
On August 14", 2007 we met with you and other members of the Division of Water Quality
(the Division) staff to discuss the City of Havelock's future wastewater treatment and effluent
discharge needs. A significant component of these future improvements and upgrades will
be dealing with effluent discharges in excess of what is currently permitted in the East Prong
of Slocum Creek. This need was also considered in light of the Division's desire to eliminate
the effluent discharge into Slocum Creek.
The concept that is being considered to address both the City of Havelock's needs, and the
Division's concerns with effluent discharge into Slocum Creek, is relocation of the City's
effluent discharge from the East Prong of Slocum Creek to the main body of the Neuse
River. This approach would include a hydraulic capacity expansion, with no net increase in
nutrient load on the river basin.
The location being considered for the relocated discharge is downstream of the existing
Cherry Point wastewater treatment plant effluent discharge, and upstream of Hancock Creek.
It was agreed during our August 14`n meeting that modeling of the river discharge would be
required to determine the water quality effects of this discharge on the river, as well as
identify any impacts the City's discharge may have on the existing Cherry Point discharge.
The City of Havelock is proposing to complete this modeling work. As part of our ongoing
engineering services to assist the City of Havelock with its long term wastewater needs, we
are proposing the employ the services of Tetra Tech to complete the river modeling and
water quality evaluations related to the proposed discharge. Tetra Tech has extensive
modeling experience with the Neuse River estuary, and we believe are uniquely qualified to
complete this work
During our meeting, it was agreed that we would provide the proposed river modeling
approach to the Division for review and approval in advance of proceeding. If pursued, the
City will make a significant investment in this effort to determine the impacts of the relocated
discharge. It will be very important that we have the Division's input on this work in advance
of proceeding.
"I
New York, NY • Armonk, NY • Woodbury, NY • Detroit, MI • Raleigh, NC • Charlotte, NC • Atlanta, GA • Fairfax, VA • Hollywooa, FL • Boca Raton, FL • Fort Pierce, FL • Sarasota, FL • Miami, FL • Philadelphia, PA
New York, NY • Philadelphia, PA • Raleigh, NC • Charlotte, NC • Greensboro, NC • Charleston, SC • Atlanta, GA • Fairfax, VA • Baltimore, MD - Cincinnati. OR - Hollywood FL • Boca Raton, FL • Sarasota. FL • Miami, FL

RvEN AND SAWYER
Mr. Gil Vinzani
September 24, 2007
Page 2
To that end, we have worked with Tetra Tech to develop a scope of work and modeling
approach for this project. We have attached this scope and approach for the Division's
review.
We will make ourselves available to meet with you to discuss any questions or comments
you or other members of the Division staff have. Following reconciliation of any questions or
concerns, we request the Division's approval of the river modeling approach so that the City
can authorize it to proceed.
Please do not hesitate to call Mr. Trevor Clements at [phone] ext 100, or me at (919)
833-7152, with any questions or comments.
Very truly yours,
HAZE�N AND SAWYER, P.C.
H. Thomas Tant, P.E.
Senior Associate
Htt/htt
Enclosure
cc: Mr. Jim Freeman, City of Havelock
Mr. Pete Deaver, City of Havelock
Mr. Trevor Clements, Tetra Tech
Mr. Ron Taylor, Hazen and Sawyer

City of Havelock proposed discharge relocation
Subject: City of Havelock proposed discharge relocation
From: "Tint. Thomas H." <[e-mail]>
Date: Mon, 24 Sep 2007 10:07:56 -0400
To: " ([e-mail])" <[e-mail]>
CC: "Clements, Trevor" <[e-mail]>, Jim Freeman
<[e-mail]>. "Taylor, Ronald L." <[e-mail]>. "Pete Deaver
([e-mail])" <[e-mail]>
Gil, we have attached a cover letter and proposal for your consideration with respect to the river modeling efforts
for the City of Havelock's proposed wastewater discharge relocation project. Once you and others have had an
opportunity to review this, let us know if a follow-up meeting is warranted in advance of receiving the Division's
approval of the approach. We are submitting this in response to our meeting with you and other Division staff in
August.
We are very appreciative of the Division's assistance in this matter and please do not hesitate to contact us with
any questions.
Thanks, Tom
H. Thomas Tant, P.E.
Senior Associate
Hazen and Sawyer, P.C.
Raleigh, North Carolina
Office: 919-833-7152
Content -Description: vinzani 09 24.07 1trhd.PDF
vinzani 09.24.071trhd.PDFI Content -Type: application/pdf
Content -Encoding: base64
I of 1 9/27/2007 3:48 PM

Scope of Work
Water Quality Modeling Analysis for City
of Havelock WWTP Discharge to Neuse
River Estuary
Prepared for Hazen and Sawyer
Tetra Tech, Inc.
PO Box 14409
Research Triangle Park, NC 27709
September 13, 2007

Tetra Tech Scope or Work - Neuse Estuary Modeling 9113107
Table of Contents
lntroduction.... .__......... ............... ..._................................... ..........................
....._..... I
2 Description of Work..._.........................._................................................._........_..... I
Task I — Existing Data Compilation and Review ................._. ............................... I
Task IA - Compile Existim._ Data............................................................................... l
Task I B - Compile and Review Existing Studies ............................................. ....... .. I
Task 2 - Model Development ........ .._......................... .........._..._.._........._................_.. 2
Task 2A - EFDC Grid Refinement.__.........._....._..................................................... 2
Task 2B - Additional EFDC Setup ...................................... ....... ............. ............ .._... 2
Task2C - WASP Setup............................................................................................... 3
Task 2D — Determination of Critical Period . ...................... ......... .............................
. 3
Task 3 - Model Simulations. ..................................... ................... ................................. 3
Task 4 — Model Output and Results ... ............................................................................. 3
Task6— Modeling Report ._ .... ...............................................................................__...4
Task 5 - Project Management and Coordination............................................................ 4
3 Schedule and Deliverables.........................................................__..............................4
OTETPA TECN.INC

Tetra Tech Scope of Work - Neuse Estuary Modeling 9113107
1 Introduction
The City of Havelock (City) currently discharges treated waste water to Slocum Creek,
which flows to the Neuse River Estuary. The City has contracted with Hazen and Sawyer
(1-l&S) to evaluate wastewater treatment options including an expansion and relocation of
their existing discharge. Following the guidance from the North Carolina Division of
Water Quality (DWQ), I &-S is evaluating a relocation of the existing discharge outfall to
the Neuse River Estuary downstream of the existing Cherry Point W WTP outfall FI&S
has requested a modeling evaluation of the proposed discharge on water quality in the
estuary. Quality considerations include the effect of nutrients and biochemical oxygen
demand (BOD) on response variables: dissolved oxygen (DO) and chlorophyll a (chl a).
In addition, the mixing characteristics at the outfall will be evaluated for an
understanding of effluent dilution (and any associated chronic and acute toxicity) for the
City's outfall as well as potential interaction with the Chevy Point discharge plume.
2 Description of Work
TASK 1 — EXISTING DATA COMPILATION AND REVIEW
Tetra Tech will perform necessary data gathering and review of past work.
Task 1A - Compile Existing Data
Existing data for model development will be collected and reviewed. Data categories
include discharger, meteorological, hydrodynamic and water quality. Sources of the data
may include DWQ, City, MCAS Cherry Point, NCSU CAAE, UNC-CH IMS, USGS,
and NCDC. Water quality data will include ambient data, long term BOD, and others as
needed to support model development. The bathymetry needed to describe the bottom
elevation will be of particular importance (Tetra Tech will work with existing sources no
collection of new survey information is implied). Tetra Tech will seek'thorough
coordination with Hazen and Sawyer, City, and DWQ to ensure that the best information
is incorporated into the model -
Task 1B - Compile and Review Existing Studies
The available reports and documents related to the MCAS Cherry Point W WTP outfall
including the prior mixing zone analysis will be reviewed to represent the outfall in the
model. Relevant considerations are the geometric properties of the outfall, discharge
characteristics (flow and quality), and ambient conditions. Geometric properties include
features such as number of ports, relevant angles, spacing, and diffuser length.
Consistency with the past MCAS Cherry Point work will be assessed and incorporated as
appropriate.
OTETPUTECNJNC.

Tetra Tech Scope of Work — Neuse Estuary Modeling 9113107
In addition to the prior Chevy Point analysis, model files and documentation from the
Neuse River Estuary TVtDL modeling will be retrieved and organized to provide the
foundation for the current work.
TASK 2 - MODEL DEVELOPMENT
Tetra Tech will build modeling tools for the current effort based on the previous EFDC
and WASP models of the Neuse Estuary developed for the existing nitrogen TNIDL. An
EFDC application coupled with its near -field mixing sub -model, Jet -Plumes F DC
(JPEFDC) will be developed for the project, which will be linked to a WASP model. The
EFDC application will represent the hydrodynamic components including near -field
mixing and dilution at the edge of the mixing zone, while WASP (Version 7.2) will
represent the fate and transport of nutrients (nitrogen and phosphorus) and BOD, as well
as response variables of DO and chi o. Together, these tools provide a dynamic, three-
dimensional, and robust framework to represent the complex Neuse River Estuary and
impacts of the City's discharge.
Task 2A - EFDC Grid Refinement
Using the previous modeling effort as a starting point, the grid for the area of interest will
be extracted and modified to a finer resolution using the best bathymetty data available.
To address the near -field mixing zone dynamics, a finer model grid in the vicinity of the
Neuse Estuary around Slocum Creek tributary and Cherry Point. Implementation of the
finer EFDC model grid, combined with use of the JPEFDC sub -model embedded within
EFDC, will provide the capability to look at near -field mixing and dilution at the edge of
the mixing zone. Use of a conservative tracer in the modeling will also allow for analysis
of any relative mixing interaction between the Cherry Point discharge and effluent front
the proposed relocated City outfall.
Task 2B - Additional EFDC Setup
The Neuse River estuary is a shallow system that is poorly connected to the ocean. As a
consequence the tidal range is relatively small and the typical patterns and sequence of
high tide/low tide are not present. The water level is more highly impacted by the wind
forcing. The wind forcing will be constructed by available data with primary focus oil
the bend. There is a lack of observed water surface elevation in the Neuse River estuary.
Therefore, some effort will need to be applied to review available discontinuous depth
observations from various sources in order to assess a critical period as well as construct
a continuous open water boundary forcing. Freshwater flows will be dominantly
influenced by the Neuse River at the headwater of the estuary. Remaining watershed
area, except for Trent River at Trenton, will be represented by area -weighting the daily
average flow record from Trent River at Trenton. A salinity forcing will be developed
for the open boundary and assigned after a review of observed data from various sources.
The water temperature forcing for the open boundary will be developed from observed
data in the vicinity of the open boundary of the grid. The water temperature forcings for
the freshwater flows may be assigned from a headwater observation station or a sine
curve fitting of observed data. Following set up, EFDC will be linked to the WASP
model for quality simulation through use of a linkage file.
OTETPA iECM.INC
K

Tetra Tech Scope of Work — Neuse Estuary Modeling 9113107
Task 2C - WASP Setup
The EFDC application will produce a hydrodynamic linkage file (HYD) that will pass
hydrodynamic forcings to the WASP model. A series of pre-processing steps will then
be applied to develop the WASP model input including kinetics constants, weather time
functions, point source water quality loadings, and boundary concentration conditions.
Tetra Tech will coordinate with Hazen and Sawyer and the City to determine the input
forcings for the W WTP effluent. ammonia, niu ite+nitrate, and organic nitrogen,
fractioning for orthophosphate and organic phosphorus, and long-term BOD f-ratio.
Task 2D — Determination of Critical Period
The ambient flow condition, particularly the ambient velocity, is a critical component in
the evaluation of mixing. The model will be run for a period, or periods, that represent
least ambient velocity and mixing to incorporate critical conditions of greatest impact. fit
addition, the ambient density condition will be evaluated by considering a representative
winter and summer period. This will broadly cover cool and warm conditions in the
ambient receiving water. Furthermore, the historical salinity observations will be
reviewed to help assess what time period represents critical conditions and thus define the
simulation period(s). The observed and simulated water temperature and salinity as a
surrogate for density will enable selection of a critical period.
TASK 3 - MODEL SIMULATIONS
The City's WWTP expansion and associated relocation is planned to occur in three
phases. Model simulations will be based on conditions with and without the discharge
and associated effluent flow and quality characteristics (under Phase I, fl, and 111). In
addition, a maximum of two outfall configurations to the Neuse River Estuary will be
modeled — either two separate diffttser configurations evaluated at one discharge location,
or one diffuser configuration evaluated at two separate discharge locations. (FI&S will
provide diffuser configurations based on guidance provided by DWQ for diffusers
previously approved by DWQ, and guidance from Tetra Tech based on prior diffuser
analysis, with modifications if necessary or warranted for enhanced mixing). Further,
simulations will focus on critical conditions and will evaluate both winter and summer
time periods.
TASK 4 - MODEL OUTPUT AND RESULTS
Output generated from model simulations will be post -processed, evaluated, and
summarized. The primary evaluation metrics for the proposed work include dissolved
oxygen and dilution (acute and chronic). Output will also be provided for secondary
variables including BOD, nitrogen, phosphorus, chi a. Note that the City has a waste
load allocation for nitrogen under the existing TMDL that cannot be increased (21,400
Ibs/yr TN).
The DO response to BOD and nutrients will be evaluated at both near -field and far -field
points of interest mutually agreed upon in early discussions with DWQ. In addition,
Tetra Tech will evaluate dilution and mixing zone issues using the JPEFDC sub -model
OTETMTECN.INC
3

Tetra Tech Scope of Work — Neuse Estuary Modeling 9113107
within EFDC. Tetra Tech will work with H&S, the City, and DWQ to determine what
time scale is appropriate to evaluate the acute and chronic dilution and the location of the
regulatory prescribed area around the outfall. Finally, the values and relative change for
seconclary variables of interest (BOD, nitrogen, phosphorus, chl a) will be provided based
on model simulations with and without the dischar_e.
TASK 5 - MODELING REPORT
A report will be developed by Tetra Tech documenting model development, simwlations;
and results. It is expected that there will be two draft versions and a final. The first draft
will be reviewed by Hazen and Sawyer and the City of Havelock. A second draft
incorporating comments from Flazen and Sawyer and the City of Havelock will be
prepared for DWQ review. Continents received from DWQ will be incorporated into the
final version of the modeling report as appropriate.
Tetra Tech will develop a PowerPoint presentation of the results and final report. and
deliver it to the City, H&S and DWQ at a mutually convenient meeting time.
TASK 6 - PROJECT MANAGEMENT AND COORDINATION
Tetra Tech will need to meet, plan, coordinate and correspond with staff from }lazes and
Sawyer, the City, DWQ and others as appropriate. Coordination and management needs
will include data collection, further clarification of technical issues and model
assumptions, presentation and discussion of progress on work tasks, guidance or direction
for modeling assumptions, exchange of data and information, and routine project
planning. Communication will take place in the form of in -person meetings, email,
conference calls, and written progress reports. Tetra Tech will prepare and transmit to
Hazen and Sawyer monthly progress reports and invoices for the project.
3 Schedule and Deliverables
The proposed schedule for completion of tasks is as follows:
Task l : Complete compilation and review of existing data and modeling reports, and
preliminary determination of critical conditions within 30 clays of notice to proceed.
Task 2: Complete model set-up within 90 days of notice to proceed (assuming no
problems in obtaining data and modeling information under Task I).
Task 3: Complete model simulations within 150 days of notice to proceed.
Task 5: Complete draft model documentation within 180 days of notice to proceed. A
technical memo will be delivered in *.pdf electronic format. A final technical memo will
be delivered within 15 business days of receipt of all continents from DWQ. Results will
be presented to and discussed with the City, H&S, and DWQ at a mutually convenient
date.
Task 6: Progress reports will be submitted along with monthly invoices.
OTETPA TECM.IXC.

have%ck - proposed ouLfalls
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havrock - proposed outfalls
Subject: havelock - proposed outfalls
From: Mike Templeton <Mike.Templeton@ncmaiLnet>
Date: Mon, 13 Aug 2007 15:56:12 -0400
To: Kathy Stecker <Kathy.Stec ker@ncmaiLnet>, Adugna Kebede <Adugna.Kebede@ncmaiLnet>, Matt
Matthews <Matt.Matthews@ncmaiLnet>, Gil Vinzani <Gil.Vinzani@ncmailnet>, Teresa Rodriguez
<Teresa.Rodriguez@ncmaiLnet>, Karen Rust <Karen.Rust@ncmailnet>, Ron Berry
<Ron.Berry@ncmailnet>
The Neuse estuary in the vicinity of Havelock is classified three ways (see the map below):
• NEUSE RIVER, 27(96) From Streets Ferry to a line across Neuse River from Johnson Point to
McCotter Point: SC Sw NSW
• NEUSE RIVER, Segment 27-(104) From a line across Neuse River from Johnson Point to
McCotter Point to aline across Neuse River from Wilkinson Point to Cherry Point: SB Sw NSW
• NEUSE RIVER, 27(1 18) From a line across Neuse River from Wilkinson Point to Cherry Point
to its mouth in Pamlico Sound (mouth of Neuse River described as a line running from Maw point
to Point of Marsh): SA HQW NSW
The three sites Havelock identified for its new outfall (thanks, Karen) are numbered in the map below.
The first two would discharge to SB Sw waters. The #3 site sits more -or -less on the divide between two
segments so, given the tidal regime here, would be treated as a discharge to SA HQW to be
conservative.
rz'c'eQ a,, � V '" J
I of 2 8/14/2007 820 AM

TETRATECH
3200 Chapel Hill -Nelson Hwy, Suite 105
PO Box 14409
Research Triangle Park, NC 27709
Tel [phone] Fax [phone]
MEMORANDUM
To: Tom Tant, P.E., Project Manager
Hazen & Sawyer
From: Trevor Clements, Director
Watershed Management Services
Cc: Steve Davie, P.E., Greg Sousa, P.E.,
Todd Kennedy, Q.E.P.
Date: July 31, 2007
Subject: Advance Materials for Meeting with
NCDWQ and City of Havelock
Proj. No. H&S# 30906-005
TO 100-RTP-T20804
Please share the following information with the North Carolina Division of Water Quality (DWQ) in
advance of our scheduled meeting for August 14, so that everyone can prepare accordingly.
Tetra Tech Conceptual Modeling Approach
The final modeling proposal will be developed after the 8/14/07 meeting with DWQ. The purpose of the
meeting is to discuss NC regulations, DWQ policies, and DWQ staff expectations regarding the proposed
modeling work such that an appropriate modeling effort can be designed and carried out efficiently.
However, we understand that it will be helpful for DWQ to know conceptually what we have in mind so
that the meeting will be as productive as possible. In that regard, the following conceptual approach is
offered.
Tetra Tech will build off of the previous EFDC and WASP models of the Neuse Estuary that was t'X15Lt 5
constructed by Tetra Tech for EPA Region IV as part of the nitrogen TMDL development effort. For
consistency purposes, it will be best to use the tool that the TMDL (with corresponding point source
wasteload allocations and nonpoint source load allocations) is based upon.
The model application will be modified to help address the near -field modeling questions. This will be
accomplished by creating a finer model grid in the vicinity of the Neuse Estuary around Slocum Creek
tributary and Cherry Point. Implementation of the finer EFDC model grid, combined with use of the Jet �t rt2 r
Plumes submodel embedded within EFDC, will provide the capability to look at near -field mixing,
dilution at the edge of the mixing zone, as well as far -field water quality impacts. Use of conservative p 7
tracers in the modeling will also allow for analysis of any relative mixing interaction between the Cherry
Point discharge and effluent from the proposed relocated Havelock outfall.
Questions for DWQ to Support Detailed- Model Approach Development
In order for Tetra Tech to refine its conceptual approach into a detailed modeling scope, the following
questions need to be answered by DWQ: W (,.ate _4� wK w . lvr
1. What are the specific modeling en¢pQints_(list of parameters) that DWQ will want provided for
their review? Please note any differences between parameters that will be reviewed in near -field
locations versus far -field locations relative to the outfall.
complex world
CLEAR SOLUTIONS'"

( 1 3 wtk`)
Tt Advance Materials for Meetth
31.2007
2. What criteria wilYbe relevant for the modeling endpoints? Again, please clarify any differences
between near -field and far -field locations.
3. Are there specific regulatory or policy considerations that DWQ will make between single -port or 7111/0"
multi -port diffusers? (If so, please provide a description and explanation of each)
" V_UtC4.
What DWQ waste load allocation (WLA) policies are applicable given that the discharge will be
Mgt CAS'"
relocated in addition to being expanded?
5.
Are there specific requirements or expectations regarding representative critical conditions that
`y1At✓19
need to be considered in setting up boundary conditions and the hydrologic record for driving the
model predictions? Please note how these might differ between the upper Neuse River tributary
versus the near -field Slocum Creek tributary.
6.
Does DWQ have any mixing zone modeling of the Cherry Point discharge that it can provide to
Tetra Tech for reference? (Please describe what is available.)
7. Are there any other modeling assumptions or regulatory factors for Tetra Tech to consider in
developing its detailed approach? If so, please describe and explain each.
Thank you in advance for your efforts to share this with DWQ staff as quickly as possible to provide for
better preparation and a successful kick-off meeting. Please do not hesitate to call if you have any
questions or need further explanation on anything (485-8278 ext-100).
l M17�
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Draft Agenda
City of Havelock WWTP Future Needs, Proposed Expansion, and Discharge Relocation
Kickoff Meeting with NCDENR DWQ
Date: August 14, 2007
Time: 10:00 am
Location: 9`h Floor Conference Room, Archdale Building
1. Introductions
2
3
9
a
31
Review meeting purpose
Existing conditions/efforts to reduce WWTP flow
Proposed Approach and Improvements 'X
a. Flow projections
b. Review process and capacity evaluations for future needs
i) No net increase in mass loading of nutrients
ii) BOD permit limit
Proposed river modeling for discharge relocation (see attached Tetra Tech July
31, 2007 Memo)
Interim solution for Havelock WWTP discharge
7. Permitting process and next steps
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