I would also like to underscore why your agency's decision about revoking or modifying the permit will set a policy precedent, for good or for ill, regarding the implementation of the TMDL program in New York and across the nation. Southern Cayuga Lake is obviously impaired, but your agency has neither investigated the problems that were originally identified ten years ago nor taken rigorous action to eliminate them.
Public bathing is banned due to turbidity and high bacteria counts.
Algal blooms and aquatic weed infestations have created widespread aesthetic impairments. Uncontrolled toxic contamination sources are located at the lake's edge. Against that background, it is inconceivable that you are permitting a new discharge that will contribute to existing water quality violations. I believe that you may be mistaken about when your agency first inventoried problems in southern Cayuga Lake. Please resolve the conflicting dates for the record.