In a strongly worded letter from a Columbus attorney on behalf of Granville and Johnstown, the two communities asked the Ohio Environmental Protection Agency to deny requests by Southwest Licking Community Water and Sewer District for a permit to build a wastewater treatment plant near Granville and Alexandria.

Attorney Stephen P. Samuels wrote in a May 1 letter that Southwest Licking’s request for permits “is rife with serious omissions, errors, and speculation; and embarrassingly bereft of data and analysis. The number and significance of these deficiencies are such that Ohio EPA should deny the permit application.”

Samuels sent a second, short letter on behalf of the communities asking the EPA for a public hearing on the permit request. The Village of Alexandria and the Granville and Johnstown-Monroe school districts also requested the hearing, which the EPA said will be held at 6 p.m. on July 16 at the Church of Christ at Alexandria, 5380 Moots Run Road.

“The hearing will last until all written and oral comments have been received,” an EPA public notice says.  Comments will be received through 5 p.m. on July 23. They can be sent via email to: or via mail to: Ohio EPA-DSW, Attn: Permits Processing, PO Box 1049, Columbus, OH 43216-1049. Include the NPDES number (ID No. 4PQ00007*AD) or project name (Raccoon Creek Wastewater Treatment Center) with each comment.

Jim Roberts, executive director of the Southwest Licking Community Water and Sewer District said that SWLCWSD officials have been open and transparent with officials in communities across western Licking County about district plans and operations, so he was “a little bit surprised at the tone and the attack mode” he read in the longer letter.

Roberts also said the letter included misinformation: “There are a lot of things in there that we don’t believe are true,” he said.

Granville is keenly interested in the SWLCWSD proposal, not only because of the potential development pressures it could bring, but also because, if the EPA approves, it would discharge treated wastewater into Moots Run just upstream from Raccoon Creek, said Granville Village Manager Herb Koehler. 

This maps shows where treated wastewater would be discharged into Moots Run from the proposed treatement plant atop a hill near the intersection of General Griffin Road, which runs parallel to Rt. 161, and Outville Road west of Granville and south of Alexandria. Credit: Ohio EPA public records

Raccoon Creek flows through Granville and helps replenish the wells from which Granville draws drinking water for Granville and Alexandria.

“As part of the permit process, citizens or public entities can ask for a public hearing, and that’s what we’ve done,” Koehler said.

Officials in Johnstown believe that a variety of alternatives should be explored when it comes to the construction of a new wastewater treatment plant, said City Manager Sean Staneart. 

“These alternatives could address the challenges and opportunities the communities face within western Licking County,” he said. “Some of these challenges and opportunities include but are not limited to local governance over our natural resources, impacts to the schools, providing quality-controlled development, maximizing economic opportunity, citizens’ health and safety, protection and preservation of greenspace and stream corridors, transportation planning, and providing quality utilities services in a cost-effective, efficient manner.”

This view of Moots Run, photographed from a bridge on Moots Run Road on Wednesday, May 29, shows the shallow creek flowing toward Raccoon Creek in the distance beyond the corn field. A wastewater treatment plant proposed by Southwest Licking Community Water and Sewer District would discharge as much as 3 million gallons of treated water into Moots Run daily. Credit: Alan Miller

Staneart said these alternatives would take into consideration current and future capacities for both water and sewer within systems operated by Alexandria, Granville and Johnstown, as well as other municipal providers currently in operation.

Samuels’ letter on behalf of Granville and Johnstown said that SWLCWSD “has conceded, as it must, that its proposed treatment plant will adversely impact the receiving stream. The proposed point of discharge is in the headwaters of a (likely) zero low-flow, pristine stream, Moots Run, immediately above its confluence with Raccoon Creek.

“To our knowledge,” Samuels wrote, “this is the only new major wastewater treatment plant that has ever been proposed in Ohio at such an (inappropriate) location. Moreover, as the comments below detail, (Southwest Licking) has failed to perform a good faith evaluation of the alternatives, provide any chemical or biological data on the existing quality of the receiving streams or the uses the public make of them, much less any analysis of the impacts the discharge would have.”

Roberts said the location for the proposed plant – on 92 acres the district owns just south of Rt. 161 and east of Outville Road – was selected with guidance and input from the Ohio EPA. It was picked in part, he said, because it would be near Moots Run and its confluence with Raccoon Creek and Lobdell Creek, where water flowing from the three streams would increase assimilation of discharge from a plant treating up to 3 million gallons a day.  

The Southwest Licking Water and Sewer District purchased 92 acres (most of which is outlined in in blue-green on this map) with plans to build water- and sewage-treatment plants on the site. The purchased happened in 2023, and the district’s announcement about its plans raised concerns in St. Albans and Granville townships. Credit: Licking County auditor's website

Samuels also wrote that the rationale Southwest Licking presented to justify the plant – “to allow/encourage significant economic development – justifies the adverse impacts the facility will have on the interests of the vast majority of the local residents and political subdivisions,” especially the school districts, which rapid development that could result if the wastewater treatment plant is built.

Roberts said “the district doesn’t promote development at all. We react when a community in our service area wants to develop. We’re never on the front end of development, but always on the back end responding.” 

This map shows the parts of Licking County that would be served by Southwest Licking Community Water and Sewer District’s proposed wastewater treatment plant in St. Albans Township. Credit: Ohio EPA public records

At this point, he said, the district wants to serve fast-growing Jersey Township and the Rt. 161 corridor west of Granville.

Koehler said it’s not a matter of Granville and Johnstown trying to kill a wastewater-treatment-plant proposal, but one of whether the one being proposed is in the best location and whether it’s the right size.

“It’s not about us trying to stifle development as it is about making sure it’s done properly,” Koehler said.

Samuels’ letter says that there are at least five other wastewater treatment facilities that could serve the area that Southwest Licking proposes to serve. They are operated by Columbus, Johnstown, Granville, Alexandria, and Southwest Licking at its Gale Road plant.


“However, the application contains no documentation of capacity reviews about or from any of them, or their willingness (individually or collectively) to accept the projected flows,” Samuels wrote. “Indeed, to our knowledge, the Gale Road facility alone currently will soon have sufficient excess capacity to treat all the ‘expected’ flow.

Roberts said “the numbers about our existing plants are not correct, and we have significant development pressures in the area served by our current plants that will quickly fill them.”

And he said that the other options mentioned in the letter don’t make sense. “Johnstown’s plant is upstream,” he said, and Alexandria’s plant is small and could handle only a couple of additional housing subdivisions.

“Granville hasn’t shown interest in taking wastewater from outside Granville Township,” Roberts said. “None of those seem to be realistic options.”

The hilltop cornfield to the right, at the intersection of General Griffin Road, just south of Rt. 161, and east of Outville Road, is the proposed location of a sewage treatment plant that Southwest Licking Community Water and Sewer District wants to build. These 92 acres stretch from General Griffin Road on the north to Morse Road on the south. Treated wastewater would be discharged into nearby Moots Run, a small creek that flows into Raccoon Creek. This photo looks east from Outville Road.

Samuels also wrote on behalf of Granville and Johnstown that land Southwest Licking bought for the proposed plant “suffers from the significant defect that the location of it is at one of the highest elevations along the 161 corridor,” adding that “it appears that this land was purchased and the environmental and financial costs to ‘make it work’ were not considered.”

Roberts said it’s not uncommon to pump sewage uphill for treatment, and that it was part of the consideration in picking that spot. 

Samuels stated that the plant would be oversized when viewed in the context of growth trends and existing capacity at other plants, which Roberts disputed, saying that the plant could serve a large portion of western Licking County. 

“All the area that we are proposing to service through the Raccoon Plant is within the boundaries of the area we have authority to service,” Roberts said. That service area covers more than 18,000 acres west of Granville, including all of Jersey, Monroe and St. Albans Townships.

Samuels concluded by writing that Southwest Licking did not make a good faith effort to respond to important questions in the permit request. Ultimately, the EPA will decide after hearing from the communities.

Alan Miller writes for, the nonprofit news organization of Denison University’s Journalism program, which is funded by the Mellon Foundation and donations from readers. Sign up for The Reporting Project newsletter here.

Alan Miller

Alan Miller teaches journalism and writes for, the nonprofit news organization of Denison University's Journalism Program. He is the former executive editor of The Columbus Dispatch and former Regional Editor for Gannett's 21-newsroom USAToday Network Ohio.