Brown, Judge. The primary issue in these appeals is the propriety of a decision reversing an administrative law judge’s revocation of a permit issued by the Environmental Protection Division of the Georgia Department of Natural Resources (“EPD”) to Brantley County Development Partners (“the Developer”) to build and operate a solid waste landfill in Brantley County pursuant to OCGA § 12-8-20 et seq., Georgia’s Comprehensive Solid Waste Management Act (“the Act”). For the reasons discussed below, we affirm. Background[1] These appeals arise from an application filed by the Developer with EPD on December 29, 2016, pursuant to OCGA § 12-8-24, seeking a solid waste handling permit for a new municipal solid waste landfill, materials recovery, processing facility and thermal treatment facility on a parcel of land in Brantley County.[2] In Georgia, a person seeking to operate a solid waste handling facility must obtain a solid waste handling permit by application to EPD pursuant to the Act. See OCGA § 12-8-24 (a). As part of the permitting process, the applicant must submit two consistency letters from the local governing authority verifying that the proposed site complies with local land use ordinances and is consistent with the local or regional Solid Waste Management Plan (the “SWMP”). See OCGA § 12824 (g); Ga. Comp. R. & Reg. 39134.02 (9) and 391-3-4-.05 (1) (a). See also Dunn v. City of Stonecrest, 368 Ga. App. 736, 737 (890 SE2d 781) (2023) (noting that the Act requires an applicant to provide written verification (a “‘consistency letter’”) to EPD that the proposed facility is consistent with the local SWMP); Murray County v. R & J Murray, LLC, 280 Ga. 314, 315-316 (627 SE2d 574) (2006) (explaining the purpose of the Act and the applicant’s obligation to obtain written verification from the local government that the proposed facility is consistent with its SWMP). The Act also requires public participation when a county takes action regarding the siting of a publicly or privately owned municipal solid waste disposal facility. See OCGA § 12-8-26. See also Emmons v. City of Arcade, 270 Ga. 196, 197 (507 SE2d 464) (1998) (noting that OCGA § 12-8-26 governs “the conduct of local government meetings concerning solid waste disposal facility site decisions,” including scheduling and proper notice). Additionally, pursuant to EPD rules, written verification of local zoning compliance must be “reaffirmed by the governmental authority prior to permit issuance.” Ga. Comp. R. & Regs. 39134.05 (1) (a). During the application process — and in response to deficiency letters from EPD — the Developer submitted consistency letters executed in 2014 and 2015 by then-chairmans of the Brantley County Board of Commissioners (“the Board”), as well as documentation that a siting meeting was held on December 22, 2016, for public comment on the proposed solid waste facility.[3] On January 6, 2017, a year into the process, the Brantley County Board of Commissioners (“the Board”) wrote to EPD voicing its “unanimous[ ]” opposition to the Developer’s application on the ground that it did not comply with the requirements of OCGA § 12-8-26, and asserting that the county had placed a 180-day moratorium on any type of waste facility. EPD nonetheless issued the permit on May 9, 2022. Following issuance of the permit, the Board filed a petition to challenge EPD’s action in a hearing before an ALJ of the Office of State Administrative Hearings pursuant to OCGA § 12-2-2 (c) (2) (A) and Georgia’s Administrative Procedure Act (APA), OCGA § 50-13-1 et seq. The petition challenged the permit on various grounds, including that consistency letters issued in 2014 and 2015 by Brantley County officials — and required to be filed with all applications under the Act — concerned an entirely different parcel of property (the “Magnolia Holdings Business Park” on the north side of Highway 82,[4] not the property on the side south) and did not verify that the facility was consistent with the County’s SWMP in existence at the time the letters were issued, and that failure to comply with the notice and meeting requirements of OCGA § 12-8-26 mandated revocation of the permit.[5] Both the Developer and Satilla Riverwatch Alliance, Inc. (“Riverwatch”) intervened in the administrative proceeding and the Developer filed a motion to dismiss count five of the Board’s petition, which alleged that issuance of the permit was unlawful for failure to comply with OCGA § 12-8-26. The ALJ summarily disposed of several claims in the petition and held a hearing on the remaining claims, namely that the consistency letters were not timely and did not apply to the facility that EPD permitted and that issuance of the permit was unlawful for failure to comply with OCGA § 12-8-26. Following the hearing, the ALJ issued a final decision on February 27, 2023, reversing EPD’s decision. The ALJ concluded that the Board did not prove that EPD wrongfully issued the permit because the consistency letters were untimely, but it nonetheless found that the consistency letters were invalid because the facility approved by the Board in those letters was not the same facility proposed in the Developer’s application: “[T]he preponderance of the admitted evidence proved that the facility located on ‘the site formerly known as Magnolia Holdings Business Park’ was on the north side of Hwy. 82, not the south side, where [the Developer's] proposed facility is” and that “the phrase ‘former Magnolia Holdings Business Park’ [was] ambiguous.” In so finding, the ALJ concluded that the consistency letters did not constitute written verification of SWMP consistency and that issuance of the permit was improper because EPD may not issue a permit without a valid SWMP consistency letter. Finally, the ALJ granted the Developer’s motion to dismiss count five of the petition, concluding that based on the Supreme Court of Georgia’s decision in Emmons, supra, EPD does not have jurisdiction to enforce compliance with OCGA § 12-8-26: “Consistent with . . . Emmons, . . . the Act did not require [EPD] to investigate whether the process of selecting the site for [the Developer's] private landfill was actually begun by local government officials, nor was EPD required to fashion a remedy for violation of a public meeting requirement under OCGA § 12-8-26.” See Emmons, 270 Ga. at 198 (2) (“[t]he administrative jurisdiction of the EPD does not include determination of whether the city has comported with meeting and notice requirements, and does not provide for remedies for . . . violations of OCGA § 12–8–26″). Appeal to the Superior Court of Bibb County On March 6, 2023, the Developer sought superior court review in Bibb County of the ALJ’s decision reversing EPD’s decision,[6] alleging that neither the Act nor EPD rules require consistency letters to describe specifically the location of a proposed facility. The Superior Court of Bibb County granted the Developer’s petition and reversed the ALJ’s decision, finding that “the ALJ erred as a matter of law when imposing an investigatory duty on EPD in regards to the February 2015 Consistency Letter to consider extrinsic evidence not presented to EPD at the time of Permit issuance.” The superior court indicated that by issuing the consistency letter, the county verified that the facility as proposed by the Developer in its application, i.e., the parcel south of Highway 82, was consistent with its SWMP. Appeal to the Superior Court of Brantley County On March 29, 2023, the Board sought superior court review of the ALJ’s decision dismissing count five in Brantley County. The Developer moved to dismiss the petition pursuant to OCGA § 9-11-12 (b) (1), alleging, inter alia, that the Board did not have standing because it suffered no injury, i.e., the ALJ reversed EPD’s decision, which was the very relief the Board sought. The Superior Court of Brantley County denied the Developer’s motion to dismiss and the Board’s petition for judicial review, ruling that the ALJ correctly concluded that Emmons controlled, divesting the ALJ of subject matter jurisdiction over count five. Appeal to Superior Court of Ware County On March 29, 2023, Riverwatch sought superior court review of the ALJ’s decision dismissing count five in Ware County.[7] The Developer moved to dismiss that petition as well, alleging, inter alia, that Riverwatch did not have standing because it suffered no injury, i.e., the ALJ reversed EPD’s decision, which was the very relief sought. The Superior Court of Ware County denied the Developer’s motion to dismiss and denied Riverwatch’s petition for judicial review, ruling that the ALJ correctly concluded that Emmons controlled, divesting her of subject matter jurisdiction over count five.[8] Appeals to the Court of Appeals In Case No. A24A0612, the Board appeals the decision of the Superior Court of Bibb County reversing the ALJ and reinstating the permit. In Case No. A24A0638, the Board appeals the decision of the Superior Court of Brantley County affirming the ALJ’s dismissal of count five of its petition, and in Case No. A24A0639, the Developer cross-appeals, contending that the Board lacked standing to seek judicial review of the ALJ’s decision. In Case No. A24A0679, Riverwatch appeals the decision of the Superior Court of Ware County, affirming the ALJ’s dismissal of count five of the Board’s petition, and in Case No. A24A0680, the Developer cross-appeals, contending that Riverwatch lacked standing to seek judicial review of the ALJ’s decision. Case No. A24A0612 1. In related enumerations, the Board contends that the Superior Court of Bibb County (a) applied the wrong standard of review to the ALJ’s decision and (b) erred in reversing the ALJ’s decision for several reasons. We disagree. (a) The Board contends that the Superior Court of Bibb County applied the wrong standard of review to the ALJ’s decision. Relying primarily on Coastal Marshlands Protection Committee v. Altamaha Riverkeeper, 315 Ga. App. 510 (726 SE2d 539) (2012), the Board asserts that the law requires the ALJ to conduct a de novo review but that the superior court ignored this standard. In its order revoking the permit, the ALJ noted that it is “‘required to make an independent determination based upon evidence presented’ including any additional probative evidence admitted at the administrative hearing”; found that the location of proposed solid waste facilities are “a critically important part of a local SWMP”; and concluded that under the Act, EPD was required to coordinate its activities with “local governments, and, when necessary, conduct investigations and analyses to ensure compliance with the Act,” including verifying “that the ‘facility to be located on a site formerly known as Magnolia Holdings Business Park’ was the same facility proposed in [the Developer's] application,” which it did not do. The ALJ then held that the “preponderance of the probative evidence [admitted at the administrative hearing] proved that the phrase ‘former Magnolia Holdings Business Park’ referred to the tract of land on the north side of Hwy. 82″ and that “the facility located on ‘the site formerly known as Magnolia Holdings Business Park’ was on the north side of Hwy. 82, not the south side, where [the Developer's] proposed facility is”; thus the 2015 consistency letter issued by the Board did not apply to the south site specified in the Developer’s application to EPD. The superior court rejected the ALJ’s ruling, finding that it erred as a matter of law when imposing an investigatory duty on EPD in regards to the February 2015 Consistency Letter to consider extrinsic evidence not presented to EPD at the time of Permit issuance. . . . Neither the Act nor [EPD's] Solid Waste Rules require a solid waste management plan consistency letter to contain a description of the property for the location of the proposed facility. The Board contends that the ALJ applied the proper standard and that the superior court impermissibly overruled the ALJ’s findings of fact and improperly reversed the final decision “due to the ALJ’s consideration of extrinsic evidence.” We disagree. “Judicial review of an administrative decision requires the court to determine that the findings of fact are supported by ‘any evidence’ and to examine the soundness of the conclusions of law that are based upon the findings of fact.” Pruitt Corp. v. Ga. Dept. of Community Health, 284 Ga. 158, 160 (3) (664 SE2d 223) (2008), citing OCGA § 50-13-19 (h). But, OCGA § 50-13-19 (h) specifically provides that [t]he court shall not substitute its judgment for that of the agency as to the weight of the evidence on questions of fact [but] . . . [t]he court may reverse or modify the decision if substantial rights of the appellant have been prejudiced because the administrative findings . . . are: . . . (5) [c]learly erroneous in view of the reliable, probative, and substantial evidence on the whole record[.] OCGA § 50-13-19 (h). “[T]he statute prevents a de novo determination of the evidentiary questions leaving only a determination of whether the facts found by the [ALJ] are supported by ‘any evidence.’” Hall v. Ault, 240 Ga. 585, 586 (242 SE2d 101) (1978) (decided under former version of the statute). While the reviewing court accepts the findings of fact if there is any evidence to support them, it may reverse or modify the decision if substantial rights of the appellant have been prejudiced because the administrative . . . decision[ ] [is] (1) [i]n violation of constitutional or statutory provisions; (2) [i]n excess of the statutory authority of the agency; (3) [m]ade upon unlawful procedure; (4) [a]ffected by other error of law. OCGA § 50-13-19 (h). Thus, the court is statutorily required to examine the soundness of the conclusions of law drawn from the findings of fact supported by any evidence, and is authorized to reverse or modify the agency decision upon a determination that the agency’s application of the law to the facts is erroneous. A determination that the findings of fact are supported by evidence does not end judicial review of an administrative decision. (Footnote omitted.) Pruitt Corp., 284 Ga. at 161 (3). “On appeal from a superior court ruling in an administrative action, our duty is not to review whether the record supports the superior court’s decision but whether the record supports the final decision of the administrative agency.” (Citation and punctuation omitted.) Harris v. Butler, 368 Ga. App. 211 (889 SE2d 401) (2023). Further, “[t]his Court conducts a de novo review of claimed errors of law in the superior court’s appellate review of an ALJ’s decision. [T]he interpretation of a statute or regulation is a question of law and, thus, is also reviewed de novo on appeal.” (Citation and punctuation omitted.) Id. In Coastal, the Coastal Marshlands Protection Committee (the agency charged with permitting under the Coastal Marshlands Protection Act of 1970, see OCGA § 12-5-280 et seq.) appealed a superior court order vacating an ALJ’s decision to affirm the Committee’s decision to issue a permit for a moveable floating dock over a marshland. 315 Ga. App. at 510-511. The Committee alleged that the superior court erred by concluding that the ALJ committed a legal error by failing to consider whether the Committee abused its discretion in issuing the permit. Id. at 511. In rejecting the appellee Riverkeeper’s assertion that an ALJ should deny a permit if there was insufficient evidence before the Committee showing that a particular structure will not be contrary to the public interest, we explained that [u]nder the [APA], the ALJ was required to make an ‘independent determination’ based upon the evidence presented and was authorized to make any disposition available to the Committee when it reviewed the permit application. Requiring an ALJ to determine whether a permit applicant met its burden of proof before the Committee would vitiate the longstanding rule that an ALJ must make an independent determination of whether the permit would violate the provisions of the applicable statute or regulations. Id. at 513-514. We further explained that [t]he superior court’s involvement is an appellate proceeding and not a de novo trial. The standard of review for the superior court, as for us, is partly “any evidence,” and partly “abuse of discretion.” The ALJ’s findings of fact must have been based on some evidence. As with any bench trial, the findings of fact are overturned even when supported by strong evidence, when they were “found” while the judge was operating under an erroneous view of the law. That part of an appellate decision is always, really, de novo. An “abuse of discretion” standard applies when the superior court, or our court, reviews the ALJ’s finding that the project is in the public interest. Id. at 514-515. In that case, the relevant statute provided that an applicant seeking a permit to build a structure over any marshland in Georgia must “demonstrate to the Committee that the proposed alteration is not contrary to the public interest and that no feasible alternative sites exist.” (Citation and punctuation omitted.) Id. at 511-512. Because the superior court focused on whether the Committee’s decision was right or wrong when it should have focused on whether the ALJ’s decision was right or wrong, we reversed. Id. at 514-515. In this case, the Board alleges that the superior court disregarded the ALJ’s duty to make an independent determination when it ruled that “EPD correctly determined the February 2015 Consistency Letter to be sufficient to complete [the Developer's] Permit Application based on the information presented to EPD at the time the Permit [was issued].” But, the Board mischaracterizes the superior court’s decision and the applicability of Coastal to this case. While Coastal makes clear that a superior court, as a reviewing court, may not reverse an ALJ’s findings of fact if they are supported by “any evidence,” it does not alter the rule that the superior court “is statutorily required to examine the soundness of the conclusions of law drawn from the findings of fact supported by any evidence.” (Emphasis supplied.) Pruitt Corp., 284 Ga. at 161 (3). Here, the superior court did not ignore or impermissibly overrule the ALJ’s factual findings; the superior court reversed the ALJ because it erred as a matter of law in imposing upon EPD an investigatory duty to investigate and confirm consistency pursuant to OCGA § 12-8-24 (g). (b) In a related enumeration, the Board contends that the superior court erred in reversing the ALJ “where such reversal was based entirely on the ALJ’s undisturbed factual findings.” The Board alleges that EPD’s duty to follow its own rules to investigate or verify whether the consistency letters related to the proposed landfill is irrelevant to the ALJ’s ultimate factual conclusion that the consistency letters did not relate to the landfill proposed by the Developer in its permit application. The ALJ’s ultimate conclusion and reversal of the permit is premised entirely on the ALJ’s finding of fact that the “Permit was wrongfully issued because [the Developer] failed to submit a valid consistency letter for the proposed facility.” In other words, according to the Board, the superior court’s analysis should have ended at its adoption of the ALJ’s factual findings as, under the Act and Rules, a solid waste handling permit cannot be issued without a consistency letter for the specific facility proposed in the relevant application. But, this argument puts the cart before the horse; as implied in Division 1 (a), supra, whether the superior court was required to accept the ALJ’s factual findings regarding the content of the consistency letters is beside the point if EPD did not have an affirmative duty under the Act and its Rules to investigate the content of those letters. As EPD notes in its appellate brief, “[t]he superior court’s reversal of the ALJ remains valid regardless of the extrinsic evidence issue, however, because the superior court’s reversal hinges on the determination that [EPD] does not have an affirmative duty to investigate the consistency letters and consider extrinsic evidence.” (c) The Board contends that the superior court erred in reversing the ALJ’s decision because the ALJ properly concluded that EPD is required to verify the congruency of a consistency letter and an application before issuing a permit. Relying primarily on OCGA § 12-8-23.1 (a) (7), the Board contends that EPD is required to consult and coordinate with local governments to verify the congruency of consistency letters and permit applications, and that in this case, a simple phone call or e-mail to the Board would have verified whether the locations designated in the consistency letter and the permit application matched. EPD and the Developer disagree with the Board, contending that the superior court’s decision should be affirmed because neither the Act nor EPD regulations require a consistency letter to include a location or obligate EPD to investigate location descriptors in consistency letters issued by local governments; in their view, local governments are in the best position to determine consistency with their SWMPs and the ALJ’s ruling encroaches on that authority by requiring EPD to tell a local government what it meant when it drafted its own letters. In its final decision, the ALJ concluded that OCGA §§ § 12-8-21 (d) and 12-8-23.1 (4) require EPD “to ‘at all times coordinate [its] activities with’ local governments, and, when necessary, conduct investigations and analyses to ensure compliance with the Act,” and that EPD is required to ensure that a permit is consistent with a local government’s SWMP before issuing a permit under OCGA § 12-8-31.1 (e). Based on these conclusions, the ALJ found that EPD “was obligated to verify that the ‘facility to be located on a site formerly known as Magnolia Holdings Business Park’ was the same as the facility proposed in [the Developer's] application,” implicitly ruling that consistency letters issued by a local government pursuant to OCGA § 12-8-31.1 (e) must include a description of the location of the proposed site. In order to properly address the Board’s argument that the ALJ’s conclusions were correct, we must first look at the relevant statutes and regulations. OCGA § 12-8-21 (d) provides: It is further the intent of the General Assembly that the director of the Environmental Protection Division of the Department of Natural Resources shall be the official charged with primary responsibility for the solid waste management program. The director, in exercising any authority granted in this part, shall conform to and implement the policies outlined in this part and shall at all times coordinate his activities with those of other state agencies and local political jurisdictions so as to achieve a unified and effective solid waste management program in the state. OCGA § 12-8-23.1 (a) (4) provides: “The director shall have and may exercise the following powers and duties: . . . To make investigations, analyses, and inspections to determine and ensure compliance with this part, the rules and regulations promulgated under this part, and any permits or orders which the director may issue.” Subsection (a) (7) of this same Code section provides: “The director shall have and may exercise the following powers and duties: . . . To advise, consult, cooperate, and contract on solid waste management matters with other agencies of this state, political subdivisions of this state, and other designated organizations, authorities, or entities[.]“ And, OCGA § 12-8-24 (g) provides: Prior to the issuance of any permit for a solid waste handling facility or the granting of any major modification of an existing solid waste handling permit, the director shall require written verification to be furnished by the applicant that the proposed facility complies with local zoning or land use ordinances, if any; and after July 1, 1992, that the proposed facility is consistent with the local, multijurisdictional, or regional solid waste management plan developed in accordance with standards promulgated pursuant to this part subject to the provisions of Code Section 12831.1. . . . Code section 12-8-31.1 in turn sets forth the requirements for cities and counties to develop SWMPs, specifying the minimum factors to be included in SWMPs and providing that [a]fter July 1, 1992, no permit, grant, or loan shall be issued for any municipal solid waste disposal facility or any solid waste handling equipment or recycling equipment used in conjunction therewith in a county or region which is not consistent with a local, multijurisdictional, or regional solid waste management plan. Each application for a permit, grant, or loan issued after July 1, 1992, shall include the following: (1) Certification that the facility for which a permit is sought complies with local land use and zoning requirements, if any; (2) Verification that the facility for which a permit is sought meets the tenyear capacity needs identified in the local, multijurisdictional, or regional solid waste management plan; and (3) Demonstration that the host jurisdiction and all jurisdictions generating solid waste destined for the applicant’s facility are part of an approved solid waste management plan or updated plan developed consistent with standards promulgated pursuant to this part, and are actively involved in, and have a strategy for, meeting the statewide goal for reduction of solid waste disposal. OCGA § 12-8-31.1 (e). EPD’s own rules are also relevant to our analysis. Rule 391-3-4-.02 of the Georgia Administrative Code provides: “The Director [of EPD] may issue permits for solid waste handling provided the application is judged complete and meets the requirements of the Georgia Comprehensive Solid Waste Management Act and these Rules.” Ga. Comp. R. & Reg. 39134.02 (1) (b). And, subsection (9) of that same Rule provides: Except for Private Industry Solid Waste Disposal Facilities, each applicant for a permit shall provide verification that the facility is consistent with the local or regional solid waste management plans. The verification shall consist of letters from the host jurisdiction and generating jurisdictions verifying consistency with the approved local solid waste plans. When this Court construes statutes, agency rules, and regulations, we employ the basic rules of statutory construction and look to the plain language of the provision in question to determine its meaning. In doing so, we must construe the statute, rule, or regulation according to its [own] terms, to give words their plain and ordinary meaning, and to avoid a construction that makes some language mere surplusage. Still, even if words are apparently plain in meaning, they must not be read in isolation and instead, must be read in the context of the statute, rule, or regulation as a whole. (Citations and punctuation omitted.) Dept. of Community Health v. Houston Hosps., 365 Ga. App. 751, 760 (V) (880 SE2d 245) (2022). Moreover, we only defer to an agency’s interpretation when we are unable to determine the meaning of the legal text at issue. As a result, when a statute is not ambiguous after we apply canons of statutory construction, our case law does not support any deference to the Department’s interpretation of the relevant . . . statutes, or to its interpretation of its own unambiguous regulations. (Citations and punctuation omitted.) Id. at 761 (V). See also Kennestone Hosp. v. Emory Univ., 318 Ga. 169, 183 (3) (897 SE2d 772) (2024) (“our longheld rule is that courts may defer to an agency’s construction of its own rule only if its meaning is ambiguous, and once the traditional tools of construction are applied, few statutes or regulations are truly ambiguous”) (citations and punctuation omitted). “Simply put, when the language of a statute is plain and susceptible of only one natural and reasonable construction, courts must construe the statute accordingly.” (Citation and punctuation omitted.) Houston Hosps., 365 Ga. App. at 771 (V) (2). Bearing these principles in mind, we now consider whether the ALJ correctly ruled that EPD wrongfully issued the permit to the Developer because it failed to submit a valid consistency letter. While the General Assembly intended to charge the director of EPD with primary responsibility for SWMPs in Georgia, OCGA § 12-8-21 (d) does not require the director of EPD to investigate and ensure compliance with the Act. See OCGA § 12-8-23.1 (a) (4). See also Nimmer v. Strickland, 242 Ga. 430, 431 (1) (249 SE2d 233) (1978) (language in statute providing that tax commissioner “shall have authority” to proceed against purchaser is permissive and not mandatory); Mayor and Council of Montezuma v. Brown Bros., 168 Ga. 1, 9 (147 SE 80) (1929) (“shall have and may exercise” means “if they choose”). Cf. Southeast Ga. Health System v. Berry, 362 Ga. App. 422, 423–424 (868 SE2d 820) (2022) (statute providing that Department of Community Health “shall have the authority to make public or private investigations” to determine whether provisions of CON program have been violated is discretionary language and imposes no duty to conduct a specific investigation). OCGA § 12-8-23.1 (a) (4) states that “[t]he director shall have and may exercise” the power to make investigations, but it does not impose a statutory duty on the director to investigate the intent or meaning of a consistency letter. Moreover, while OCGA § 12-8-21 (d) places upon EPD primary responsibility for a unified and effective solid waste management program in Georgia, nothing in the statute requires EPD to go behind the consistency letters and investigate the soundness of a county’s consistency determination on individual permit applications and/or whether that determination comports with the county’s own SWMP. Finally, while EPD’s rule governing consistency letters requires a permit applicant to “provide verification that the facility is consistent with the local or regional [SWMP],” (emphasis supplied) Ga. Comp. R. & Reg. 39134.02 (9), nothing in the Code sections or rules cited by the ALJ or the Board require EPD to investigate and validate the congruency of consistency letters or require consistency letters to pinpoint, describe, or specify the precise geographical location or site of that proposed facility, and we “cannot add language to a statute by judicial decree.” (Citation and punctuation omitted.) Moosa Co. v. Commr. of Ga. Dept. of Revenue, 353 Ga. App. 429, 432 (838 SE2d 108) (2020). See also EEOC v. Abercrombie & Fitch Stores, 575 U. S. 768, 774 (II) (135 SCt 2028, 192 LE2d 35) (2015) (“[w]e construe [a statute's] silence as exactly that: silence”); Hynes v. State, 341 Ga. App. 500, 511–512 (801 SE2d 306) (2017) (“To hold that the statute, in its silence, applies to tests administered at the direction of a judicial officer would require us to add words not found in the statute. This, we will not do.”). With regard to the siting of a facility, EPD’s Rule 391-3-4-.01 (77) defines “Site” as “the entire property a permitted solid waste handling facility is located within and includes all activities within that property,” and the Rules require that an “[a]pplication for a permit or for the transfer of a permit shall contain, but shall not be limited, to the following: . . . (e) For a permit application, a site assessment as required by Rule 39134.05[.]” See Ga. Comp. R. & Reg. 39134.02 (7). Rule 39134.05 (4) in turn provides: “ The site assessment report shall be prepared in accordance with Circular 14, 1991, (amended 1997) as published by the Georgia Geologic Survey, Georgia Environmental Protection Division.”[9] Circular 14 contains “criteria for performing site acceptability studies for solid waste landfills in Geor
