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BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

IN THE MATTER OF:

WATER QUALITY STANDARDS AND

EFFLUENT LIMITATIONS FOR THE

CHICAGO AREA WATERWAY SYSTEM

AND THE LOWER DES PLAINES

RIVER: PROPOSED AMENDMENTS TO

35 Ill. Adm. Code

Parts

301, 302,

303 and

304

R08-9

(Rulemaking

Water)

METROPOLITAN WATER RECLAMATION DISTRICT OF GREATER

CHICAGO'S PRE-FILED QUESTIONS TO GERALD ADELMANN

Page 1, Paragraph 2, Sentence 2: You state that communities have spent billions of

dollars on projects. Can you provide a list of these projects, associated costs, community

financing the project, and an approximate time frame when the projects were completed?

Page 1, third paragraph, last sentence: You state that adopting more stringent water

quality standards will shape smart growth throughout the greater Chicagoland area for

years to come.

What do you mean by smart growth?

How do you envision water quality standards in the CAWS as being a driver for

growth in the greater Chicagoland area?

If implementation of the proposed effluent bacterial standards does not lead to

significant improvement in water quality in the

CAWS

especially during, and for

lingering periods following

wet weather and does not significantly reduce health

risks, how will that affect smart growth?

Page 2, first paragraph: You state that the regional vision calls for safe and adequate

paddling access to 10 rivers in northeastern Illinois and identifies 480 miles of water

trails and 174 access points for paddling.

Please identify the 10 rivers.

Which of these rivers are included in this rulemaking and which are not?

Do you know how many of the 480 miles of water trails and 174 access points for

paddling that the plan identifies are located on the CAWS, on the LDPR, and on

other of the 10 rivers in northeastern Illinois?

Page 2, second paragraph: You state that Openlands is committed to help water trail

providers make paddling safe for everyone and that you have advocated since 2000 for

THIS

FILING

IS BEING SUBMITTED

ON RECYCLED PAPER

Electronic Filing - Received, Clerk's Office, August 25, 2008

adequate limits for bacterial contamination to support all current and anticipated human

usage of the Chicago River System.

Can

you define the term water trail provider?

In describing your efforts to help ensure safety, you do not indicate

that you

advise paddlers of the risks and danger of recreating alongside commercial barges

and tour boats

and other motorized watercraft

traffic.

Does your concern for

paddler safety extend to reducing the potential risk of drowning resulting from

capsizing or collision with these watercraft?

Please define the Chicago River System and how it compares to the system of

waterways defined as

the CAWS.

Please list what you consider to be all current and anticipated human usage of the

Chicago River System.

Would

you agree

that what

you are

actually

advocating

for is for adequately low

levels of microbial pathogens

in CAWS waterways

to support all current and

anticipated human usage?

How should these adequately low levels of microbial pathogens be determined?

Will you be satisfied if these levels are unattainable during wet weather?

Page 2, third paragraph

You state that improving water quality and aquatic habitat along

the CAWS and LDPR will benefit ecology, tourism and recreation throughout the area.

You also state that the waterways are hydrologically connected to higher quality streams

that you have worked for decades to preserve and restore.

Have you assessed the feasibility and cost of effecting habitat improvements to

the CAWS and LDPR that will provide significant ecological benefits?

What is the basis for your statement that tourism and recreation will benefit from

improved water quality? To what extent do you expect them to improve as a

result of the proposed rulemaking?

Can you list the specific high quality streams that are hydrologically connected to

the CAWS and LDPR that you have been working for decades to preserve and

restore

Can you describe their hydrological connection to the CAWS and LDPR

making note of direction of flow, and presence of dams, locks, and electric field

barriers?

What impact have you determined

the CAWS

and the LDPR currently have on

each of the streams you just identified

How do you expect this influence to

change if

IEPA'

s proposed rulemaking is adopted?

THIS FILING

IS BEING SUBMITTED

ON RECYCLED PAPER

Electronic Filing - Received, Clerk's Office, August 25, 2008

Is the Illinois and Michigan Canal hydrologically connected to the CAWS or

LDPR? Do you consider it be of higher quality than the CAWS and LDPR? If

so, on what basis?

On page 3, first paragraph of your testimony, you indicate that by "looking forward to

what the waterways are now capable of attaining, we can improve opportunities for

people to experience the natural beauty, diversity and tranquility of the region."

Do you disagree with the conclusion

in the UAA

that the recreational uses of the

waterways do not include primary contact recreation?

Do you agree with the conclusion in the

UAA that the

waterways will not be safe

for incidental contact recreation during and following wet-weather discharges?

Page 3, Conclusions

You state that people are now responding in unprecedented

numbers to the improvements in water quality

in the CAWS

and that improved aquatic

life use designations are fundamental in creating habitat conditions for greater

biodiversity.

Please clarify what you mean by unprecedented numbers. Do you mean growing

numbers of people?

How do you know that growing numbers of people are using the CAWS?

If in fact the number of CAWS users is growing, how do you know that this is in

response to the water quality improvements?

Which specific water quality

improvements are you alluding to?

Is this statement your personal opinion or do you have any survey data showing

the number of people that are currently

using

the CAWS for recreational

activities?

Please explain how the proposed aquatic life use designations are an improvement

over the current aquatic life use designations for the CAWS.

Please explain how you envision that the proposed aquatic life use designations

will create habitat conditions that will result in greater biodiversity.

Are you

envisioning that physical habitat will improve as a result of this rulemaking?

What safety protocols does your organization employ when inviting the public to use the

CAWS? Do you avoid certain areas due to barge and motorized boat traffic, absence of

safe entry and exit locations, and/or other issues incompatible with recreational uses? Do

you avoid certain times, such as during and following wet weather events?

Even if the wastewater treatment plant effluent was disinfected, would you recommend

that people, particularly children, should avoid exposure to the CAWS due to pathogen

contributions from stormwater runoff and combined sewer overflows?

THIS FILING IS BEING SUBMITTED ON RECYCLED PAPER

Electronic Filing - Received, Clerk's Office, August 25, 2008

10.

In your survey of members and others, did you ask about the cost people would be

willing to assume to disinfect effluent from the treatment plants?

Dated: August 25, 2008

Respectfully submitted,

METROPOLITAN WATER RECLAMATION

Ballard

BARNES & THORNBURG LLP

Suite 4400

One North Wacker Drive

Chicago,

Illinois 60606

(312) 357-1313

482125v1

THIS FILING IS BEING SUBMITTED ON RECYCLED PAPER

Electronic Filing - Received, Clerk's Office, August 25, 2008