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BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
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IN THE MATTER OF:
PROPOSED EXTENSION OF ADJUSTED STANDARD
APPLICABLE TO ILLINOIS-AMERICAN
WATER COMPANY'S ALTON PUBLIC WATER
SUPPLY FACILITY DISCHARGE
TO THE MISSISSIPPI RIVER
UNDER 35 ILL. ADM. CODE 304.124 AND 304.106
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AS 2007-2
(Adjusted Standard)
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TESTIMONY OF ALLEY RINGHAUSEN
WITNESS IDENTIFICATION AND BACKGROUND
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Please state your name and business address:
My name is Alley Ringhausen. I work at Great Rivers Land Preservation Association,
Inc., also known as Great Rivers Land Trust, located at 2102 McAdams Parkway in
Alton, Illinois, 62002.
What are your job title and your job responsibilities?
Since 2000, I have been employed by Great Rivers Land Trust as its Executive Director.
My primary
job responsibilities are administering and implementing conservation
projects in the confluence region. My main focus is making sure the Piasa Creek
Watershed Project is administered and implemented successfully. My initial goal was to
help Illinois-American Water Company'swater treatment facility in Alton meet the 2 to 1
offset goal required by the adjusted standard that was granted to the facility in 2000, but
we surpassed this goal much earlier than expected. Now, my focus is maximizing the
soil savings and other benefits that can be achieved with Illinois-American Water's
annual contribution
What is your educational background?
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I earned a master's degree in Environmental Studies from Southern Illinois University
(Edwardsville), specializing in Watershed Management.
What is your business background?
I am an environmental planner. Before taking my current position with Great Rivers
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Land Trust, I worked as a consultant with the Illinois Association of Resource
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Conservation and Development Areas and the American Farmland Trust, as well as
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various Soil and Water Conservation Districts, school districts, and various non-profit
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organizations. My duties as a consultant for these organizations generally involved
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planning and implementing soil conservation projects.
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PURPOSE OF TESTIMONY
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What is the purpose of your testimony in this proceeding:
The purpose of my testimony is to: (1) verify portions of Illinois-American Water's
answers to the Illinois Pollution Control Board'squestions in the Hearing Officer Order
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dated August 6, 2007, in particular, those answers to which I contributed; (2) summarize
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the achievements of the Piasa Creek Watershed Project; (3) describe some ofthe
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accolades that Great Rivers Land Trust has received as a result of the Project; (4) explain
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the maintenance activities that can be implemented to maintain a 2 to I offset ratio and a
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minimum soil savings of 6,600 tons; and (5) address several technical points raised by the
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Board, including uncertainty discounts and retirement.
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VERIFYING CERTAIN ANSWERS OF ILLINOIS-AMERICAN WATER TO
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QUESTIONS POSED BY THE BOARD IN THE HEARING OFFICER ORDER
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ENTERED AUGUST 6, 2007
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Did you participate in the preparation of Illinois-American Water's answers to the
questions presented in
the Hearing Officer Order entered in this proceeding on
August 6, 2007?
Yes.
What was your role in the preparation of the Company's answers?
I read the questions in the Hearing Officer Order and participated in several meetings
with Illinois-American Water's counsel to discuss those questions and answers. I helped
formulate Illinois-American Water'sanswers to questions l a, lb, l d, If, 2b, 2c, 2d, 3a,
3b, 3c, and 3d, posed to the Illinois-American Water, as well as Illinois-American
Water's answer to questions 5a and 5b, posed to the Illinois Environmental Protection
Agency
I will ask you now to verify, Mr. Ringhausen, that the answers attributed to you for
questions
Ia, Ib, Id, If, 2b, 2c, 2d, 3a, 3b, 3c, and 3d, posed to Illinois-American
Water, and to questions 5a and 5b, posed to Illinois EPA, are true and correct to
the best
of your knowledge, information and belief.
Yes they are.
Did you provide any other input to Illinois-American Water for its answers to the
Board's questions?
Yes. I also supplied an Affidavit which is attached to Illinois-American Water'sPetition
for Extension. Also, I prepared a ten-year proposal for maintenance, which is attached to
Illinois-American Water'sresponses to the Board'squestions.
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I know that your Affidavit was signed under oath, but let me ask you now if the
information contained in
that affidavit is true and correct to the best of your
knowledge, information and belief.
Yes, it is.
Also, can you verify that the proposal for maintenance attached to Illinois-American
Water's responses is identical to the proposal you prepared and gave to Illinois-
American
Water?
Yes, it is.
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THE PIASA CREEK WATERSHED PROJECT HAS ACHIEVED A DRASTIC
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REDUCTION IN SEDIMENT LOADING TO THE PIASA CREEK AND OTHER
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BENEFITS AS WELL
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What are some of the Piasa Creek Watershed Project'smost significant
achievements?
The Project's most significant achievement is amount of sediment that it has kept out of
Piasa Creek and, in tum, the Mississippi River. This soil savings has surpassed all
expectations. Everyone hoped that the Project would be able to save 6,600 tons
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sediment by the end ofthe 10-year period (so, by 2010), but it had already surpassed this
goal by the six-year mark. As
ofOctober 12, 2006, the Project had achieved a savings of
approximately 6,691 tons. I'm working now on calculating the additional savings
achieved since that time, and hope to have an updated total by the
Board'shearing on
August 28. GRLT will continue to implement
new projects over the next few years, and
my conservative estimate is that the Project will reach 10,000 tons
of savings by the end
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ofthe 10-year period. With the progress ofthe Project so far, though, I hope to reach a
savings
of 12,000 to 15,000 tons.
Aside from the soil savings, what are some of the Project's other significant
achievements?
The amount of awareness that the Project has brought to local farmers and other
landowners has made a huge impact on the water quality
in
the Piasa Creek Watershed.
Before this Project was implemented, GRL T
was doing some sediment reduction projects
in
the area, but we really had to work to get people interested and make them understand
what could be accomplished. Now, given this Project'sincredible success, farmers
actually
come to us and ask us to help them implement sediment reduction projects on
their land. They receive program funds to cover a portion
ofthe cost for this and GRL T
provides them additional financing, but
they have to pay for a portion of these projects
out
of pocket, and they'rehappy to do
it.
The success ofthis Project has gotten people
who
may not have even been aware that sediment reduction projects were out there to
invest their money and time in improving the environment.
Are there any other benefits?
Ofcourse. The sediment reduction projects have other environmental benefits, such as
creating habitat for wildlife, protecting sensitive ecosystems, and reducing flash flooding.
But the Project also adds a lot to the local communities in other ways.
For instance,
GRLT has worked with local schools and colleges on various educational programs. In
addition, the money GRL T spends on each project goes back into the local communities.
The Project has created employment opportunities for companies and individuals, and has
created contractual opportunities for engineering firms and heavy equipment suppliers.
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The Project has also resulted in the purchase of local supplies and materials like rip-rap,
tile, concrete, trees, and seed.
Let'sexamine the other side of the issue, Mr. Ringhausen. What detriment, if any,
would follow if Illinois-American
Water's contributions to the Project terminate
later this year?
We have several projects in the development stages. Our projects involve planning,
engineering studies, negotiations with landowners, and construction. Currently, we have
a waiting list
of landowners. They anticipate having an opportunity to participate in
projects over the next three years. Some projects are in various stages
of completion. All
projects under development would stop, and construction would stop. In addition, we
would have a lot
of disappointed landowners. Enthusiasm for the Project is very high,
but that would be lost. The money we receive from Illinois-American Water also serves
as seed money to attract funding from other sources, like grants from private foundations.
I am not predicting that those other funds will dry up, but they will certainly be more
difficult to obtain without this seed money. In fact, we are negotiating for additional
grants right now; the loss
of Illinois-American Water's funds will severely hurt our
chances for these grants.
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GREAT RIVERS HAS RECEIVED NUMEROUS ACCOLADES RECOGNIZING THE
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ACHIEVEMENTS OF THE PIASA CREEK WATERSHED PROJECT
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Mr. Ringhausen, what kind of awards has Great Rivers Land Trust received
recognizing
the Piasa Creek Watershed Project's achievements?
Great Rivers Land Trust has received numerous national, state, and local awards
recognizing the Project's success. These awards are described in my Affidavit, which is
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attached to Illinois-American Water'sPetition for Extension, so I won't describe them all
here. As an example, though, Great Rivers received the Illinois Governor's Pollution
Prevention Award in the "Community Group" category. This award is given to only one
organization to recognize its accomplishments in helping the environment and the
economy of Illinois by successfully reducing waste.
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was an honor to receive this
award, because it brought the Piasa Creek Watershed Project into the spotlight and
showed the state what type of benefits can be achieved through sediment reduction
practices.
I'm very proud of it.
Aside from awards, what other recognition has the Piasa Creek Watershed Project
received?
The Piasa Creek Watershed Project has been featured in national forums and mentioned
in numerous presentations and publications as an example of a successful watershed
based trading project. One example
ofthis is the National Forum on Synergies Between
Water Quality Trading and Wetland Mitigation Banking, which was co-sponsored by the
U.S. Environmental Protection Agency and the Environmental Law Institute. This
national forum was designed to bring together experts in wetland mitigation banking with
those in the water quality trading community to facilitate a dialogue on stimulating future
markets in water quality trading.
What results do you think the Piasa Creek Watershed Project has seen as a result of
this recognition?
Once other individuals, organizations, local governments, and businesses learned about
the Piasa Creek Watershed Project, they became interested in partnering with or
providing financial assistance to Great Rivers Land Trust to help it achieve its goals.
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These partners and funders include private landowners; educational institutions such as
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Principia College, Southern Illinois University (Edwardsville), Lewis
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Community College, the University of Illinois, and the Alton School District; the City of
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Alton and the Village of Godfrey; the Jersey County Board; Soil & Water Conservation
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Districts in Jersey, Madison, and Macoupin Counties; Tri-County Farm Supply; the
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Resource, Conservation and Development; Pride, Inc.; The Nature Institute; the James
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and Aune Nelson Foundation; the Olin Foundation; the Monsanto Fund; Trees Forever;
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the Illinois Clean Energy Community Foundation; the Illinois Environmental Protection
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Agency; the Illinois Department ofNatural Resources; the Illinois Board of Education;
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the U.S. Department of Agriculture; U.S. Fish
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Wildlife; the National Park Service; and
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the Boy Scouts ofAmerica.
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MAINTENANCE ACTIVITIES CAN MAINTAIN A 2 TO 1 OFFSET RATIO AND AT
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LEAST 6,600 TONS OF SOIL SAVINGS
Please explain how you plan to use maintenance activities to maintain Illinois-
American
Water's 2 to 1 offset ratio and achieve a minimum soil savings of 6,600
tons.
I plan to use Illinois-American Water'sremaining contributions under the current
contract to both fund new projects and maintain existing projects.
Ifthe Board grants the
requested extension to the adjusted standard, Illinois-American Water is committed to
maintaining a 2 to 1 offset and a minimum soil savings
of 6,600 tons. I estimate that it
will cost approximately $136,800 each year for 10 years to maintain the soil savings
of
existing projects above that level. I shared this number with Illinois-American Water,
and believe that the company understands what we will be able to accomplish with this
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amount. GRLT and Illinois-American Water have not started negotiating the specific
terms
of a maintenance contract yet, but I expect this contract to require Illinois-
American Water to pay GRLT whatever amount is necessary to maintain the soil savings
at a 2 to 1 offset and above 6,600. This will likely be the amount I estimated, but it could
be more or less depending on the River conditions, the performance
of the individual
sediment reduction projects, and the types
of new projects implemented from now
through 2010.
What types of activities will Illinois-American Water's annual maintenance
contribution allow you complete to maintain the soil savings?
Mostly stewardship activities on lands owned or leased by GRLT or under cooperative
agreement with GRLT. The specific maintenance activities that are required will depend
on the specific type
of sediment reduction project in place, but could include tree
plantings, mowing, maintenance
of tile and drain structures, and use of groundcover.
GRLT will also conduct site visits to work with landowners and inspect existing projects
to make sure they are still in place and effectively trapping sediments.
Will you spend any portion of Illinois-American Water's annual maintenance
contribution on anything else?
Yes. Some ofthat amount will be allocated toward legal fees and court costs, just in case
we get into a dispute with a landowner and have to defend an easement or take some sort
ofenforcement action to make the landowner implement and maintain sediment
reduction projects as required by a cooperative agreement with that landowner. Also,
$25,000 per year
of Illinois-American Water's contribution will be set aside in an
endowment fund, which I expect will grow large enough over ten years to allow me to
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continue maintaining the existing sediment reduction projects so that the 2 to 1 offset and
a minimum
of 6,600 tons of soil are saved into the future.
How did you come up with these cost estimates and expenditure categories?
They are based on information developed by the National Land Trust Alliance, one ofthe
leading organizations in land preservation and maintenance.
What if the endowment fund isn't large enough?
Illinois-American Water will have to contribute more. I understand that the Company is
committed to financially supporting the Piasa Creek Watershed Project to ensure that the
2 to 1 offset and a minimum
of 6,600 tons of soil are saved, for as long as the adjusted
standard is in place.
If the Board extends the adjusted standard indefinitely, I understand
that Illinois-American Water will ensure that the offset and minimum savings are
maintained indefinitely. But
it's impossible to estimate now how much this will cost.
Periodic review or reexamination will be necessary to ensure effectiveness.
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APPLYING AN UNCERTAINTY DISCOUNT OR RETIRING CREDITS IS NOT
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NECESSARY TO COMPLY WITH USEPA POLICY
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Let's turn now to some of the principles identified in USEPA policies that are
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discussed in the Board's questions. Are you familiar with the concept of an "uncertainty
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discount"?
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I understand the concept. USEPA recommends using an uncertainty discount to make
sure the tons saved by a project are not overestimated.
If soil savings are overestimated,
the environmental benefit
of a water quality trading project or offset might not be equal
to or greater than what could be achieved by conventional treatment.
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Do you use an "uncertainty discount" in calculating the tons of soil savings achieved
by the Project?
No, not a fixed uncertainty discount ratio like those described in USEPA'spolicies. But
it'sextremely important to me that the soil savings from this and other water quality
trading projects and offsets are accurately reported. By using reliable numbers, we
increase the confidence that governments and local communities have in these types of
projects. Also, we guarantee that these projects are helping, rather than hurting, the
environment. I have always made it a point to use very conservative estimates in
reporting soil savings from the Piasa Creek Watershed Project, and I am confident that,
based on the latest calculation methods, every ton that I report as saved is actually
prevented from entering Piasa Creek.
How do you make sure your numbers are reliable and conservative?
We calculate soil savings using only methods that are well-established and widely-
accepted by the U.S. Department of Agriculture. Also, we know there are additional soil
savings that are achieved by the Piasa Creek Watershed Project that are not included in
the reported totals for soil savings. For instance, we
don'tcount any soil savings from
"sheet and rill" erosion, because farmers address this type of erosion through USDA-
sponsored programs. No sediment reduction project can stop all soil from eroding,
though, so the Piasa Creek Watershed Project traps some
ofthe soil that those projects
can't. In other words, the Piasa Creek Watershed Project acts as a second line of defense.
But we don'tcount these additional soil savings at all, because it is difficult to quantify
exactly how many tons are saved by the USDA-sponsored programs and how many tons
of sheet and rill erosion are saved by the Project, and I didn'twant to take credit for any
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