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
III.
Adm. Code Parts 301, 302, 303 and 304
)
)
)
)
)
)
)
)
R08-9
(Rulemaking - Water)
NOTICE OF FILING
TO:
See Attached Service List
PLEASE TAKE NOTICE that on the 26th day
of June, 2008, I filed with the Office of
the Clerk
~f
the Illinois Pollution Control Board the attached Response in Opposition to Motion
to Stay by the People
of the State of Illinois, a copy of which is hereby served upon you.
Respectfully submitted,
LISA MADIGAN,
Attorney General
of the
State of Illinois
By:
Susan
/LL~
Hedman
Environmental Counsel
(312) 814-4947
Andrew Armstrong
Assistant Attorney General
(312) 814-0660
Environmental Division
69 West Washington Street, Suite 1800
Chicago, Illinois 60602
(312) 814-4947
Electronic Filing - Received, Clerk's Office, June 26, 2008
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 III.
Adm. Code Parts 301, 302, 303 and 304
)
)
)
)
)
)
)
)
R08-9
(Rulemaking - Water)
RESPONSE IN OPPOSITION TO MOTION TO STAY
BY THE PEOPLE OF THE STATE OF ILLINOIS
The People
of the State of Illinois ("the People"), by and through Illinois Attorney
General Lisa Madigan, oppose the motion to stay this proceeding ("Motion") that was filed by
the Metropolitan Water Reclamation District
of Greater Chicago ("the District") on June 12,
2008. Staying this rulemaking would be injurious to the public interest, harmful to the
environment, and would result in an extraordinary waste
of the resources of the Illinois Pollution
Control Board ("the Board"), the Illinois Environmental Protection Agency ("IEPA"), and the
many other public and private stakeholders that have spent years preparing for and participating
in this proceeding. The People therefore request that the District's motion be denied.
I.
APPLICABLE LAW
"Motions to stay a proceeding must be directed to the Board and must be accompanied by
sufficient information detailing why a stay
is needed." 35 Ill. Adm. Code 101.514.
When considering such motions, the Board carefully weighs the extent to which a stay would
burden the Board or otherwise result in the waste
of time and resources. Vernon and Elaine
Zohfeld
v. Bob Drake,
et aI.,
PCB 05-193 (February 2, 2006) (denying motion to stay to avoid
Electronic Filing - Received, Clerk's Office, June 26, 2008
burdening the Board's ability to manage its cases; convenience to the Board weighs against
granting a stay). The Board denies motions to stay when "the Board believes the effect of a stay
in its entirety would harm the environment" or "be injurious to public interest." People of the
State
of Illinois v. ESG Watts, PCB 96-107 (March 19, 1998),
citing
IEPA v. Pielet Brothers
Trading, Inc. PCB 80-185 (February 4,1982) and IEPA v. Incinerator, Inc., PCB 71-69 (October
14,1971).
II.
THERE IS NO FACTUAL BASIS FORA STAY.
The District's motion to stay this proceeding is premised on:
(1) a one-sided
(mis)characterization
of the record offered by counsel for the District; (2) alleged deficiencies in
the record
I
that counsel for the District claims to have identified; and (3) unsupported and self-
serving assertions regarding the nature and the expected findings
of certain studies that the
District might perform during the pendency
of a stay. This is not a factual basis for a stay.
There are no expert affidavits. Not even a verified filing. Counsel's unsupported and unverified
assertions do not provide the Board with "sufficient information" on which to base a decision to
stay this rulemaking.
35 Ill. Adm. Code 101.514. For this reason alone, the District's motion
should be denied.
III.
STAYING THIS PROCEEDING WOULD INTERFERE WITH THE BOARD'S
ABILITY TO MANAGE ITS DOCKET AND WOULD WASTE TIME AND
RESOURCES.
IEPA has spent the better part
of the last decade conducting detailed analyses in
preparation for this rulemaking to amend water quality standards and effluent limitations for the
Chicago Area Waterway System (CAWS) and Lower Des Plaines River. (Statement
of Reasons,
I
Putting aside the merits of these alleged deficiencies, counsel for the District fails to acknowledge that the
evidentiary record will not be complete until after the parties file testimony
in August and hearings are held in
September, in accordance with the schedule set by the Hearing Examiner.
2
Electronic Filing - Received, Clerk's Office, June 26, 2008
at 22-23.) IEPA has actively involved stakeholders in this process since at least September 2002,
when IEPA convened a Stakeholders Advisory Committee. (Statement
of Reasons, Attachment
E "Timeline
of Lower Des Plaines River and CAWS Stakeholder Advisory Committee Meetings
and Outreach Activities.")
IEPA'sefforts culminated with the proposed rule presented to the
Board on October 26, 2007.
The Board formally commenced this rulemaking on November
1, 2007 and, since then,
89 interested parties have registered electronically in this docket. The Board has held ten days
of
hearings to allow stakeholders to cross-examine IEPA witnesses on pre-filed testimony and over
56 exhibits that have been filed in this proceeding. The Board also heard testimony from 44
people at a public hearing on June 16, 2008, and has received written public comments from over
65 parties-virtually all in support of the proposed rules.
The Board has set a deadline
of August 4, 2008, for parties to submit additional pre-filed
testimony in preparation for another round of hearings to begin in September 2008. (May 19,
2008 Board Order). Many parties, including the People, have retained witnesses and are hard at
work to finish testimony by the August 4
th
deadline. Most parties have already expended
significant effort and resources on this testimony, which was originally due on February 19,
2008. (November 20, 2007 Board Order).
All stakeholders have had ample time to conduct studies and prepare testimony for this
docket-over the course of at least five years of discussions prior to the rulemaking and during
almost a year since this docket was formally commenced.
It
is therefore surprising that the
District has chosen to file a motion to stay rather than file expert testimony. The District.claims
that experts retained by the District need more time-until at least the end of 20 1O-to complete
their analysis. (Motion at 14.) If true, that is a problem of the District's own making.
3
Electronic Filing - Received, Clerk's Office, June 26, 2008
The District apparently waited until the Summer of 2007 to begin a peer review process
to examine the epidemiological, microbiological and other research studies that
th~
District
hopes to use in testimony for this proceeding. (Motion, Exhibit A.) The District
now claims to
have a "final study plan [that] reflects modifications that were advised in the peer review
process." (Motion, Exhibit A, p. 2.) In other words, the District has essentially been told by a
panel
of experts that testimony based on its existing studies will not withstand cross-
examination. Consequently, the District now asks the Board, the many parties to this proceeding
and the thousands
of people who recreate in the CAWS and Lower Des Plaines to wait for
several years until the District does what it should have done a long time ago to prepare for this
proceeding. The Board cannot allow a party to stall a proceeding because
of its failure to
properly prepare.
A stay would result in an enormous waste
of the resources that the Board, IEPA and other
parties to this rulemaking have already expended.
If there were a lengthy stay of this proceeding,
all parties would be required to expend additional time and resources to update their analyses and
testimony when the proceeding resumes.
It
would send IEPA back to the drawing board to
d~vise
a new proposal that could not be presented until 2011 at the earliest; it would require all
of the other private and public stakeholders to prepare anew for a new iteration of the
rulemaking; and it would force the Board to write
off the substantial investment of time and
resources in this
proceeding-only to repeat the entire effort in several years' time.
A stay would waste the
Board'sresources, disrupt its docket, waste public monies, and
place additional burdens on other parties to this proceeding. These considerations clearly
outweigh unsupported representations that the District's studies will aid the Board in its decision
making.
If the District's studies were as critically relevant to this proceeding as the District
4
Electronic Filing - Received, Clerk's Office, June 26, 2008
claims, they should have been initiated and completed at a much earlier date.
The District's request to stay this proceeding seems calculated to obstruct, rather than aid,
the Board's decision making in this docket. This rulemaking should proceed, in accordance with
the schedule already set by the Board. The District's motion should be denied on the grounds
that
it would interfere with the Board'sability to manage its docket and would waste the time
and resources
of the Board and all parties involved in this proceeding.
IV.
A STAY WOULD BE INJURIOUS TO THE PUBLIC INTEREST AND
HARMFUL TO THE ENVIRONMENT.
When the Clean Water Act was enacted in 1972, it articulated several national goals,
starting with the following:
(l) it is the national goal that the discharge of pollutants into the navigable waters be
eliminated by 1985;
(2) it
is the national goal that wherever attainable, an interim goal of water quality which
provides for the protection and propagation
of fish, shellfish, and wildlife and
provides for recreation in and on the water be achieved by July
1, 1983.
33 U.S.C. § 1251(a)(l) and (2).
The State of Illinois is required to conduct a triennial review of use designations and the
applicable water quality standards necessary to protect designated uses for all navigable
waterways that have not previously been determined to be fishable and swimmable, in
accordance with
33 U.S.C. § 1251(a)(2). 33 U.S.C. § 1311(c)(l); 40 C.F.R. 131.20(a). The
State is also required to review and revise, as necessary, effluent limitations at least every five
years.
33 U.S.C. § 1311(d). That IEPA has been preparing for
thi~
rulemaking since 2002 is but
one indication that the State has failed to meet these requirements for the CAWS and the Lower
Des Plaines River.
5
Electronic Filing - Received, Clerk's Office, June 26, 2008
This rulemaking is designed meet these Clean Water Act requirements. In this
proceeding, the Board
is on course to make a long overdue determination as to the uses that are
attainable for the CAWS and the Lower Des Plaines, and the water quality standards and effluent
limitations that are necessary to attain and protect those uses. Failure to make these
determinations as expeditiously as possible would not only be harmful to the environment and
the public interest, but would also violate clear deadlines established by federal law.
The District appears to have confused certain institutional self-interests with the public
interest. Indeed, instead
of
serving
the public's interest and
responding
to widespread public
support for the proposed rules, the District appears to be trying to manipulate the
public-issuing
an "Urgent Call to Action" and providing sample letters for the public to send to the Board in
support
of the District's request for a stay of this proceeding.
See,
Exhibit A. This is
questionable behavior for a public
agency-which exists to serve the public, not to enlist the
public in a campaign to persuade the Board to grant the District more time to prepare testimony
that should have been prepared long ago. A stay would be injurious to the public interest and
harmful to the environment and should, therefore, not be permitted in this case.
v.
THE DISTRICT'S MOTION TO
STAY
THIS PROCEEDING IS CONTRARY TO
BOARD PRECEDENT.
The District does not cite any previous Board orders in which the Board stayed a
rulemaking proceeding upon the motion
of a participant. In fact, a search of the Board's on-line
document collection indicates that the Board has never before been presented with such a
motion, let alone granted one. The District's proposal appears to be truly
unprecedented-and
should not be granted.
6
Electronic Filing - Received, Clerk's Office, June 26, 2008
The four Board orders that the District cites in support of the motion to stay are readily
distinguishable from the facts and legal posture
of this proceeding. None of the orders cited by
the District involve a rulemaking proceeding.
See
Israel Gerold's v. IEPA, PCB 91-108 (July 11,
1991) (Underground Storage Tank Fund Reimbursement Determination);
People of the State of
Illinois v. State Oil Co., PCB 97-103 (May 15,2003) (Enforcement-Water, Land); In the
Matter
of the Petition of Midwest Generation, LLC, Will County Generating Station for an
Adjusted Standard from 35 Ill. Adm. Code 225.230, AS 07-04 (March
15,2007) (Adjusted
Standard-Air); and In the Matter of the Petition of Cabot Corp. for an Adjusted Standard from
35 Ill. Adm. Code Part 738, Subpart B, AS 07-06 (Adjusted
Standard-Land) (August 9,2007).
Moreover, in each of those four orders, the Board granted a motion to stay primarily because of a
related concurrent proceeding before another body. See Israel Gerold's, PCB 91-108 (July 11,
1991) at 1 (pending proceeding in Illinois circuit court); State Oil Co., PCB 97-103 (May 15,
2003) at 1 (pending proceeding in Illinois appellate court); In re Midwest Generation, L.L.C., AS
07,-04 (March
15,2007) at I (pending Board rulemaking proceeding); In re Cabot Corp., AS 07-
06 (August 9, 2007) at 1 (pending petition before United States Environmental Protection
Agency).2 In this rulemaking proceeding,
by contrast, there are no concurrent proceedings.
The District cites In re Midwest Generation,
L.L.c., AS 07-04 (March 15,2007) and In
re Cabot Corp., AS 07-06 (Aug. 9, 2007) for the proposition that the Board has historically
granted motions to stay in order to
1) "avoid wasting time, expenses, or resources"; 2) "avoid
practical difficulties"; 3) "avoid duplicative efforts by the Board and other review authorities
addressing related issues"; and 4) "assist the'Board in making the proper determination."
(District Mtn. to Stay at 4). Given that the Board did not actually address any
of these
2 These proceedings are also distinguishable for the reason that only in Israel Gerold's did IEPA oppose the motion
to stay.
7
Electronic Filing - Received, Clerk's Office, June 26, 2008
considerations in those two orders, the District's argument fails, Moreover, even 'by reference to
the District's hand-picked criteria, its motion fails, As discussed above, the District's proposal
would be wasteful and would not assist the Board, but rather would interfere with the Board's .
ability to manage its docket. The District's motion is unsupported by Board precedent and
should be denied,
VI.
CONCLUSION
A motion to stay a rulemaking proceeding is unprecedented. Staying this rulemaking
would be injurious to the public interest, harmful to the environment, and would result in an
extraordinary waste
of the resources of the Board, the IEPA, and the many other public and
private stakeholders that have spent years preparing for and participating
in this proceeding. For
all
of the reasons stated herein, the People request that the Board deny the District's motion to
stay this proceeding.
LISA MADIGAN,
Attorney General
of the
State of Illinois
By:
5=-~
Susan Hedman
Envirorimental Counsel
(312) 814-4947
Andrew Armstrong
Assistant Attorney General
(312) 814-0660
Environmental Division
69 West Washington Street, Suite 1800
Chicago, Illinois 60602
(312) 814-4947
DATE: June 26, 2007
8
Electronic Filing - Received, Clerk's Office, June 26, 2008
EXHIBIT A
Electronic Filing - Received, Clerk's Office, June 26, 2008
Metropolitan Water Reclamation District of Greater Chicago
100 EAST ERIE STREET
CHICAGO, ILLINOIS 60611-3154
312'751'5600
. ,.,
.~::
:
BOARD OF COMMISSIONERS
Terrence
J.
O'Brien
President
Kathleen Therese Meany
Vice President
Gloria Aillto Majewski
Chairman
of Finance
Frank Avila
Pstricia Horton
Barbara
J.
McGowan
Cynthia M. Santos
Debra Shore
Patricia Young
URGENT CALL TO ACTION:
Proposed Water Quality Standards
Public Hearing Monday, June 16
5:30 p.m. to 8:00 p.m.
Me~ropolitan
Water Reclamation District
100 East
Erie. Chicago
The lllinois Pollution Control Board will be holding a public hearing on the
Proposed Waterway
Use Classifications and Water Quality Standards
- Docket R08-009.
The Metropolitan Water Reclamation District is conducting studies that will enable a scientific
, basis to determine whether the proposed standards will benefit the health of people recreating on
the waterways. These studies will also determine if aquatic life will
be improved.
If
the proposed standards are approved, they will have a major economic impact on the area. The
costs
of meeting these standards will be borne by taxpayers.
Water quality has dramatically improved in past decades
thanks to the initiatives undertaken by
the Metropolitan Water Reclamation District. The proposed water standards require further
deliberation and study to demonstrate the need for new rulemaking.
If
you would like to testify at the hearing in person, here is what you must do:
Sign-in on Monday June 16, 2008 prior to 5:30 p.m. -or - contact the Hearing Officer before
June
16
th
by phone or email advising that you wish to testify.
.
If
you would like to submit comments in writing to the Dlinois Pollution Control Board:
Send your comments to the IPCB web-site at www.ipcb.state.iI.us. A Sample Letter has been
provided in your packet.
Also, kindly advise Jill Horist, Manager Public Affairs, if you will be attending the hearing,
testifying at the hearing, or sending comments in writing. You may contact her
at: 312-751-7909
or jill.horist@mwrd.org.
Electronic Filing - Received, Clerk's Office, June 26, 2008
SAMPLE
John Therriault
lllinois Pollution Control Board
James R. Thompson Center
100 W. Randolph
Suite 11
~500
ChIcago, lllinois 60601
Subject: IPCB
Docket R08-9
To the members of the illinois Pollution Control
~oard:
SAMPLE
I believe any decisions in this rulemaking should be delayed until it is certain that
promulgation
of standards proposed by the lllinois Environmental Protection Agency will
result in a significant and meaningful public health or environmental benefit.
It
is my
understanding that the Metropolitan Water Reclamation District ofGreater Chicago is
conducting studies that wili enable you to have a scientific basis to detemtine whether the
proposed standards will benefit the health
ofpeople recreating on the waterways and further
improve aquatic life in the waterways.
:.. -_. -TIecostS.ofmeetililfll:i:e proposedStatidaras ai'tfniginmo-Willoebomeoyfaxpayers:1""Wan"l-'----_......- -_...:....
to make certain that tax dollars are not diverted for unnecessary projects that may not provide
any benefit to the taxpayers and in fact could increase greenhouse gas emissions causing
further harm to the environment.
. Regardless that the current water quality standards h8ve not changed in depades, water
quality has dramatically improved thanks to the initiatives undertaken
by the Metropolitan
Water Reclamation District. Water quality will
~ontinue
to improve as-it hasover the past
decades, when the Metropolitan Water Reclamation District completes the deep tunnel
pr~ject
reservoirs in the near future.
It
is imperative that prior to issuing a decision, the Board consider all ofthe on.going studies
being conducted
by the District.. Until such time, iUs premature to issue rules that will be
extremely costly to taxpayers and may not provide
aily publi,? health or environmental.
benefit.
Sincerely,
Electronic Filing - Received, Clerk's Office, June 26, 2008
CERTIFICATE OF SERVICE
I, ANDREW ARMSTRONG, do certify that I filed electronically with the Office of the
Clerk
of the Illinois Pollution Control Board the foregoing Notice of Filing and Response in
Opposition to Motion to Stay by the People of the State of Illinois and caused them to be served
this 26th day
of June, 2008 upon the persons listed on the attached Service List by depositing
true and correct copies
of same in an envelope, first class postage prepaid, with the United States
Postal Service at 69 West Washington Street, Chicago, Illinois, unless otherwise noted on the
SerVice List.
ANDREW
t!LL-~
ARMSTRONG
Electronic Filing - Received, Clerk's Office, June 26, 2008
SERVICE LIST R08-9
Mr. John T. Therriault
Assistant Clerk
of the Board
Illinois Pollution Control Board
100 West Randolph Street
Suite 11-500
Chicago, Illinois 60601
[by electronic mail]
Ms. Marie E. Tipsord
Hearing Officer
Illinois Pollution Control Board
100 West Randolph Street
Suite 11-500
Chicago, Illinois 60601
Deborah
J. Williams, Esq.
Stefanie
N. Diers, Esq.
Illinois EPA
1021 North Grand Avenue East
Post Office Box 19276 .
Springfield, Illinois 62794-9276
Frederick
M. Feldman, Esq.
Ronald
M. Hill, Esq.
Mr. Louis Kollias
Margaret
T.
Conway
Metropolitan Water
Reclamation District
100 East Erie Street
Chicago, Illinois 60611
Richard
J. Kissel, Esq.
Roy
M. Harsch, Esq.
Drinker, Biddle, Gardner, Carton
191 North Wacker Drive
Suite 3700
Chicago, Illinois 60606-1698
Claire
A.
Manning, Esq.
Brown, Hay
&
Stephens, LLP
700 First Mercantile Bank Building
205 South Fifth Street
Post Office Box 2459
Springfield, Illinois 62705-2459
Kevin
G. Desharnais, Esq.
Thomas
W. Dimond, Esq.
Thomas V. Skinner, Esq.
Mayer, Brown LLP
71 South Wacker Drive
Chicago, Illinois 60606-4637
Charles
W. Wesselhoft, Esq.
James T. Harrington, Esq.
Ross
&
Hardies
150 North Michigan Avenue
Suite 2500
Chicago, Illinois 60601-7567
Mr. Robert VanGyseghem
City
of Geneva
1800 South Street
Geneva, Illinois 60134-2203
Jerry Paulsen, Esq.
Cindy Skrukrud, Esq.
McHenry County Defenders
132 Cass Street
Woodstock, Illinois 60098
Mr. Bernard Sawyer
Mr. Thomas Granto
Metropolitan Water
Reclamation District
6001 West Pershing Road
Cicero, Illinois 60650
Ms. Lisa Frede
Chemical Industry Council
of Illinois
2250 East Devon Avenue
Suite 239
Des Plaines, Illinois 60018-4509
Fredric P. Andes, Esq.
Erika
K. Powers, Esq.
Barnes
&
Thornburg LLP
1 North Wacker Drive
Suite 4400
Chicago, Illinois 60606
Electronic Filing - Received, Clerk's Office, June 26, 2008
Mr. James
L.
Daugherty
Thorn Creek Basin Sanitary District
700 West End Avenue
Chicago Heights, Illinois 60411
Ms. Sharon Neal
Commonwealth Edison Company
125 South 'Clark Street
Chicago, Illinois 60603
Tracy Elzemeyer, Esq.
American Water Company
727 Craig Road
St. Louis, Missouri 63141
Margaret
P. Howard, Esq.
Hedinger Law Office
2601 South Fifth Street
Springfield, Illinois 62703
Mr. Keith
I.
Harley
Ms. Elizabeth Schenkier
Chicago Legal Clinic, Inc.
205 West Monroe Street
Fourth Floor
Chicago, Illinois 60606
Frederick
D. Keady, P.E.
Vermillion Coal Company
1979 Johns Drive
Glenview, Illinois 60025
Mr. Fred
L.
Hubbard
16 West Madison
Post Office Box
12
Danville, Illinois 61834
Ms. Georgia Vlahos
Naval Training Center
2601A Paul Jones Street
Great Lakes, Illinois 60088-2845
W.C. Blanton, Esq.
Blackwell Sanders LLP
4801 Main Street
Suite 1000
Kansas City, Missouri 64112
Mr. Dennis
L.
Duffield
City
of Joliet, Department of Public
Work and Utilities
921 East Washington Street
Joliet, Illinois 60431
Ms. Kay Anderson
American Bottoms RWTF
One American Bottoms Road
Sauget, Illinois 62201
Mr. Jack Darin
Sierra Club
70 East Lake Street
Suite 1500
Chicago, Illinois 60601-7447
Mr. Bob Carter
Bloomington Normal Water
Reclamation District
Post Office Box 3307
Bloomington, Illinois 61702-3307
Mr. Tom Muth
Fox Metro Water Reclamation District
682 State Route
31
Oswego, Illinois 60543
Mr. Kenneth
W. Liss
Andrews Environmental Engineering
3300 Ginger Creek Drive
Springfield, Illinois 62711
Albert Ettinger, Esq.
Jessica Dexter, Esq.
Environmental Law
&
Policy Center
35 East Wacker
Suite 1300
Chicago, Illinois 60601
Electronic Filing - Received, Clerk's Office, June 26, 2008
Ms. Vicky McKinley
I;:vanston Environment Board
223 Grey Avenue
Evanston, Illinois 60202
Mr. Marc Miller
Mr. Jamie
S. Casten
Office
of Lt. Governor Pat Quinn -
Room 414 State House
Springfield, Illinois 62706
Susan M. Franzetti, Esq.
Franzetti Law Firm P.C.
10 South LaSalle Street
Suite 3600
Chicago, Illinois 60603
Mr. Irwin Polls
Ecological Monitoring and Assessment
3206 Maple Leaf Drive
Glenview, Illinois 60025
Dr. Thomas
J. Murphy
2325 North Clifton Street
Chicago, Illinois 60614
Ms. Cathy Hudzik
City
of Chicago-Mayor's Office
of Intergovernmental Affairs
121 North LaSalle Street
City Hall - Room 406
Chicago, Illinois 60602
Ms. Beth Steinhour
2021 Timberbrook
Springfield, Illinois 62702
Mr. James
Huff
Huff
&
Huff, Inc.
915 Harger Road
Suite 330
Oak Brook, Illinois 60523
Ann Alexander, Esq.
Natural Resources Defense Council
101 North Wacker Drive
Suite 609
Chicago, Illinois 60606
Ms. Traci Barkley
Prairie Rivers Network
1902 Fox Drive
Suite 6
Champaign, Illinois 61820
Jeffrey
C. Fort, Esq.
Ariel
J. Tesher, Esq.
Sonnenschein Nath
&
Rosenthal
7800 Sears Tower
233 South Wacker Drive
Chicago, Illinois 60606-6404
Kristy
A. N. Bulleit, Esq.
Brent Fewell, Esq.
Hunton
&
Williams LLC
1900 K Street,
NW
Washington, DC 20006
Lyman
C. Welch
Manager, Water Quality Programs
Alliance for the Great Lakes
17 North State Street
Suite 1390
Chicago, Illinois 60602
Stacy Meyers-Glen
Openlands
25 East Washington Street
Suite 1650
Chicago, Illinois 60602
Katherine
D. Hodge
Thomas G. Safley
Monica
T. Rios
,Hodge Dwyer Zeman
3150 Roland Avenue
Post Office Box 5776
Springfield, Illinois 62705-5776
Electronic Filing - Received, Clerk's Office, June 26, 2008
