Public Comment re: R01-13
    RECEIVED
    December 4, 200(fLERK’S OFFICE
    DEC 0 7 2000
    Ms. Dorothy Gunn
    STATE OF ~LUNOIS
    Clerk ofthe Board
    Pollution Control
    Board
    Illinois Pollution Control Board
    100 W. Randolph St.
    Suite 11-500
    Chicago, illinois 60601
    Re: Public Comment re: RO 1-13
    Dear Ms. Gunn:
    As an Environmental Engineer and a citizen ofthe State ofIllinois for nearly two decades, I
    believe that the Illinois Pollution Control Board (1PCB) should adopt strong rules to prevent
    degradation ofIllinois’ rivers, streams, lakes, and wetlands.
    Illinois’ new Antidegradation regulations should do the following three things:
    1. Prevent any newor expanded pollution source that would harm waters within the state.
    2. All Illinois waters should be protected against new pollution that :is:not necessary to
    accommodate important economic or social development.
    3. Citizens must be allowed to petition to place high quality waters offlimits for increased
    pollution and petition requirements must not be overly burdensome.
    First, new or increased discharges ofpollutants should not be allowed where theywill harm the
    biological integrity ofthe receiving waters. No state permits or approvals should be granted for
    pollution discharges or other pollution-causing projects unless it is clear, after study by state
    biologists ofthe receiving stream that the new pollution will not kill or harm aquatic life or other
    wildlife. These findings should be documented in a clear and rigorous manner, and be available
    for review by non-state biologists and the general public.
    Secondly, all Illinois waters should be protected against new pollution that is not necessary to
    accommodate important economic or social development. All reasonable alternatives to
    allowing the new pollution must be considered careftully.
    Developers and dischargers may argue that the illinois antidegradation rules should only apply to
    the very highest quality streams and that the rest ofthe state’s waters should be allowed to be
    polluted until theyjust barely meet water quality standards. But the health ofthe environment
    and the Clean Water Act require that we do better than that. Just barely meeting Illinois water
    quality standards is certainly not good enough, particularly given that those standards are far too
    weak at present.
    Also, the rules should NOT exempt “small” or “de minimus” new or increased pollution to be
    permitted without an antidegradation analysis. While obviously a small increase in relatively
    harmless new pollution need not be studied with the same care as a proposed major new
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    Public Comment re: R01-13
    discharge oftoxins or other pollutants, nothing should be allowed to fly in under the radar.
    Little sources ofpollution add up to big problems.
    Under the Illinois EPA proposal, the antidegradation protections will not apply to new pollution
    sources that fall under general permits. This means that many new business and construction
    permits that cause increased stormwater run-offpollution would be permitted even ifthey would
    harm high quality streams. I urge the Pollution Control Board to plug this loophole.
    No new pollution should be allowed until it is shown that it is truly necessary for important
    economic or social development. For example, if a company claims that newpollution is
    necessary to have a new factory that will providejobs, the company should at least be required to
    estimate what jobs it will provide and what it would cost to avoid the new pollution. We can then
    see what is being “saved” and “gained” by allowing new pollution in our waters.
    Thirdly, citizens must be allowed to petition to place high quality waters offlimits for increased
    pollution.
    In all regions ofthe state, there are a few high quality lakes and streams that should be preserved
    in their existing high quality. To protect natural beauty, endangered species, wildlife, and
    opportunities for our children to enjoy nature and outdoor recreation, new development should
    be preventing from impacting these outstanding waters.
    The Illinois EPA proposal allows citizens to petition to have waters designated as “Outstanding
    Resource Waters” and protected from future pollution, but practically makes it impossible for
    them to do so. Under the proposal, notice must be given to many more types ofbusinesses and
    individuals than is reasonably necessary. Also, the proposed rules require citizen groups to
    provide evidence on potential economic impacts ofan Outstanding Resource Water designation
    although such groups obviously do not have access to the necessary information. I urge the
    Board to eliminate unnecessary burdens on ORW petitions and not require citizens to offer
    testimony on things that only business knows. Such petitions should not be tied up in a lot of
    unnecessaryred tape and citizens should not be expected to show the economic impacts ofthe
    designation. Ifdevelopers and other businesses are concerned about a potential ORW
    designation, they can come forward with evidence as to how it might hurt their revenues or costs.
    Thank you for the opportunity to voice my opinion on these matters. Please place me on the
    mailing list forthe responsiveness summary, or other official response to these proceedings.
    Yours truly,
    ~t Pi~
    Mr. Brett M. Schmidt
    800 Shanahan Court
    Naperville, IL 60540-8219
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