IN THE MATTER OF:
WATER QUALITY TRIENNIAL REVIEW
AMENDMENTS TO
35
ILL. ADM. CODE
302.208(e)-(g), 302.504(a), 302.575(d), 303.444,
309.14 1(h); AND PROPOSED
35
ILL. ADM.
CODE
301.267, 301.313, 301.413, 304.120, AND
309. 157
NOTICE OF FILING
TO:
Dorothy M. Gunn
Clerk ofthe Board
Illinois Pollution Control Board
James R. Thompson Center
100 West Randolph Street
Suite 11-500
Chicago, Illinois 60601
(VIA FIRST CLASS MAIL)
Marie E. Tipsord
Hearing Officer
Illinois Pollution Control Board
James R. Thompson Center
100 West Randolph Street
Suite 11-500
Chicago, Illinois 60601
(VIA FIRST CLASS MAIL)
(PERSONS ON ATTACHED SERVICE LIST)
PLEASE TAKE NOTICE that I have filed today with the Clerk ofthe Illinois
Pollution Control Board an original and nine copies of
COMMENTS OF THE
ILLINOIS ENVIRONMENTAL REGULATORY GROUP,
copies of which are
herewith served upon you.
Dated: February 20, 2002
Robert A. Messina
Illinois Environmental Regulatory Group
215
East Adams Street
Springfield, Illinois 62701
(217) 522-5512
Respectfully submitted,
ILLINOIS ENVIRONMENTAL
REGULATORY GROUP,
By:
~
One o Its Attor(ieys
BEFORE THE
)
)
)
)
RECEiVED
BOARD
CLERK’S OFFICE
FEB 2 52002
STATE OF ILLINOIS
R02-1
1
PollutIon Control Board
(Rulemaking-Water)
)
)
)
)
THIS FILING SUBMITTED ON RECYCLED PAPER
RE
CE WED
CLERK’S OFFICE
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
FEB
2
5
2002
IN THE MATTER OF:
)
PollutionSTATE
OFControlIWNOISBoard
)
WATER QUALITY AMENDMENTS TO
)
R02-1 1
35 Ill. Adm. Code 302.208(e)-(g),
302.504(a),
)
(Rulemaking
-
Water)
302.575(d),
303 .444, 309.141(h); and
)
PROPOSED 35 Ill. Adm. Code 301.267,
)
301.313,301.413,304.120,and3O9.157
)
COMMENTS OF
THE ILLINOIS ENVIRONMENTAL REGULATORY GROUP
NOW COMES the ILLINOIS ENVIRONMENTAL REGULATORY GROUP
(“IERG”), by one ofits attorneys, Robert A. Messina, and submits the following
comments in the above-referenced matter to the Illinois Pollution Control Board
(“Board”), stating as follows:
The Illinois Environmental Regulatory Group (IERG) submits the following
comments in support of the proposed rulemaking entitled “Water Quality Triennial
Review (R02-11).” IERG thanks the Illinois Pollution Control Board (“Board”) for the
opportunity to submit these comments today. IERG reserves the right to supplement or
modif~’these comments at the close of testimony.
IERG is a not-for-profit Illinois corporation comprised of 70 member companies
engaged in industry, commerce, agriculture, and other related activities, that are regulated
by governmental agencies that promulgate, administer or enforce environmental laws and
regulations. IERG was organized to promote and advance the interests of its members
before governmental agencies, such as the Illinois Environmental Protection Agency and
Illinois Pollution Control Board, and before judicial bodies, such as the Illinois Courts.
Moreover, IERG is an affiliate ofthe Illinois State Chamber ofCommerce, which has
more than 5,000 members in the State. Finally, a great number ofIERG’s members
would be affected by this rule.
IERG first became involved in this matter in the fall of2000, at which time the
Illinois EPA began to circulate drafts ofthe proposal to various interested parties,
including members ofboth the regulated and environmental communities. IERG has
reviewed the proposal and shared it with our members. We believe that the proposal is
reasonably and technically astute, and that Illinois EPA relied upon sound science and
methodologies in developing this proposal. In short, IERG supports the Agency’s efforts,
and urges the Board to adopt the amendments to 35 Ill. Adm. Code 302.208(e)-(g),
302.504(a),
302.575(d),
303.444, 309.141(h), and language found at 35 Ill. Adm. Code
301.267, 301.313, 301.413, 304.120, and 309.157 as proposed.
Respectfully submitted,
ILLINOIS ENVIRONMENTAL
REGULATORY GROUP,
By:/~~
/2
Robert A. Messi~
~2:’~/~
Dated: February 20, 2002
Robert A. Messina
Illinois Environmental Regulatory Group
215 East Adams Street
Springfield, Illinois 62794-9276
(217) 522-5512
2
CERTIFICATE OF SERVICE
I, Robert A. Messina, the undersigned, certify that I have served a copy ofthe
COMMENTS OF THE ILLINOIS ENVIRONMENTAL REGULATORY GROUP,
upon:
Dorothy M. Gunn
Clerk ofthe Board
Illinois Pollution Control Board
James R. Thompson Center
100 West Randolph Street
Suite 11-500
Chicago, Illinois 60601
SEE ATTACHED SERVICE LIST.
Marie E. Tipsord
Hearing Officer
Illinois Pollution Control Board
James R. Thompson Center
100 West Randolph Street
Suite 11-500
Chicago, Illinois 60601
by depositing said documents in the United States Mail in Springfield, Illinois on
Rkbert A. ~\46ssina
February 20, 2002.
SERVICE LIST
Mike Callahan
Bloomington Normal Water Reclamation District
P 0 Box 3307
Bloomington, IL 61702-3307
Larry Cox
Downers Grove Sanitary District
2710 Curtiss Street
Downers Grove, IL 60515
Dennis Duffield
Department of Public Works City of Joliet
921 E Washington
Joliet, IL 60433-1267
Albert Ettinger
Environmental Law & Policy Center
35 E Wacker Drive Ste 1300
Chicago, IL 60601-2110
Lisa Frede
Director of Regulatory Affairs
Chemical Industry Council of Illinois
9801 W Higgins Rd Ste 515
Rosemont, IL 60018
Dorothy M. Gunn
Clerk
IL Pollution Control Board
100 W. Randolph Ste. 11-500
Chicago, IL 60601
James T. Harrington
Ross & Hardies
150 N. Michigan Ave., Ste. 2500
Chicago, IL 60601 -7567
Katherine D. Hodge
Hodge Dwyer Zeman
3150 Roland Avenue P 0 Box 5776
Springfield, IL 62705-5776
Margaret Howard
Hedinger & Howard
1225 South Sixth Street
Springfield, IL 62703
Torn Muth
Fox Metro Water Reclamation District,
682 State Route 31
Oswego, IL 60543
Irwin Polls
Water Reclamation District
of Greater Chicago
6001
W. Pershing
Rd.
Cirero, IL 60804-4112
Sanjay Sofat
Illinois Environmental Protection Agency
1021 N Grand Ave E P0 Box
19276
Springfield, IL 62794-9276
Marie E. Tipsord
IL Pollution Control Board
100W. Randolph St., Ste. 11-500
Chicago, IL 60601
