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Pre-filed Testimony ofAlbert Ettinger

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Board

I

am Senior StaffAttorney at the Environmental Law & Policy Center ofthe Midwest

and

Water Issues Coordinator and General Counsel forthe Illinois Chapterofthe Sierra Club. I

have worked in Illinois on matters relating to water pollution and implementation ofthe federal

Clean Water Act since 1982. I am the primary drafter ofthe petition to amend the Part 309

Subpart A.

Earlier drafts ofthe petition were discussed with officials ofIllinois EPA and members of

various interest groups concerned with the NPDES permitting process. Various changes were

made to the draft in response to views express in these discussions but no consensus was reached

as to the proposal.

The proposal amends the most recent version ofthe rule as published on the Board’s Web

site.

I would be pleased to answer any questions by the Board ormembers ofthe public

regarding the proposal, the reasons that it is being offered, or its expected effect.