BEFORE THE ILLINOIS POLLUTION
OR IIGI\AL
CONTROL BOARDRECEIVED
CLERK'S OFFICE
IN THE MATTER OF
:
)
PROPOSED AMENDMENTS TO
)
R04-25
DISSOLVED OXYGEN STANDARD
)
35 IILL. ADM
. CODE 302 .206
)
NOTICE
TO:
Dorothy Gunn, Clerk
Richard McGill, Hearing Officer
Illinois Pollution Control Board
Illinois Pollution Control Board
James R
. Thompson Center
James R
. Thompson Center
100 W. Randolph Street 11-500
100 W . Randolph Street, Suite 11-500
Chicago, Illinois 60601
Chicago, Illinois 60601
SEE ATTACHED SERVICE LIST
PLEASE TAKE NOTICE that I have filed with the Office of the Clerk of the
Pollution Control Board the Illinois Environmental Protection Agency's
Exhibit 39 on
behalf of the Illinois Environmental Protection Agency, a copy of which is herewith
served upon you.
Date: December 20, 2006
1021 North Grand Avenue East
Springfield, Illinois 62794-9276
(217) 782-5544
ILLINOIS ENVIRONMENTAL PROTECTION
AGE CY
S
anie N. Diers
istant Counsel
sion of Legal Counsel
THIS FILING IS SUBMITTED ON RECYCLED PAPER
DEC 2 2 2006
Pollution
STATE OF
Control
ILLINOISBoard
Introduction :
Over the last 30+ years the Illinois water quality standards have been modified to reflect
more-recent scientific understanding of specific numeric chemical criteria in order to better
protect both human health and aquatic life . Although these standards have proven effective for
monitoring and controlling point source discharges, their application toward assessing overall
ecological integrity is limited
. As a result, Illinois water quality standards have not reflected
advances in the use of non-chemical data (i.e. biological criteria) for achieving Clean Water Act
aquatic life goals . This paper focuses on biological criteria and tiering or subdividing the aquatic
life use as an approach to updating Illinois water quality standards
.
Background
The basic framework for the current water quality standards in Illinois were formulated in
1972 . To a large extent they brought together existing water quality standards and associated
provisions scattered throughout a number of separate regulations
. The goal of these standards,
with the exception of a few "highly industrialized streams in the Chicago area," was that all
waters were to be protected from nuisances and health hazards and be capable of supporting
aquatic life
. The standards also exist for Illinois to meet the goals of the Federal Clean Water
Act (CWA). The primary objective of the CWA is the restoration and maintenance of the
chemical, physical and biological integrity of the Nation's waters
. Under the CWA, States are
responsible for adopting and revising water quality standards and must consider their use and
value in protecting public water supplies, propagation of fish and wildlife, recreation, agriculture,
industrial and navigation purposes .
Historically, when the term water quality is used, it implies the chemical characteristics
of the water. As a result, when the term water quality standard is used, it generally refers only to
the numeric chemical criteria
. However, water quality standards on a national scale are typically
referred to as consisting of three basic parts :
1 . A designated use,
2 . A water quality criteria which can be either numeric
(e.g., total ammonia-N shall not
exceed 15 mg/1) or narrative (e.g., Waters of the State shall be free from sludge
. . .) and,
3 . A non-degradation statement that not only prevents waterbodies from becoming worse
but also protects those which are already achieving the use at a higher level .
A
designated use, is the activity or processes that a state wishes the waterbody to support
. For
example, in Illinois under the General Use water quality standards (Title
35
Illinois
Administrative Code Subpart B, Section
302 .201)
designated uses for most surface waters
include aquatic life, wildlife, agriculture, secondary contact, most industrial uses, aesthetic
Illinois EPA - Bureau of Water
TALU Framework
September 2006
1 of 8
EXHIBIT390
R I
L7 I
I V
A L
RER'S
OFFICE
DEC 2 2 2006
Pollution
STATE
OF
ControlILLINOISBoard
Biological Criteria and Tiered Aquatic Life Uses :
Potential Changes to Illinois Water Quality Standards
quality and where physical configuration allows, primary contact . The chemical and narrative
requirements to protect those uses then follow in the regulation
.
However, a single aquatic life use category and numeric criteria as they exist in current
standards fail to account for two fundamental realities
:
1 . Chemical and physical conditions necessary to sustain healthy aquatic life can differ
significantly across the state of Illinois, and
2. The level to which healthy, self-sustaining aquatic life can be attained differs among
various environmental and socioeconomic settings throughout Illinois .
These issues are particularly problematic for the Illinois EPA when developing the
biennial water quality reports required under CWA Sections 305(b) and 314 and the
accompanying 303(d) list of impaired waters
. On the national level and for most states, it has
been recognized that direct measures of fish or macroinvertebrates communities were more
desirable for assessing aquatic life use attainment than relying solely on water chemistry as a
surrogate
. However, state water quality standards typically emphasize numeric criteria .
Ultimately, incorrectly identifying a waterbody as impaired because it has an unattainable or
improperly defined designated use can result in a loss of limited resources spent on the wrong
problem while other waterbodies continue to suffer human health and environmental risks.
Conversely a designated use that is too broad may inadequately protect certain higher quality
resources.
Biological Criteria
Chemical criteria can be either numeric or narrative and protect a designated use by
defining the concentration of a specific parameter that may be allowed without negatively
impacting that use . Biological criteria can also be either numeric or narrative and protect the
aquatic life use by defining the biological condition of the aquatic community that a waterbody
should support . While chemical samples are limited to reflecting the conditions at the time they
are collected, biological samples can reflect both current and cumulative effects for months to
years prior to collection
. The limited nature of chemical sampling may miss spills or events that
can have significant impacts on aquatic communities .
The incorporation of biological criteria into water quality regulations would not appear
that much different than chemical criteria
. A narrative biological criterion might state,
"Measures ofbiological integrity for aquatic macroinvertebrates and fish assemblages must be
within the range ofthe reference condition ."
A numeric biological criterion might state, "Fish
index of
biotic integrity scores for wadeable streams must be greater than the 25` n percentile of
scores that represent the appropriate reference condition for that site ."
The concepts of biological criteria are not new to the state of Illinois
. The Illinois EPA
has been using biological data (fish and macroinvertebrates) along with chemical and habitat
data as part of the CWA 305(b) aquatic life use assessment process since 1986
. In 1993, the
Illinois EPA initiated a Biocriteria Workgroup to allow stakeholders the opportunity to
participate in the development of biological criteria . To date the process has focused primarily
Illinois EPA - Bureau of Water
TALU Framework
September 2006
2 of 8
on updating the biotic indices. As a result, development of a revised fish IBI was completed in
2001 and a new macroinvertebrate IBI was completed in 2005
.
Adopting biological criteria as a part of Illinois water quality standards would formalize
the current practices of using biological data:
1
. As a measure of use attainability for CWA reporting requirements, TMDL
development and internal studies,
2. To develop more refined aquatic life use tiers
; and,
3
. As a tool to evaluate antidegradation .
Tiered Aquatic Life Uses (TALU)
Tiered aquatic life uses are based on the expected biological condition in specified
waterbodies and represent the distance the biotic community is from achieving an acceptably
high level of biological integrity. They reflect the fact that biological conditions will vary based
on the level of natural and anthropogenic stresses that have occurred within a waterbody type .
Some states have water quality standards that are based on different types of waterbodies
but these are not true tiered aquatic life uses
. Federal Regulations (40 CFR 131 .10.c) allow
states to adopt sub-categories of a use and set criteria to reflect the varying needs of the sub-
categories within their water quality standards . For aquatic life, these different use sub-
categories represent waterbody classes or types, which have fairly predictable and
distinguishable biological communities
. One example is for Salmonids (i .e., trout) which cannot
survive in streams where water temperatures are too high
. Some states use the ability of a stream
to support Salmonids to separate "coldwater" from "warmwater" streams
. Numeric criteria for
ammonia, dissolved oxygen and temperature may vary between these two stream types in order
to protect the biota that occur there
. A second example is for the Great Lakes where Illinois,
along with other states, have a different set of standards than other waters within the state to
protect the uses in Lake Michigan . Within any given region there are many different types of
waterbodies including lakes, wetlands, large rivers, etc
. that may warrant different criteria to
protect the aquatic life use . However, these are not tiered aquatic life uses because each sub-
category is still expected to meet the interim aquatic life goals of the CWA
: ". . .water quality
which provides for the protection and propagation of fish, shellfish and wildlife . . ."
The United States Environmental Protection Agency has developed the biological
conditions gradient
model (BCG) to help explain how tiered aquatic life uses relate to human
disturbance and to aid states in developing a tiered approach (Figure 1)
. As stressors move from
none to high, the ability of a waterbody to retain natural biological communities decreases
. Tiers
in the model range from 1 (natural) to 6 (severe changes) and illustrate the relative position of
the tier to an undisturbed condition . The BCG uses ten ecological attributes expressed at
differing spatial scales to define conditions within a tier
. These are narrative statements on
presence, absence and abundance of several groups of taxa
as well as statements on system
connectivity and ecosystem attributes . For example, if tiered aquatic life uses were designated
for different waterbody types within a state,
(e.g., lakes and streams) a tier would indicate the
same relative degree of human disturbance to the waterbody . A Tier 1 lake or stream would both
Illinois EPA - Bureau of Water
TALU Framework
September 2006
3 of 8
represent those waterbody types where the biological communities were similar to natural
conditions .
Figure 1 . Biological Conditions Gradient Model (USEPA, 2005)
.
0
W
00
Natural structure and function, and taxonomic integrity preserved
osys
main
Matters
ges in structure due to replacement of
sensitive ubi
taxa by more tolerant taxa ; overall
balanced distribu fall expected taxa ; ecosystem
functions largely ma
Conditions show sig
ysiological stress
ecosystem function sho
cod complexity
and redundancy ; increased
or export of
unused materials
Structure and function similar to natural community with some additional taxa &
biomass
; no or incidental anomalies ; sensitive non-native taxa may be present ;
em functions are fully maintained
dent changes in structure due to loss of some rare native
fts in relative abundance ; ecosystem functions fully
through redundant attributes of the system
6
Anomalies may be frequent; ecosys
functions are extremely altered
Low Levels
of Stressors p. High
Because undisturbed watersheds are generally nonexistent in most of the United States,
biological conditions as close to natural as possible are often the beginning point for water
quality standards purposes . As a result, reference conditions may represent Tier 2 or Tier 3 on
the BCG depending on local conditions (e.g.,
regional or statewide) . The actual number of tiers
will depend on the region and data available
. For Illinois, developing tiered aquatic life uses
would likely reflect the reference conditions used in the revised fish and macroinvertebrate IBIs
.
As a result waters proposed for tiered aquatic life use development would be limited to the range
of streams (i.e.,
primarily 3 rd -7th order) represented by those indices
. Each tier would be
assessed against any specific chemical, biological or habitat criteria applicable to that tier
.
Because biological criteria have not been developed for use in Illinois at this time for large
rivers, headwater streams, lakes or wetlands, tiered aquatic life uses would not be applied to
these waters. Waterbodies that are not tiered for aquatic life use would retain existing water
quality standards for protection and assessment purposes (Table 1)
.
Illinois EPA - Bureau of Water
TALU Framework
September 2006
4of8
Developing tiered aquatic life uses and incorporating biological criteria into water quality
standards provides the framework both for identifying high quality waters that warrant more
stringent protection and the process for conducting a Use Attainability Analysis to identify
waterbodies where attaining the designated use is not feasible (40 CFR 131 .10.g)
. Although
tiered aquatic life uses relate directly to biological criteria, they can also be linked with chemical
or physical criteria that are compatible with the goals for a specific tier. These may include
habitat features or chemicals that vary geographically . For example, the level of nutrients
allowed between tiers could vary if those levels would not adversely affect the biota that tier was
expected to support
. On the other hand, for a toxic substance such as cadmium, the chemical
criteria may remain constant across several tiers in order to protect the biota
.
Table 1
. Potential structure of Illinois water quality standards with the addition of tiered
aquatic life use
(ALU).
Note the designated use terms above are for illustrative purposes only .
Each tiered aquatic life use and its associated chemical and biological criteria could be
added under 35 IAC Water Quality Standards Part 302 and the specific waters associated with
each tier identified in Part 303
. Short of restructuring all of Part 302, a new subpart "G" could
be used to define the scope and applicability of tiered aquatic life uses
. For other uses under the
General Use (Section 302 .200), some could be separated
(i.e., primary contact and aesthetic
quality) while others would be linked to a basic protection level . Ultimately stakeholders
involved in a workgroup developing the BCG would have to determine what tiers would be
needed and how they would be defined .
Adding tiered aquatic life uses and biological criteria to Illinois water quality standards
will have multiple effects
. However, it is impossible to predict how significant those will be
until a more complete framework is developed
. First, permitted dischargers could be affected by
changes to aquatic life use designations
. Some waters may warrant more restrictive effluent
limits due to instream standards (i .e.,
ammonia or dissolved oxygen) associated with tiers
reflecting more natural conditions while others may warrant less restrictive effluent limits
.
Illinois
EPA -
Bureau of Water
TALU
September
Framework2006
5 of 8
BCG Tier
Tier 3
Tier 4
Tier 5
Tier 6
Not
Applicable
Designated
Use
Exceptional
ALU
Normal ALU
Modified ALU Limited ALU
General
Aquatic Life
Waterbody
Type
3rd to 7'h Order
Streams
3rd to 7ih
Order
Streams
3rd to 7'" Order
Streams
Yd
to 7m Order
Streams
Lakes, Ponds,
Wetlands,
Large Rivers,
Headwaters
Criteria
Numeric and
Narrative
Chemical and
Biological
Numeric and
Narrative
Chemical and
Biological
Numeric and
Narrative
Chemical and
Biological
Numeric and
Narrative
Chemical and
Biological
Numeric and
Narrative
Chemical
Primary
Assessment
Tool
Biological
criteria
Biological
criteria
Biological
criteria
Biological
criteria
Chemical
Criteria
Second, the 303(d) list of impaired waters would change . Some waters currently listed as
impaired could be removed from the list as they would now be supporting their designated
aquatic life use.
Ohio Aquatic Life Uses
One way to think about how tiered aquatic life uses might be used in Illinois is to look at
what other states have done . Ohio is the only USEPA Region V state that has had a several sub-
categories of aquatic life uses in their standards since the mid-1970s (Table 2) .
Table 2 . Summation of Ohio's aquatic life uses.
http://www.epa.state.oh.us/dsw/rules/3745-t.html
As described earlier, there is a difference between sub-categories of waterbody types and
aquatic life use tiers . A sub-category represents lakes versus streams or coldwater streams
versus warmwater streams ; whereas a tiered aquatic life use reflects the distance within a
waterbody type (e.g., warmwater stream) the biological community is from the natural condition .
Ohio, like several other USEPA Region V states, recognizes two types (sub-categories) of
streams : coldwater and warmwater
. Although Ohio's standards have two coldwater
designations (Table 2) they are not really tiers because they don't indicate the distance the
biological communities in those streams are from either a natural or expected condition . Instead
they are based simply on their use by salmonid species (i.e., trout) . In addition to coldwater,
Ohio's Limited Warmwater category is not a true tiered aquatic life use
. Again, there is no
measure to an expected community (i .e., position along the BCG) to place waters into this
category . Ohio is not adding new waters to this category and the standard implies that it will
eventually be phased out by conducting UAAs and redesignating these waters under the tiered
system
. This category appears similar to Illinois Secondary Contact and Indigenous Aquatic Life
use waters .
Ohio's four remaining aquatic life uses categories provide a model for developing tiers in
Illinois EPA - Bureau of Water
TALU Framework
September 2006
6 of 8
Ohio
Standard
Aquatic Life
Use
Description
B-1-c
Exceptional
Warmwater
Comparable to the (=>)75 t percentile of statewide reference sites .
B-1-a
Warmwater
Comparable to the (=>) 25'" percentile of the identified reference sites within
each of ecoregions
B-1-d
Modified
Warmwater
(<=) 25'" percentile of the identified reference sites within each of ecoregions .
Subject to a UAA
B-1-g
Limited
Resource Water
Substantially degraded fauna, Subject to a UAA
B-1-b
Limited
Warmwater
Temporarily designated in the 1978 WQ standards as not meeting warmwater
habitat criteria . Case by case variations in criteria
.
No additions allowed.
B-1-f
Coldwater
(i) waters which support trout stocking and management
(ii) waters capable of supporting populations of native cold water species
B-1-e
Seasonal
Salmonid
Support passage of salmonids from October to May .
Illinois. Each category is based on how similar the biological condition at the sample site is to
the reference biological condition . This similarity is represented numerically via percentiles
(exceptional, warmwater and modified) or as a narrative (limited resource) . As mentioned
above, in Illinois development would be limited to 3 d
through 7th order streams appropriate for
fish and macroinvertebrate IBI scoring . Although the actual break down between the tiers would
be determined after an analysis of the data . Currently, Illinois fish and macroinvertebrate IBIS
can distinguish four or five levels of biological integrity (condition) which can represent up to
five levels aquatic life use attainability tiers . Considering four or five tiered aquatic life uses for
Illinois provides an appropriate starting point . Given the extent of row crop agriculture and
urbanization in some areas of Illinois that have altered natural conditions (i
.e., BCG Tier 1), the
biological conditions represented in BCG Tier 2 or 3 seem to be a reasonable reference condition
(benchmarks) for interpreting and then selecting the appropriate biological criteria for each of
Illinois tiered aquatic life uses (Figure 1) .
Two of Ohio's aquatic life use tiers, Modified and Limited Resource, require a UAA
.
The reason for this is that they are not meeting the interim aquatic life goals of the CWA :
" . . .water quality which provides for the protection and propagation of fish, shellfish and
wildlife . . ." In order to be placed in one of these tiers one of the six reasons listed in 40 CFR
131 .10.g must be met :
I . Naturally occurring pollutant concentrations prevent the attainment of the use
; or
2 . Natural, ephemeral, intermittent or low flow conditions or water levels prevent the attainment of
the use, unless these conditions may be compensated for by the discharge of sufficient volume of
effluent discharges without violating State water conservation requirements to enable uses to be
met; or
3
. Human caused conditions or sources of pollution prevent the attainment of the use and cannot be
remedied or would cause more environmental damage to correct than to leave in place
; or
4. Dams, diversions or other types of hydrologic modifications preclude the attainment of the use,
and it is not feasible to restore the water body to its original condition or to operate such
modification in a way that would result in the attainment of the use ; or
5
. Physical conditions related to the natural features of the water body, such as the lack of a proper
substrate, cover, flow, depth, pools, riffles, and the like, unrelated to water quality, preclude
attainment of aquatic life protection uses ; or
6. Controls more stringent than those required by sections 301(b) and 306 of the Act would result in
substantial and widespread economic and social impact .
According to their standards, Ohio's modified aquatic life use tier is closely linked to physical
habitat modifications (#4) whereas the limited resource aquatic life use relates to #3 for issues
such as acid mine runoff.
Summary
Incorporating biological criteria and tiered aquatic life uses into Illinois water quality
standards can improve both protection of water resources and management decisions
. They will
not make the standards less complicated or solve all the issues in regulating and protecting a
natural system
. However, their adoption would allow the state to utilize direct measures of the
aquatic resources to evaluate improvements to the environment and help set program priorities
for restoration and management .
Illinois EPA - Bureau of Water
TALU Framework
September 2006
7 of 8
Acknowledgements
The following Illinois EPA staff, under the direction of Bureau of Water Chief Marcia Willhite,
have participated in numerous internal discussions regarding the development of biological
criteria and tiered aquatic life uses for potential application in Illinois water quality standards
:
Howard Essig, Bill Ettinger, Gregg Good, Toby Frevert, Mark Joseph, Scott Shasteen, Matt
Short and Roy Smogor
. This paper was compiled by Matt Short to articulate the Bureau of
Water's position.
Literature Cited
USEPA. 2005
. Draft: Use of Biological Information to Better Define Designated Aquatic Life
uses in State and Tribal Water Quality Standards : Tiered Aquatic Life Uses
. Susan K. Jackson
Editor. EPA-822-R-05-001 . USEPA. Office of Water . Washington, DC
Illinois EPA - Bureau of Water
TALU Framework
September 2006
8 of 8
ORIGINAL
RECEIVED
STATE OF ILLINOIS
)
)SS .
.
DEC
2 2 2006
COUNTY OF SANGAMON
)
Pollution
STATE OF
Control
ILLINOISBoard
PROOF OF SERVICE
I, the undersigned, on oath state that I have served the attached Exhibit 39 upon
the person to whom it is directed, by placing it in an envelope addressed to
:
TO: Dorothy Gunn, Clerk
Richard McGill, Hearing Officer
Illinois Pollution Control Board
Illinois Pollution Control Board
James R. Thompson Center
James R. Thompson Center
100 W. Randolph Street 11-500
100 W. Randolph Street, Suite 11-500
Chicago, Illinois 60601
Chicago, Illinois 60601
SEE ATTACHED SERVICE LIST
and mailing it First Class Mail from Springfield, Illinois on December 20, 2006, with
sufficient postage affixed .
0-ry
.m1o -1), (6.1a
SUBSCRIBED AND SWORN TO BEFORE ME
this 20th day of December, 2006
OFFICIAL SEAL
11
BRENDA BOEHNER
NOTARY PUBLIC, STATE OF IWNOIS '
"COMMISSION
. : .. . :.••••f?.p4a9444449a949~
EXPIRES 113.2008
•'
?
THIS FILING IS SUBMITTED ON RECYCELD PAPER
Printing Service List .. . .
Party Name
Role
City & State
Phone/Fax
Metropolitan .
Water
Reclamation
District
100 East Erie Street
Chicago
312/751-6583
Interested Party
IL 60611
312/751-6598
Michael G . Rosenberg, Esq
.
Louis Kollias, Acting Director of Research & Development
Office of theAttorney General
188 West Randolph, 20th
Chicago
312/814-0660
Interested Party
Floor
IL 60601
Matthew 3 . Dunn
Illino'
_
. . .
Re , ndent
. . .
17/78 807
eborah J
. Willi
nme_ntal Protectioa.Agency
1021 North
East
L 62794-
P .O ox 19276
9276
Page 1 of 3
312/814-2347
http://www .ipcb .state .il
.us/coollexternal/easenotifyNew .asp?caseid=6385¬ifytype=Se . . . 12/19/2006
Stefanie N . Diers, Assistant Counsel
Interested
Gardner Carton
Party
& Douglas
Suite
191 N .
3700Wacker
Drive
ChicagoIL
169860606-
312/569/1000312/569-3000
Roy M . Harsch
Brown, Hay __& Stephens LLP
700 First Mercantile Bank
Building
Springfield
IL 62705-
217/544-8491
Interested Party
205 South Fifth St ., P .O .
2459
217/241-3111
Box 2459
Claire A . Manning
Interested
Hodge_Dwyer
PartyZema_n
3150
Post Office
Roland
Box
Avenue5776
Springfield5776IL
62705-
.
217/523-4900217/523-4948
Katherine D . Hodge
City
Interested
of
GenevaParty
22 South First Street
IL
Geneva220360134-
630/232-7494630/232-1494
John Donahue
Illinois Environmental Regulatory,-Group
Springfield
217/523-4942
Interested Party
3150 Roland Avenue
IL 62703
217/523-4948
N . LaDonna Driver
Metropolitan Water Reclamation
District
6001 W . Pershing Rd .
Cicero
Interested Party
IL
411260650-
Bernard Sawyer
Chemical Industry Council of Illinois
2250 E . Devon Avenue
DesPlaines
Interested Party
Suite 239
IL
450960018-
Lisa Frede
Thorn Creek Basin Sanitary District
Chicago
708/754-0525
Interested Party
700 West End Avenue
HeightsIL
60411
708/754-3940
James L
. Daugherty, District Manger
American Water Company
St . Louis
314/996-2348
Interested Party
727 Craig Road
MO 63141 314/997-2451
Tracy Elzemeyer, General Counsel
Hedinger Law Office
Springfield
217/523-2753
Interested Party
2601 South Fifth Street
IL 62703
217/523-4366
Margaret P . Howard
http://www.ipcb.state
.il.us/cool/externallcasenotifyNew
.asp?caseid=6385¬ifytype=Se . . . 12/19/2006
Printing Service List . . . .
Vermilion Coal Company
Glenview
IL 60025
Danville
IL 61834
Kansas City
MO 64112
Chicago
IL 60601
Joliet
IL 60431
Bloomington
Page 2 of 3
847/832-9007
847/832-9010
217/446-0144
217/477-0573
816/983-8000
816/983-9151
312/814-3620
312/814-3669
815-724-4230
Interested Party
1979 Johns Drive
Frederick D . Keady, P.E ., President
Fred L . Hubbard
16 West Madison
Interested Party
P.O
. Box 12
Blackwell Sanders Peper Martin LLP
4801 Main Street
Interested Party
Suite 1000
W .C . Blanton
Illinois Pollution Control Board
100 W . Randolph St .
Interested Party
Suite 11-500
Dorothy M . Gunn, Clerk of the Board
Richard McGill, Hearing Officer
City of Joliet, Department_ of Public Works_
and Utilities
921 E . Washington Street
Interested Party
Dennis L
. Duffield, Director of Public Works and Utilities
Bloomington Normal Water Reclamation_
District
PO Box 3307
IL 61702-
Interested Party
3307
Downers Grove Sanitary District
Downers
Grove
IL 60515
Interested Party
2710 Curtiss Street
Larry Cox
Interested
Fox Metro Water
Party
Reclamation District
682 State Route 31
IL
Oswego60543
Tom Muth
Illinois Department of Natural Resources
Springfield
217/782-1809
Interested Party
One Natural Resources Way 1
1271
62702-
217/524-9640
Stanley Yonkauski
William Richardson, Chief Legal Counsel
Barnes & Thornburg
Interested Party
1 N. Wacker, Suite 4400
ChicagoIL
60606
312/357-1313
Erika K
. Powers
Environmental Law & Policy Center
Interested Party
35 E . Wacker
Chicago
312 795 3707
Suite 1300
IL 60601
Albert Ettinger, Senior Staff Attorney
Friends of the ChicagoRiver
Interested Party
407 S
. Dearborn, Suite
Chicago
312/939-0490
1580
IL 60605
Todd Main, Director of Policy and Planning
Evanston
Interested
Environment
Party
Board
223 Grey Avenue
IL
Evanston60202
Vicky McKinley
Office of Lt
. Governor Pat Quinn
Interested Party
Room 214 State House
IL
Springfield62706
217-782-7884
Marc Miller, Senior Policy Advisor
Michael J . Fischer, Policy Advisor
Ecological Monitoring and Assessment
Interested Party
3206 Maple Leaf Drive
IL
Glenview60025
847-564-9905
Irwin Polls
Printing Service List . . . .
Page 3 of 3
Dr. Thoma5 J
. Muro_h_y
Interested Party
2325 N . Clifton Street
ChicagoIL
60614
Total number of participants : 35
http ://www .ipcb.state.il.us/cool/external/casenotifyNew
.asp?caseid=6385¬ifytype=Se
. . . 12/19/2006
