STATE OF ILLINOISPollution Control Board

•     12—16—04; 4:17PM                                

7736319934

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FROM

COURSEY&RSSOC.

FAX NO.

7736319934

Dec. ~

CL~PK’~OFFICE

DEC 16 2004

STATE OF

ILLINOIS

Pollution Control Board

Illinois

Pollution

control Board

November

29,

2004

600 S. Second Street, Suitc 402

Springfield, IL 62704

c1’1

Dear Sir or Madam:

The illinois Council of Trout Unlimited (TU) represents approximately 3,000 Trout

Unlimited members who reside in Illinois. Nationally TU enjoys 130,000 members who

join in the TI mission ofconserving, protecting and restoring North America’s cold

water fisheries and their watersheds.

A proposal by the illinois EPA now before the Illinois Pollution Control Board would

limit phosphorous levels to 1 mg/L (1 mg ofphosphorous per each liter ofwaler

discharged) in any case where a new or expanding discharge is proposed which would

discharge at least one milliongallons per day. Your adoption ofthis proposal will reduce

algae and bacteria growth that kills fish and other wi’dlife and can turn waters into green

slime that is undesirable for swimming and other uses. The proposal is very modest, but

it represents the first real requirement to reduce phosphorous for discharges to streams in

Illinois. Currently only discharges to lakes and tributaries to lakes have to reduce

phosphorous. Prairie Rivers, The Sierra Club, arid the Environmental law and Policy

Center have been pushing for such a limit for several years and strongly support IEPA”s

proposaL So too does the Illinois Council ofTrout Unlimited.

This proposal is good for water quality and is consistent with, and required under, current

laws and regulations. The Clean Water Act and Illinois law requires that NPDES permits

corjtrQl pollutants that may cause or contribute to violations ofwater quality standards

arid prohibit allowing new pollution that has not been shown to be necessary. Limits on

phosphorous are needed to prevent violations of Illinois water quality standards and

comply with antidegradation requirements Also, controls are needed to prevent

violations ofthe water quality standards regarding offensive conditions, pH and dissolved

oxygen.

We urge you to adopt the EPA proposed interim discharge stëndard for phosphorous of 1

mg/L.

Sincerely,

James W. Coursey

Chairman- Government Affairs Subcommittee

Illinois Council ofTrout Unlimited

6880 N. Wildwood Ave.

Chicago, IL 60646

Cc. Edward L Michael, Chair The Illinois Council ofTrout Unlimited