TESTIMONY BEFORE THE POLLUTION CONTROL
BOARD
OUTSTANDING RESOURCE WATERS (ORWs)

C E !

tiE fl

CLERK’S OFFICE

J1~N

192001

IN THE MATTER OF:

REVISIONS TO ANTIDEGRADATION

RULES. 35 ILL.ADM. CODE 302.105, 303.206,

AND 106.990-106. 995.

)

R01-13

)

STATE

OF ILLINOIS

Polluti0~

Control

Board

NOTICE

FILING

TO:

Ms. Dorothy M. Gunn

Clerk ofthe Board

Illinois Pollution Control Board

James R. Thompson Center

100 West Randolph Street

Suite 11-500

Chicago, Illinois 60601

(PERSONS ON ATTACHED SERVICE LIST)

Marie Tipsord, Esq.

Attorney

Illinois Pollution Control Board

James R. Thompson Center

100 West Randolph Street

Suite 11-500

Chicago, Illinois 60601

PLEASE TAKE NOTICE that I have filed today with the Clerk ofthe Illinois Pollution

Control Board an original and nine copies ofthe TESTIMONY OF DAVID L. THOMAS OF

THE ILLINOIS DEPARTMENT OF NATURAL RESOURCES, ON THE ABOVE

CAPTIONED MATTER, copies ofwhich are herewith served upon you.

January 19, 2001

Stanley Yonkauski, Jr.

Legal Counsel

Illinois Department ofNatural Resources

524

South Second Street, LTP

Springfield, Illinois 62701-1787

(217) 782-1809

Respectfully submitted,

ILLiNOIS DEPARTMENT OF

NATURAL RESOURCES,

By:

One ofIjlA/~orneys

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

TESTIMONY BEFORE THE POLLUTION CONTROL

BOARD

OUTSTANDING RESOURCE WATERS (ORWs)

David L. Thomas, Chief

Illinois Natural History Survey

Champaign, IL

INTRODUCTION

The testimony presentedhere today provides information on streams ofthe state that

could be classified as Outstanding Resource Waters (ORW’s). I will also like to take the

opportunity to express some concerns with the overall process by which waters would be

designated “outstanding water resources” especially with regard to economic

considerations. We also knowthat Illinois has significant and outstanding recreational

waters which can be considered ORW’s. Illinois’ boundary rivers (Mississippi, Ohio and

Wabash Rivers) and streams (Illinois River and its backwaters, and other large rivers and

creeks) provide 27 ofthe total number of fishing days and $1 billion ofthe $3.76

billion statewide fishing economic impact. However, we have not analyzed the data

sufficiently to identify specific recreational streams for inclusion as ORW’s at this time.

The Department applauds the intended purpose ofthis proposed rule to “maintain high

quality waters and to prevent unnecessary deterioration ofwaters ofthe State.” However

I want to express some concerns with the overall process by which waters would be

designated “outstanding water resources” especially with regard to economic

considerations.

These proposed rules require petitions to designate waters or water segments as an

outstanding resource waters (ORW) to include information on the benefits and economic

impacts ofsuch a designation. More specifically, Section 106.994 (d) requires “a

statement supporting the designation including, but not limited to, the health,

environmental, recreational, -aesthetic or economic benefits ofthe designation.”

Subsection (e) requires “a statement identifying the ORW designation’s anticipated

impact on economic and social development.” This is to include the impacts on the

regional economy and regional employment, based on “current verifiable information,”

and “a comparison ofthe health and environmental impacts to the economic impacts of

an ORW designation.” While the proposed rule only requires “statements” on the various

benefits and economic impacts, it will take extensive analysis and access to data not

readily available to the public for such statements to have any meaning.

The economic impact side ofthe ORW designation needs to include at a minimum; cost

figures, changes in income, changes in revenue, changes in employment, impacts on

different economic sectors, and impacts on local government such as infrastructure and

revenue. The prediction offuture economic opportunities is highly subjective, which will

result in challenges to whateverthe results are ofthe economic statements provided by a

petitioner.

An examination ofthe benefits ofan ORW designation would entail site specific studies

and surveys on the value ofdifficult to calculate benefits such as aesthetic,

environmental, recreational, and health. Such studies take significant resources to

complete and even then there can be strong disagreements on the validity ofsuch analysis

in a hearing before the Pollution Control Board. Consequently, this can be a burdensome

process for individuals and organizations that want to petition forORW designation,

requiring extensive technical and legal support for each ORWdesignation petition.

Designation ofan ORW should be based on water quality, biological criteria and

significant recreational resources; adding an economic analysis requirement may make it

impossible to designate an ORW.

The identification ofstreams of “exceptional ecological significance” is based on

extensive biological collections made over many years by the Illinois Natural History

Survey (INHS). A 1992 report listed 132 steams or stream segments as biologically

significant (cited below). Additional streams meeting the criteria for listing as

biologically significant have been identified from data collected since the publication of

the 1992 report. Also some ofthe streams identified in the 1992 report no longer meet

the criteria and will be downgraded. Working from the 1992 list, we added new

information obtained since the publication ofthe report, and identified a subset of45

streams or stream segments ofexceptional ecological significance. Within the list of45

streams or stream segments we have identified 25 that warrant special attention because

theyharbor extant populations ofthreatened and endangered species.

We are not prepared at this time to make the case called for in the proposed rules for

ORW designation ofall 45 streams or stream segments that we have identified with

threatened and endangered species or high quality habitat, we do feel that these streams

deserve some extra protection from the state. Some ofthe T&E species could be

threatened by waters that just meet water quality standards. Based on data related to

changes in the distribution and abundance ofsome ofour state’s threatened and

endangered species, populations are disappearing from our waters. It therefore appears

that ORW designation may be necessary to maintain these populations.

We have identified below four streams that we believe need immediate protection

afforded by designation as ORW’s. These include the Middle Branch North Fork

Vermilion River Drainage, the Middle Fork Vermilion River (which runs through state

land for much ofits length and is Illinois’ only nationally designated wild and scenic

river), Lusk Creek, and Big Creek (both ofwhich are in the Shawnee National Forest).

All four ofthe streams have state endangered species and the Middle Branch North Fork

also has a federally endangered mussel. Based Upon our review, we know ofno current

discharges with NPDES permits in these streams segments.

Below is a more detailed description ofthe four streams we are proposing for immediate

ORW designation plus a list of41 streams or stream segments (culled from the larger list

ofbiologically significant streams and others with high biodiversity) that may warrant

listing as ORW’s in the future.

ILLINOIS STREAMS IN NEED OF PROTECTION

In drafting the present list of streams we drew from two data sets: the Biologically

Significant Streams Report (Page et al. 1992) (a copy ofthis report is attached to this

testimony) and an EPT index, both ofwhich are discussed below.

BiologicallySign~fIcantStreams:

Illinois has over 2700 named streams that make up

more than 26,000 miles ofinland watercourses. In 1992, biologists from the Center for

Biodiversity ofthe Illinois Natural History Survey published a report entitled

Biologically

Sign~flcantillinois Streams: An Evaluation ofthe streams ofillinois basedon Aquatic

Biodiversity

(Page et al. 1992). The objective ofthe study was to identify the state’s most

biologically significant streams so that protection efforts could be concentrated on a

manageable number ofstreams. The report was designed to supplement an earlier and

continuing study to identify high quality streams called the

Biological Stream

Characterization

or BSC. The BSC is a stream-quality index developed by the Illinois

Department ofNatural Resources and Illinois Environmental Protection Agency to

categorize streams based largely upon fish populations, water quality, and selected

aquatic macroinvertebrates.

In the Biologically Significant Streams report, data on freshwater mussel diversity and

threatened and endangered species were used to expand the list of streams identified by

the BSC as those most important to protect and manage-for their outstanding biological

characteristics. Those sites in common or overlapping in the Biologically Significant

Streams study and the BSC rank among the best in Illinois. The specific criteria used to

identify biologically significant streams were:

1. Streams that supported populations of federal or state watch list, threatened or

endangered species ofplants, mussels, crustaceans, or fishes.

2. Streams with high mussel diversity. High diversity mussel streams or stream

segments were defmed as those with more than ten live species or those with a

Shannon-Weaver Diversity index greater than

2.5.

The use ofmussel diversity was

limited to only those streams where we had recent (post-1976) data (Kaskaskia,

Kankakee, Sangamon, Mackinaw, Vermilion, Embarras, Little Wabash, and Wabash

rivers).

One hundred and eight streams that met the above criteria were identified. These streams

plus the 24 streams identified as “A” streams in the BSC classification brought to 132 the

number of biologically significant streams recognized. Data collected since 1993 on the

aquatic fauna ofIllinois indicate that additional streams or stream segments meet the

above criteria or contain exceptional biodiversity. However, we have not yet analyzed

the data in order to identify those streams at this time.

High EPT Streams:

In addition to the biologically significant streams identified in the

1992 report, other streams were considered ofexceptional ecological significance based

on the presence ofspecies, or communities of sensitive aquatic insects. The three orders

of aquatic insects that are most sensitive to environmental degradation are the

Ephemeroptera (mayflies), Plecoptera (stoneflies), and Trichoptera (caddisflies)

—

species

richness ofall at a site has been used as an effective index ofstream health, the EPT

index. Dr. Donald Webb and Dr. R. Edward DeWalt, also ofINHS-CBD, have sampled

throughout the state forEphemeroptera, Plecoptera, and Trichoptera. Streams were

selected on the basis ofhigh EPT species richness (sheer numbers ofspecies) or presence

ofa few exceedingly sensitive or very rare species. These streams are noteworthy in that

they also have high habitat quality. The two, habitat quality and EPT richness, often are

highly correlated.

The INNS / DNR has identified streams which we feel meet the “uniquely high biological

quality” criteria for ORW designation. These streams were selected from the 132

identified in the 1992 report ofPage et al. or added based on new data collected since that

report. Although other streams or segments identified in the 1992 report may meet one or

more ofthe above criteria they were not selected for special mention because habitat

quality may not be high enough to support sensitive species long-term. For example,

some state endangered species still survive in streams that have been severely modified

from channelization and habitat quality may not be sufficient to sustain the populations

over time. Below are the streams or stream segments we have identified ofexceptional

biological significance that

1. Should be considered for ORW designation as part ofthe Board’s current proceedings.

(4 Streams)

2. Those streams that may be future ORW candidates based on the presence of

threatened or endangered species (plants, mussels, crustaceans, or fishes) and high

quality habitat.

(21 Streams)

3. Those streams that may be ORW candidates based on the outstanding habitat and high

diversity (fishes, mussels, crustaceans, or EPT species).

(20 Streams)

The specific criteria used to select each stream in the list below are given in parentheses.

The first four streams on the list are in need ofimmediate ORW designation and the

supporting data for their listing follows. The next 21 streams on the list are those that

have extant populations ofthreatened or endangered species and therefore warrant special

consideration. The remaining 20 streams are those with diverse EPT taxa or an

exceptionally high diversity ofmussels, crustaceans or fishes. The list begins with

streams in the northern part ofIllinois and generally proceeds to the south. Additional

data, from the BSC or other sources, may result in some modifications ofthe list;

however, all ofthese streams remain highly biologically significant and should be

protected from degradation.

STREAMS

PROPOSED FOR

IMMEDIATE

ORW DESIGNATION (4

streams)

Below are the four streams we are proposing for inclusion in Section 303 .206 (list of

Outstanding Resource Waters).

MIDDLE BRANCH

NORTH

FORK VERMILION RWER DRAINAGE

(Federally endangered mussel; state threatened and endangered fishes and

mussels; high mussel diversity)

Based on historical occurrences, the North Fork Vermilion River supported more state

threatened or endangered species than any other stream in Illinois (Illinois Endangered

Species Protection Board. 1993. Highest priority streams/lakes forthe conservation of

aquatic endangered and threatened species in Illinois. Springfield, Illinois. 7 pp.).

Freshwater mussels have been decimated throughout the eastern United States and may

be the most endangered group ofanimals in North America. Records from the Illinois

Natural History Survey indicate that the North Fork Vermilion River drainage historically

supported a diverse mussel fauna of at least 30 species, over a third (12) ofwhich are

currently threatened or endangered. The only remaining Illinois populations ofthe

federally endangered clubshell

(Pleurobema clava)

and the state endangered rainbow

(Villosa iris)

survive in the North Fork. The river also likely supports the last

reproducing populations ofthe state endangered rabbitsfoot

(Quadrula cylindrica)

and

purple lilliput

(Toxolasma lividus)

in Illinois. Additionally, the state endangered eastern

sand darter

(Ammoctyptapellucida)

and bigeye shiner

(Notropis boops)

occur in the

North Fork.

In terms ofwater quality, the Illinois Environmental Protection Agency (1996) rated the

North Fork Vermilion River as “Full Use Support” and the Biological Streams

Characterization rated the North Fork from the Illinois-Indiana state line to Panther Creek

and from Lake Vermilion to the Vermilion River as a “B” Stream (Highly Valued

Aquatic Resource). The North Fork Vermilion River from Lake Vermilion upstream to

the Illinois State line has been classified a Biologically Significant Stream in Illinois.

The Middle Branch is the largest tributary ofthe North Fork Vermilion River. The

Middle Branch is 17.3 miles (27.8 1cm) in length and drains an area of43 mi2

(57

km2) in

Illinois. A survey ofthe mussel fauna ofthe Middle Branch was conducted in 1996-98.

In that survey 22 ofthe 30 known species from the North Fork drainage were found alive

including one federally endangered, five state endangered and two state threatened

species. Based on comparisons with other Illinois drainages, the Middle Branch supports

one ofthe most diverse mussel faunas in Illinois. Species richness is comparable to other

basins with much larger drainage area. By way ofcomparison the Middle Branch

supports only 4 fewer mussel species than the ENTIRE Illinois River mainstream. With

the exception ofthe entire Vermilion River watershed, the Middle Branch supports more

rare species than any other drainage in Illinois regardless ofsize.

The presence ofthe federally endangered clubshell in the Middle Branch is highly

significant. The clubshell was historically widespread and abundant in the Ohio River

basin ofIllinois, Kentucky, Indiana, Ohio, Michigan, Pennsylvania, Tennessee, and West

Virginia. It has been documented from 94 river systems but currently survives in only 9.

The clubshell was formerly abundant in the Wabash River. However, surveys in 1987,

1988, and 1996 at over 50 sites yielded no live or fresh-dead clubshells and it is believed

to have been extirpated from the mainstream ofthe Wabash River. It is clear that current

water quality standards have not been sufficient in protecting this species from near

extinction. Any lowering ofthe water quality in the Middle Branch from current levels

would likely be detrimental to this species.

The fish fauna ofthe MiddleBranch Vermilion River drainage is also diverse. Forty

species (about 22 ofthe state’s fauna) have been reported from the basin and others

likely occur there. Included among the 40 is the state endangered bigeye shiner and state

threatened eastern sand darter.

B. MIDDLE FORK VERMILION RIVER

From the mouth to Champaign / Ford County line

(Endangered mussels and fishes, high mussel diversity, BSC “A” stream)

The Middle Fork originates in Livingston County, has a substrate ofpredominantly sand

and gravel with some rubble, is 83 miles long, and has a drainage area of 438 square

miles. The Illinois Water Quality Report (IEPA, 1990) rated the Middle Fork Vermilion

River as “Full Support.” The Biological Stream Characterization (Hite and Bertrand,

1989) rated the Middle Fork ofthe Vermilion River from Knights Branch to its mouth as

an “A” stream (Unique Aquatic Resource).

Seventy-four species offishes are known from the Middle Fork Vermilion River

drainage. State endangered fishes include the bigeye chub,

Hybopsis amblops,

bigeye

shiner,

Notropis boops,

and the bluebreast darter,

Etheostoma camurum.

State threatened

species are the eastern sand darter,

Ammocryptapellucidum

and the river redhorse,

Moxostoma carinatum.

Thirty-three species ofmussels have been reported from Middle Fork Vermilion River

drainage. The Middle Fork Vermilion River drainage has historically supported 14

special status species including four state threatened and ten state endangered species.

C. LUSK CREEK

Headwaters to confluence with Flick Creek, Pope County

(Endangered fish crustacean, and plant, High EPT species richness, The

premier stream for EPT in the state ofIllinois, high habitat quality)

Lusk Creek rises near Delwood, drains 88 square miles ofnortheastern Pope County, and

empties into the Ohio River at Golconda. Lusk Creek is 25 miles in length and averages

23 feet wide. The stream has cut through massive sandstone, carving a canyon with cliffs

that vary from only a few feet to nearly 100 feethigh. The creek is shallow in some areas

and flows swiftly around numerous rock and gravelly riffles. In other areas the water is

deep and forms quiet pools. Lusk Creek is one ofthe more aesthetic streams in Illinois.

Inthe Illinois Water Quality Report (IEPA, 1990) rated Lusk Creek as “Full Support.”

The Biological Stream Characterization rated Lusk Creek from Little Lusk Creek to

MansonFork as an “A” Stream (Unique Aquatic Resource). Smith (1971) rated Lusk, and

Big creeks as “Excellent” to “Good” with Big Creek and Lusk Creek as the “Outstanding”

streams in southern Illinois

Lusk Creek is a rocky, spring-fed stream traversing wooded uplands. Springs and caves

throughout the system add to the high biological diversity ofthe system and provide

habitats for species unknown elsewhere in Illinois, including the state endangered

amphipod,

Crangonyx anomalus.

The state threatened least brook lamprey,

Lampetra

aepyptera,

is also known from Lusk Creek.

Lusk Creek in Pope has the most diverse species rich fauna ofEphemeroptera,

Plecoptera, and Trichoptera in Illinois. Within this small drainage 20 species of

Ephemeroptera, 23 species ofPlecoptera, and 22 species ofTrichoptera have been

recorded. The diversity ofEPT species in Lusk Creek is exceptional and is about five

time as rich as the average Illinois stream

D. BIG CREEK

Hardin County

(Endangered fish and crayfishes)

Big Creek is a beautiful, clear, rocky, spring-fed stream that flows through limestone

formations ofShawnee Hills in western Hardin County. Big Creek has a drainage area of

43 square miles, a length of20 miles, and an average width of40-60 feet. The stream

enters the Ohio River

0.5

miles below Elizabethtown. Three habitats

predominate—course gravel riffles, shallow slab rock poois with a gravel substrate, and

deeper sand and gravel bottom pools. The water is fed by many springs so it is usually

clear and cool. The clear cool water provides a stream environment suitable for fauna

that is intolerant ofsluggish, silty, warm waters. Big Creek with its hilly scenery and

diverse biota is a near facsimile ofan Appalachian stream. Tributaries have gravel

substrates and large influxes ofspring water. The drainage basin includes forested land,

pastures, and some row crops. Parts ofthe basin are owned by the U.S. Forest Service

and afforded some protection.

The Illinois Water Quality Report (IEPA, 1990) rated Lusk Creek as “Full Support.” The

Biological Stream Characterization rated Big Creek upstream from HogthiefCreek as an

“A” Stream (Unique Aquatic Resource).

Fifty-five species offishes are known from the Big Creek drainage. State listed fishes

include the endangered bigeye shiner,

Notropis boops,

and the state threatened least

brook lamprey,

Lampetra aepyptera.

The state endangered crayfish,

Orconectes kentuckiensis,

exists in three streams in Hardin

County: Big, Hosick, and Peters creeks. The state endangered crayfish

Orconectes

placidus

also occurs in Big Creek and sporadically in the Ohio and Mississippi rivers.

ORW

CANDIDATE STREAMS BASED ON THE PRESENCE

ThREATENED OR ENDANGERED SPECIES (21

streams)

MISSISSIPPI

RIVER AND

SMALL DIRECT TRIBUTARIES

A. Mississippi River

Rock Island County

(Endangered fishes and mussels, high mussel diversity)

B. Miller Creek

Alexander County

(Endangered fish, BSC Class “A” Stream)

ROCK RIVER BASIN

C. Raccoon Creek

Winnebago County

(Endangered fish)

FOX RIVER BASIN

D. Lower Fox River

Morgan Cr. to confluence with the Illinois R., Kendall and LaSalle

counties

(Endangered fishes)

KANKAKEE RIVER BASIN

E. Kankakee River

From Momence to the Des Plaines Wildlife Conservation Area, Will Co.

(Endangered fishes and mussels, high mussel diversity)

VERMILION RIVER BASIN

F. Mud Creek

Livingston County

(Endangered fish)

MACKINAW

RIVER

BASIN

G. Mackinaw River

From Colfax to Tazewell County line

(Endangered fishes and mussels, high mussel diversity)

SANGAMON

RIVER BASIN

H. Sangamon River

From its source to the Piatt/Macon County line

(Endangered mussels, high mussel diversity, high EPT richness and

habitat quality)

I. Salt Creek

Clinton Lake to Kickapoo Creek

(Endangered mussels, high mussel diversity)

KASKASKIA RIVER BASIN

J. Kaskaskia River

Ill. Rt. 16/128 to Howe Creek, Shelby County

(Endangered fish, high mussel diversity)

VERMILION RIVER

BASIN

K. NorthFork Vermilion River

Lake Vermilion upstream to Illinois State line, Vermilion County

(Endangered fishes and mussels, high mussel diversity)

L. Salt Fork Vermilion River

From the Champaign County line to the Middle Fork

(Endangered fishes and mussels, high mussel diversity)

EMBARRAS RIVER BASIN

M. Embarras River

From the Douglas / Coles Co. line south to Cumberland, Co. line

(Endangered fishes and mussels, high mussel diversity, High EPT species

richness and habitat quality, in top 95th percentile forEPT and top 80th

percentile for habitat)

LITTLE

WABASH RIVER BASIN

N. Little Wabash River

Rt. 50 to the mouth, Clay, Edwards, Gallatin, Richland, Wayne, and White

Counties

(Endangered fishes and mussels, high mussel diversity)

WABASH

RIVER AND DIRECT TRIBUTARIES

0. Wabash River

New Harmony, Indiana to the Ohio River, White County

(Federally endangered mussels and endangered fishes)

P. Little Vermilion River

Vermilion County to the state line

(Endangered fishes and mussels, high mussel diversity, EPT richness and

habitat quality in top 90th percentile)

OfflO RIVERAND

DIRECT TRIBUTARIES

Ohio River

Lock and Dam 53 to Mound City, Pulaski County

(Endangered mussels and crayfish, high mussel diversity)

R. Big Grand Pierre Creek

Rt. 146 to Pinhook Creek, Pope County

(Endangered mussel, high mussel diversity)

CACHE RIVER BASIN

S. Cache River

From Big Creek to Karnak, Johnson / Pulaski Counties

(Endangered fish)

T. Horseshoe Lake / Lake Creek

Alexander County

(Endangered fishes, endangered crayfish, high fish diversity)

SALINE RiVER

BASIN

U. Sugar Creek (Saline River Drainage)

2.5 miles above and below Rt. 166, Williamson County

(Endangered fish, endangered crayfish)

3. ORW CANDIDATE STREAMS BASED ON HIGH DIVERSITY FISHES,

MTJSSELS, CRUSTACEANS, OR EPT

TAXA

OR OUTSTANDING HABITAT

(20 streams)

ROCK RIVER BASIN

A. Kishwaukee River.

Boone, McHenry and Winnebago counties

(High mussel diversity, BSC “A” stream)

B. Sugar River

Wisconsin state line to confi. with Pecatonica River, Winnebago County

(High EPT species richness, high habitat quality)

C. South BranchKinnikinnick Creek

Caledonia Rd downstream to I-90/US-51 overpass, Boone/Winnebago

Cos.

(High EPT species richness and habitat quality 85th percentile)

FOX RIVER BASIN

D. North BranchNippersink Creek

From Wisconsin border to Nippersink Creek

(High mussel diversity)

E. Tyler Creek

Upstream ofRandall Rd. to Big Timber Road, Kane County

(High EPT species richness and habitat quality in the top 85th percentile)

F. Ferson Creek

Two kilometers W Randall Rd to 200 m downstream of same, Kane

County

(High EPT species richness and habitat quality, in top 85th percentile)

DES PLAINES RIVERBASIN

G. Jackson Creek (Kankakee River Drainage)

Entire reach within Midewin National Tallgrass Prairie, Will County

(EPT species richness and habitat quality scores in the top 90th percentile)

MACKINAW

RIVER BASIN

H. Panther Creek

Rt. 24 to the confluence with Mackinaw River, Woodford County

(high mussel diversity)

SANGAMON RIVER BASIN

I. Sugar Creek (Sangamon River Drainage)

McLeanlLogan County line to Ill. Rt. 121

(High mussel diversity, High EPT species richness, habitat quality, and

HilsenhoffBiotic index scores all in top 90th percentile for streams in

Illinois)

J. Lone Tree Creek

Clinton Lake to Kickapoo Creek

(high mussel diversity)

VERMILION RIVER BASIN

K. Jordan Creek

Vermilion County

(Endangered fish)

L. Stony Creek

Vermilion County

(Endangered mussel and amphibian)

OfflO OR MISSISSIPPI RIVER TRIBUTARIES

M. Bay Creek

From the headwaters to Ill. Rt. 147, Pope County

(High EPT species richness, habitat quality in 99th percentile).

N. Clifty Creek

Upstream of Old Metropolis Road, Johnson County

(High EPT species richness and habitat quality)

Hutchins Creek (Clear Creek Drainage)

Headwaters to confluence with Clear Creek, Union County

(High EPT species richness)

P. Simmons Creek

Headwaters to confluence with Big Grand Pierre Creek, Pope County

(High EPT species richness and habitat quality)

SALINE

RIVER BASIN

Q. Little Saline River

Pope/Johnson County line to Saline/Pope County line.

(High EPT species richness and habitat quality)

R. Burden Branch

Headwaters to confluence with Little Saline River, Pope County

(High EPT species richness and habitat quality)

S. Battle Ford Creek

Headwaters to Shawnee National Forest Boundary, Pope and Saline Cos.

(Presence of rare and environmentally sensitive stonefly species)

CACHE RIVER BASIN

T. LickCreek

Headwaters to 1-57 overpass, Union County

(High EPT species richness and habitat quality)

This concludes my testimony.

CERTiFICATE OF SERVICE

I Stanley Yonkauski, Jr., the undersigned, certify that I have served a copy ofthe attached

TESTIMONY OF DAVID L. THOMAS OF THE ILLINOIS DEPARTMENT OF NATURAL

RESOURCES ,in the matter ofrevisions to antidegradation rules upon:

Ms. Dorothy M. Gunn

Clerk ofthe Board

James R. Thompson Center

100 West Randolph Street

Suite 11-500

Chicago, Illinois 60601

in person

January 19, 2001; and upon

(SEE ATTACHED SERVICE LIST)

by depositing copies ofsaid documents in the United States Mail in Springfield, Illinois

onJanuary 19, 2001.

£~:~~/~41

Stan/ey ~n/onkauski,

4’~-~-~

Jr.

RO1-13

SERVICE LIST

Richard Acker

Openlands Project

25 E. Washington Street, Suite 1650

Chicago, Illinois 60602

Kay Anderson

American Bottoms RWTF

One American Bottoms Road

Sauget, Illinois 62201

Fredric P. Andes

Barnes & Thornburg

2600 Chase Plaza

10 South LaSalle Street

Chicago, Illinois 60603

Karen L. Bernotelt

IL Environmental Regulatory Group

215 East Adams Street

Springfield, Illinois 62701-1199

Chris Bianco

Chemical Industry Council

9801 West Higgins Road, Suite 515

Rosemont, Illinois 60018

Christine Bucko

AAG

188 West Randolph,

20th

Floor

Chicago, Illinois 60601

Bill Compton

Caterpillar, Inc.

100 N. E. Adams Street

Peoria, Illinois 6 1629-3350

Jack Darn

Sierra Club, Illinois Chapter

200 N. Michigan, Suite 505

Chicago, Illinois 60601

Albert Ettinger

Environmental Law & Policy Center

35 E. Wacker Drive, Suite 1300

Chicago, Illinois 60601-2110

Susan M. Franzetti

Sonnenschein Nath & Rosenthal

8000 Sears Tower

233 S. Wacker Drive

Chicago, Illinois 60606

Daniel J. Goodwin

Goodwin Environmental Consultants, Inc.

400 Bruns Lane

Springfield, Illinois 62702

Dorothy Gunn

Clerk, Pollution Control Board

100 W. Randolph, Suite 11-500

Chicago, Illinois 60601

James T. Harrington

Ross & Hardies

150 N. Michigan, Suite 2500

Chicago, Illinois 60601

John M. Heyde

Sidley & Austin

Bank One Plaza

10 South Dearborn Street

Chicago, illinois 60603

Ron Hill

Metropolitan Water Reclamation District

100 EastErie

Chicago, Illinois 60611

Katherine Hodge

Hodge & Dwyer

808 South Second Street

Springfield, Illinois 62704

RO1-13

SERVICE LIST

Richard J. Kissel

Gardner, Carton & Douglas

321 North Clark Street, Suite 3400

Chicago, Illinois 60610

Sharon Neal

CornEd

Unicaom

Law Department

125 South Clark Street

Chicago, Illinois 60603

Jerry Paulson

McHenry County Defenders

804 Reginact

Woodstock, Illinois 60098

Paul Pederson

Nalco Chemical

6216 West

66th

Place

Chicago, Illinois 60638

Irwin Polls

Metropolitan Water Reclamation

Environmental Monitoring

6001 West Pershing Road

Cicero, Illinois 60804-4112

Nancy J. Rich

Katten Muchin Zavis

525 West Monroe Street, Suite 1600

Chicago, Illinois 6066 1-3693

Cindy Skrudkrud

4209 West Solon Road

Richmond, Illinois 60071

Jeffrey Smith

Abbott Labs

1401 N. Sheridan Dept 072N, Bldg P14

North Chicago, Illinois 60064-6239

Marie Tipsord

Attorney, Pollution Control Board

100 West Randolph, Suite 11-500

Chicago, Illinois 60601

Connie Tonsor

IEPA

Division ofLegal Counsel

P.O. Box 19296

Springfield, Illinois 62702

Philip Twomey

Admiral Environmental Services

2025 5. Arlington Heights Rd, Suite 103

Arlington Heights, Illinois 60005

Georgia Viahow

Department ofthe Navy

Naval Training Center

2601 A Paul Jones Street

Great Lakes, Illinois 60088-2845

Jack Welsch

Stateside Associates

2300 Clarendon Blvd., Suite 407

Arlington, Virginia22201

Charles Wesselhoft

Ross & Hardies

150 North Michigan, Suite 2500

Chicago, Illinois 60601