SchsstzVainly Vim: LW

2446 North County Ri! 1500

Niota, 1162358

Phone 217-755-4459

Fax 217-755-4323

RECEIVED

CLERK’S OFF1C’F

MAY

1

5

2001

STATE OF ILLINOIS

May 11.2001

Pollution Control

Board

Dorothy M. Gunn

Pollution Control Board

James R

Thompson Center

100W.

Randolph, Suite 11-500

Chicago, IL 60601-03286

Dear BoardMembers,

Thank you for the opportunity to addressthe Board regarding new ruis changestoward the building standards for

livestock facilities.

I realize you have a difficultjob

in weighing all the different suggestions that have been

proposed.

As in all cases, a common sense approach always seemsto prevail.

Let me express my appreciation for

your thoughtful deliberations.

I will address those itemsthat I testified to,

as well as some ofthe information that you had asked me to provide.

1)

Regarding the requirement for a construction joint andwaterstop every

50’

of concrete.

In my opinion this

adds costto aproject andmakes for apoorer finished project.

We are going to have more human error in this

requirement while a continuous pour would be cheaper and amuch better and safer concrete surface.

This change

would have less likelihood of abroken seal andleakage. I would ask, where is the evidence that shows this is

necessary?

I think this is just evidence that the MIPS booklet is outdatedin many recommendations.

2)

As for drainage around afarmstead.

I think this is unfair.

Are we going to require that all small Towns and

Municipalities are going to provide the same?

Thereis no

evidence that effluent is contaminating ground water.

If

there is a concern with some waste facility, monitoring wells can detect any problems.

Many drainage outlets in

Illinois

are on relatively fiat ground which would require alift station for the drainage to be put in aholding

lagoon.

This would be very expensive andmost smallto medium livestock farms would discontinue operation

rather than spendthat money.

This would be an unsubstantiated assumption

without any evidence that it is

needed.

3)

There was aproposal to extend the minimum 4” thick

concrete surface to aminimum of 5”.

As I asked at the

hearing and your first concern should be,

WHY?

Is there evidence that we have a problem now?

Whatis the

impact going to be on

producers ifthis is enacted.

I must admit that our new operation will be abit largerthan most construction projects; however, most cannot

afford this additional expense.

In

our project, we estimate464 yards of concrete in each facility at the 4” requirement. Ifwe are to add 1” to the

standard on

each ofthe three,buildings on 5,’floors this would add approximately 116 yards per building or 348

yardstotal.

At an estimated priceof $60.00 per yard ofconcrete and $80 per yard for labor on installation, we

have added $48,720.00 to the cost ofour project.

Ifwe add in the cost requirement of Illinois that we need a 10”wall in our deep pit construction ratherthan on

8”

wall as in other states, we have already added

100 yardsper barn timesthe two deep pits, which equals 200 yards

atthe

$140 estimated construction costs

or atotal additional cost to us of$28,000.00.

Add these two requirements

andwe will haveto spend $76,000.00 in illinois for adeep pit construction over what we can do in other

neighboring

states.

---

Seemsto me, ifyour board agrees that a deep pit structure for holding effluent is safer and more environmentally

friendly over the lagoon system, weshould not be addingunnecessary costs. As I stated in my testimony,

lagoon

systems havebeen engineered to be safeand desirable.

However, the concrete pit system is safer.

Your current

rules andcertainly these new additions will only encourage the lagoon system, because ofeconomical factors.

As I

testified, wewill spend approximately $50,000.00 to $100,000.00 more on our project for a deep pit system over a

lagoon system.

These additional costs will only push us to the lower

costs system or look to other states to expand.

I would encourage that this new standard not be adapted and that someone look at the MIPS plan service to find

other construction requirements that are outdated andunnecessary~

In closing I would hope that you would keep these two ideas alive as you decide new standards.

First, Illinois has

new livestock facility requirements, many too strict in my opinion.

Where is the evidence that stricter

requirements are needed?

Some say that wedo not have studies on old confinement systems.

These systems are

forty years old, in every county in the state, andthereare no problems with them.

We haveproved that theyare

safe because thereare no reports of problems.

There will onlybe isolated problems ifany, becausethe design of

concrete filled with manure, which is an excellent structure sealer on its own, is the safest design for containment.

Secondly, please ask for a studyto look at the MIPS Plan Service booklet that was published over thirtyyears ago.

These should be minimum standards not excessive requirements.

Please

remember most projects, have hired a

licensed engineer.

Their expertise should be honored when approvinga project, not general requirements from a

booklet three decades old.

I would think some weight should be given to an Engineering Firms study of approval.

Once again,

1 thank you for your diligence and considerations in keeping Illinois safeandyet workable.

IfI can

help in anyother regard, please feel free to contactme.