Pra in
RECEIVED
et~
S fATE OF ILLINOIS
Pollution Control Board
Executive Director
Robert J. Moore
Board of Directors
Bruce Hannon
President
Champaign, Illinois
Jon McNussen
Treasurer
Villa Grove, Illinois
Eric Freyfogle
Secretary
Urbana, Illinois
Karen Ennen
Naperville, Illinois
Michael Rosenthal
Clencoe, Illinois
Ken Hartke
Topeka, Illinois
Clark Bullard
Urbana, Illinois
Virginia Scott
Springfield, Illinois
Laurene von Klan
Chicago, Illinois
Charles Goodall
Sidell, Illinois
809 South Fifth Street
Champaign, IL 61820
217-344-2371
Fax 217-344-2381
Ms. Dorothy Gunn
Clerk
of the Board
Illinois Pollution Control Board
100 W. Randolph St., Suite 11-500
Chicago, Illinois 61601
March 19, 2001
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~//7/~
To the Illinois Pollution Control Board:
We the undersigned organizations urge you to adopt antidegradation rules which
accomplish the
following:
1. Guarantees the protection of all existing uses of Illinois’ waters including
swimming, fishing, paddling, drinking water, and the preservation of aquatic
species,
including threatened or endangered species.
2. Maintain water quality in high quality waters and those waters that are
currently better than the minimum water
quality standards for the state of
Illinois.
3. Provide for a fair process for designating streams of exceptional recreational
and ecological significance as ‘‘Outstanding Resource Waters.
In order to accomplish these goals we request that the Illinois Pollution Control
Board adopt the following principles.
First, we suggest that the Board not adopt a de minimis provision or a significance
test as part
of Illinois’ antidegradation policy. A de minimis provision and a
significance test would allow arbitrary levels ofpollution to be released to our
waters without undergoing an adequate review to determine if existing uses would
be harmed or if water quality would be unnecessarily degraded.
Second, we urge the board to remove the exception from antidegradation review
of activities covered under a General NPDES permit. Just because an activity is
covered under a General NPDES permit, rather than a site-specific NPDES
permit,
does not mean it will not cause degradation. At a minimum we request
that board not allow general permits to be issued in waters that are known to
contain rare
species or species that are intolerant of pollution.
Third, we ask that the board not adopt any additional exceptions to
antidegradation review. The exceptions described in the Agency’s original
proposal
(excluding the one from general permits) are adequate and cover a broad
range
of activities for which an antidegradation review would be duplicative.
Protecting Illinois’ Streams
printed on recycled paper
Additional exceptions proposed by the regulated community are not consistent with the
concept
ofantidegradation.
Lastly,
we request that the Board adopt procedures for the designation of Outstanding
Resource Waters that are not overly burdensome. The proposed rules create a process
which we believe would exclude any organizations such as ours from ever bringing a
petition before the
Board. We request that the socioeconomic analysis be much more
limited in scope and only require a simple statement on the potential impacts to the local
economy. We also request that the list of recipients ofthe full petition be restricted to the
Board,
Illinois EPA, and Illinois DNR, with a reasonable notification list possibly
included to cover other potentially interested parties.
We applaud the
efforts to date of the Board and the Illinois EPA to create the proposal
which is now under your consideration. A strong antidegradation policy is an essential
piece to Illinois’ clean water program and one which has been largely missing for far too
long.
Thank
you for the opportunity to provide input on the important matter.
Sincerely
~:
aIbOZ
‘L~
Executive Director
Prairie
Rivers Network
Other groups also signing on to this letter:
Kathy Andria
American Bottoms Conservancy
and
348 R Collinsville Ave.
East St. Louis, IL 62201
Tom Wall, President
Better Fishing Association of Northern
Illinois
1212 Peoria Street
Peru, IL
61354
-
Dennis Lubbs and Kathy’Lubbs, Co-chairs
Bureau County Natural Area Guardians
29541 1250 East
Street
Walnut, IL 61376-9801
Dan Faust, Chairman
Central Illinois Chapter of the Illinois
Paddling Council
17 Oakwood Drive
Pontiac, IL 61764
Erik Sprenner, Regulatory Affairs Chairman
Chicago Whitewater Association
633
N. Genesee St.
Waukegan, IL 60085
Phyllis Oliver, President
Citizens Committee To Save Cache River
360 Walker Drive
Vienna, IL 62995
Jan King, President
Citizens Organizing Project
1776 Knox Highway 11
Gillison, IL 61436
Gary Mechanic, Chairman
Des Plaines River Alliance
4905
N. Hanilin
Chicago, IL 60625
Karen Hudson, President
Families Against Rural Messes
(F.A.R.M.)
P.O. Box 615
Elmwood, IL 61529
Sam Steams, Public Education Coordinator
Friends Of Bell Smith Springs
RR 1, Box
154
Stonefort, IL 62987
Nick Nikola
Friends Of Critters And Salt Creek
114 Essex Road
Elk Grove Village, IL 60007
Robert Vogl, President
Friends Of The Rock River
1230
E.
Honey Creek Road
Oregon, IL 61061
Marianne Nelson
Friends Of Tyler Creek
316 RiverBluffRd
-
Elgin, IL 60120
Mark Donham,
Forest Watch Coordinator
Heartwood
RR# l,Box 308
Brookport, IL 62910
Ken Konsis, President
Illinois Association of Conservation
Districts
2296-A Henning Road
Danville, IL 61834
Marilyn
Campbell
Illinois Audubon Society
425B N. Gilbert
P.O.Box 2418
Danville, IL 61834-2418
Lynne Padovan, Executive Director
Illinois
Environmental Council
319W. Cook
Springfield, IL 62704
Kevin Bradley, President
Illinois Paddling Council
610 Randi Lane
Hoffman Estates, IL 60194
Brian Metcalf, Environmental Associate
Illinois Public Interest Research Group
(IL PIRG)
180 West Washington
Suite 500
Chicago, IL 60602
Dr. Bob Williams
Illinois Rivers Project
Southern Illinois University
Box 2222
Edwardsville, IL 62026
Randy Vogel, Executive Director
Illinois Stewardship Alliance
POB 648
Rochester, IL 62563
Laura Huth, Executive Director
Illinois Student Environmental Network
110 5. Race, Suite 205
Urbana, IL 61801
Don Langford, Commodore
Lincoln Park Boat Club
1936 N. Clark St., #10
Chicago, IL 60614
DeAnna Belz
Living Upstream, Bloomington Chapter
Rt. I Box 166
Towanda,IL 61776
George Burner, President
Mackinaw Canoe Club Of Central Illinois
257 E. Washington St.
East Peoria, IL 61611
Kathy Andria
Madison County Conservation Alliance
348
R Collinsville Ave.
East
St. Louis, IL 62201
Richard H. Acker, Regional Land Use
Coordinator
Openlands Project
25
E. Washington St., Suite 1650
Chicago, Illinois 60602
Kristi Hanson
Regional Association Of Concerned
Environmentalist
(RACE)
Rt. 1 Box
308
Brookport, IL 62910
Jeff Swano, Executive Director
Salt Creek Watershed Network
8738 Washington Ave.
Brookfield, IL 60513
Brook McDonald, Executive Director
The Conservation Foundation
10 5. 404 Knock Knowles Road
Naperville, IL 60565
Jacquelyn Dobrinska, Project Manager
The Wetlands Initiative
53
W. Jackson Blvd.
#1015
Chicago, IL 60604-3703
Ed
Michael, Conservation and Fishery
Development Chair
Trout Unlimited, Illinois Council
223
Barberry Road
Highland Park, IL 60035
