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    22001
    Ms. Dorothy Gunn
    STATE OF ILLINOIS
    Pollution
    Control Board
    Clerk ofthe Board
    Illinois Pollution Control Board
    100 W. Randolph
    St., Suite 11-500
    Chicago, Illinois 61601
    To the Illinois Pollution Control Board:
    We the undersigned organizations urge you to adopt antidegradation rules which
    accomplish the following:
    1.
    Guarantees the protection ofall existing uses ofIllinois’ watersincluding
    swimming, fishing, paddling, drinking water, and the preservation ofaquatic
    species, including threatened or endangered species.
    2.
    Maintains 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.
    Provides for a fair process for designating streams ofexceptional recreational
    and ecological significance as “OutstandingResource 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 minimus provision or a significance
    test as part ofIllinois’ antidegradation policy. A de minimus 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 was 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 ofpollution.
    Third, we ask that the board not adopt any additional exceptions to antidegradation
    review. The exceptions described in the Agency’soriginal proposal (excluding the
    one from general permits) are adequate and cover a broad range of activities for
    which an antidegradation review would be duplicative. Additional exceptions
    proposed by the regulated community are not consistent with the concept of
    antidegradation.
    Lastly, we request that the Board adopt procedures for the designation of
    Outstanding Resource Waters that are not overly burdensome. The proposed rules
    created a process which we believe would exclude any organizations such as ours
    from everbringing a petitionbefore the Board. We request that the socioeconomic
    analysis be muchmore limited
    in scope and only require a simple statement on the
    potential impacts to the local economy. We also request that the list ofrecipients of
    the full petitionbe 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 ofthe 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 forthe opportunity to provide input on the important matter.
    Sincerely,
    Phyllis Oliver,
    President!
    Citizens Committee to Save
    Cache River

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