ILLINOIS

POLLUTION CONTROL BOARD

March

28,

1972

In

the

Matter

of

3

IR

71—15

PLN!T

NUTRIENTS

)

Concurring Opinion (by Mr. Currie):

I join the Board’s opinion both because I~agree with its

disposition

of

this

proceeding

and

becausethe opinion contains

valuable

insights

into

these

problems

by

Mr.

Aldrich,

who is

intimately

familiar

with

thia

subject.

I

think

it

important,

however,

to

add

a

few words

clarifying

my

own

view

of

what

we

are doing and why.

The

central

question

before

us,

as

I

see

it,

is

whether

or

not

to

do

something

about

nitrogen

fertilizers.

I

think

the

important

thing

is

that

the

Board

has

found

there

are

violations

of

existing

health—related

water

quality

standards

for

nitrate

nitrogen;

that

agricbltural

runoff

contributes

to

these

violations;

and

that

the

Institute

is

requested

to

propose

an

implementation

plan

for

achieving

compliance.

If

the

Institute’s

study

shows that compliance is not worth the cost, we ask that

a new standard be proposed.

But

as matters

stand

now, a

health-related

standard

is

being

violated,

and we

are

asking

the

Institute

to tell us

what

to do

about

it.

It

should

be

clear

that

in

asking

the

Institute

for

information

we

are

in

no

sense

deciding

today

that

the

use of

fertilizer

should

or

should

not

be

restricted

or

that

treathent

of

runoff

should

or

should

not

be

provided.

We

are

not

deciding

the

merits of the nitrogen controversy today.

If we were we would

not

have

referred

the

matter to the Institute.

With

regard

to

phosphorus,

I

agree

for

the reasons

given

by

Mr. Lawton in In the Matter of Detergent Phosphate Ban, 1R71-lO

(March 14, 1972),

that

there

is

inadequate

proof

of

the

need

for

statewide

controls

since

the

adverse

effect

of

phosphorus

on

flowing

streams,

as

contrasted

with

Impoundments,

has

not

generally

been

demonstrated.

-.

~.

-

C

I, thristan Moffett, Clerk of the Pollution Control Board, certify

that

Mr. Currie filed the above

Concurring

Opinion

this

28th

day

of

March.

n

F

4—136