~I

~

P.O. Box 648

•

Rochester,

IL 62563

Phone (217) 498-9707

•

Fax

(217) 498-9235

E-mail: isa@iUinoisstewardshipalliance.org

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2

0

2003

EOF

II Hnois

Stewardship AIIra~e

COnI~N~d

Ms. Marie E. Tipsord

Hearing Officer, Illinois Pollution Control Board

100W. Randolph St.,

Suite 11-500

Chicago, Illinois

60601

Re: Public Comment on R03-19

Dear Ms. Tipsord:

The Illinois Stewardship Alliance is a 29-year old citizen’s organization that promotes a safe and

nutritious food system, family farming and healthy communities by advocating diverse, humane,

socially just and ecologically sustainable production and marketing practices.

ISA is heartened that the ICPB is considering changes to the NPDES

permitting process that will

provide

for

greater

public

participation

and

input.

We

work

with

Confined

Animal

Feeding

Operation permitting,

and

have

seen

first

hand

how the

citizens

and

taxpayers of Illinois

can

“lose” their voices when public participation is

limited because of the control of the process by

livestock integrators.

It

is

very

important

for

citizens

to

have

a

fair

opportunity

to

comment

on

all

aspects

of

a

proposed NPDES

permit.

The Clean Water Act intends NPDES

permit conditions

and

limits to

be

subject to

significant

public

scrutiny,

and

the

Illinois

Environmental

Protection

Act

also

envisions

widespread public

involvement

in permit

development

and

issuance.

For the

CAFO

NPDES permit

currently undergoing revision,

this

was commented on by IEPA during the May

28, 2003 Public Hearing held in Springfield by their legal counsel.

NPDES permits should not be issued without affording an opportunity for public

comment. This

should be true for both General and Individual

Permits.

Moreover, when significant substantive

changes

are

made

to

a

permit

after

the

public

comment

period

is

closed,

an

additional

opportunity for public input should be provided on the revised portions.

In addition, regulations

should ensure the establishment ofa sufficient administrative record to justify a permit.

It is also important for our regulations to

specify that permit limits may not allow discharges that

cause or contribute to

violations of water quality standards,

that limits and conditions

should be

enforceable by

citizens

as well

as by

the

Illinois

Environmental Protection

Agency,

and

that

monitoring

terms

should

be

included

in

the permits.

These revisions

will

help protect

water

quality and ensure Illinois’ compliance with the Clean Water Act.

Sincerely,

Elizabeth Burns, MS

®4~is Stewardship Alliance

June 12, 2003

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