1. NOTICE OF FILING
      2. ~!
RECE~VED
CLERK’S OFACE
OCT
12
2OO~
BEFORE THE ILLINOIS POLLUTION CONTROL
BOARD
STATE OF ILLINOIS
PoUutiOfl Contro’ Board
IN THE MATTER OF:
)
)
INTERIM PHOSPHOROUS EFFLUENT
)
STANDARD, PROPOSED 35 ILL.ADM.
)
R04-26
CODE 304.123
(G-K)
)
(Rulemaking-Water)
)
)
NOTICE OF FILING
TO:
SEE ATTACHED
SERVICE LIST
PLEASE
TAKE
NOTICE
that
on
October
12,
2004
the
undersigned
filed
the
Metropolitan
Water
Reclamation
District
of
Greater
Chicago’s
Rebuttal
to
Previously
Filed
Comments
Of Professor
Walter
K.
Dodds
By Richard
Lanyon
And
The
Metropolitan
Water
Reclamation District of Greater Chicago with the Illinois Pollution Control Board.
A copy of the
filing accompanies this notice.
METROPOLITAN WATER RECLAMATION
DISTRICT OF GREATER CHICAGO
~:•U4t~,I
~!
Michael G. Rosenberg, Its Attorney
Metropolitan Water Reclamation
District of Greater Chicago
Michael G. Rosenberg
Ronald M. Hill
100 East Erie Street
Chicago, Illinois
60611
(312) 751-6583
RMH:jp
THIS FILING IS
SUBMITTED ON RECYCLED PAPER
STATE OF LLINOIS
)
)
SS
COUNTY OF COOK
)
CERTIFICATE OF
SERVICE
I,
Judith
A.
Pappalardo, being duly sworn
on oath,
certify that
I caused a copy of the
attached Metropolitan Water Reclamation District of Greater Chicago’s Rebuttal To Previously
Filed Comments Of Professor Walter K. Dodds By Richard Lanyon And The Metropolitan Water
Reclamation District
Of Greater Chicago
to be
served by First
Class
U.
S.
Mail
to
all
parties
shown
on the
attached Service List,
at their addresses shown
on
said Service List,
with proper
postage prepaid,
from
100
E.
Erie Street, Chicago, Illinois,
at or near the hour of 4:00 p.m.,
on
October
12, 2004:
TO:
SEE
ATTACHED
SHERVICE
LIST
SUBSCRIBED and SWORN to
before me on October 12, 2004.
____~FIciAL
SEAL”
Notary Public
Notary
Pu~jC~
State of Illinois
My Commission
Exp. 04/10/2006
RMH:jp
THIS FILING IS SUBMIITED ON RECYCLED PAPER
Printing Service List....
Page 1
of 1
Party
Name
Role
City & State
Phone/Fax
IEPA
1021
North Grand Avenue
East
SprIngfield
217/782-5544
Petitioner
P.O.
Box 19276
IL
62794-9276
217/782-9807
Sanjay K.
Sofat, Assistant Counsel
Gardner Carton
& Doucilas
191
N.
Wacker Drive
Chicago
312/569/1000
Interested Party
Suite
3700
IL
60606-1698
312/569-3000
Roy
M.
Harsch
Office of the Attorney General
Environmental
Bureau
Chicago
312/814-2550
Interested Party
100 West
Randolph
Street, 11th
Floor
IL
60601
312/814-2347
Matthew J.
Dunn, Chief
Illinois
Environmental
Regulatory Group
3150 Roland Avenue
Springfield
217/523-4942
Interested Party
IL
62703
217/523-4948
Robert A.
Messina,
General Counsel
Environmental
Law
and
Policy Center
35
East Wacker Drive
Chicago
312/673-6500
Interested Party
Suite 1300
IL
60601
312/795-3730
Albert F. Ettinger
Wilkie
& McMahon
8
East Main Street
Champaign
217/359-2115
Interested Party
IL
61820
217/359-2754
John McMahon
Department of Natural
Resources
One Natural
Resources
Way
Springfield
217/782-1809
Interested Party
IL
62702-1271
217/524-9640
Jonathan
Furr
MWRP~
Chicago
100
E.
Erie
Interested
Party
IL
60611
Richard
Lanyon,
Director of
Research & Development
Aurora
University
Aurora
347 Gladstone Avenue
Interested
Party
IL
60506
David
Horn, Asst.
Prof.,
Biology
___________
Piano
City of
PIano
17
E.
Main Street
Interested
Party
II
60545-1521
Darin Boyer
Total
number of participants:
10
http://www.ipcb.state.il.us/cool/external/casenotifyNew.asp?caseid=6418&notifytype=Service
10/8/2004
CLERK’S OFFICE
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
OCT
122004
IN THE MATTER OF:
)
STATE OF ILLINOIS
P~IJ~ti~~
Control Board
INTERIMPHOSPHORUS EFFLUENT
)
R04-26
STANDARD, PROPOSED 35 ILL. ADM.
)
(Rulemaking-Water)
304.123(G-K)
)
)
)
REBUTTAL TO PREVIOUSLY FILED COMMENTS OF PROFESSOR
WALTER K. DODDS BY RICHARD LANYON AND THE METROPOLITAN
WATER RECLAMATION DISTRICT OF GREATER CHICAGO
My
name
is
Richard
Lanyon.
I
am
currently
employed
by
the
Metropolitan
Water
Reclamation District of Greater Chicago
(“District”)
as
its
Director of Research
&
Development.
The
District
is
a
unit
of
local
government
created
by
the
state
legislature
for
the
purpose
of
collection and disposing of sewerage, reducing pollution of the waterways and preventing flooding.
70 ILCS
2605/1,
et seq.
The District’s
service area is most of Cook County.
In
its
capacity as a
water reclamation district,
the District operates
seven treatment facilities in its
service area,
serves
five million residents andtreats an average of 1.4 billion gallons of sewage daily.
I
have
been
the
District’s
Director
of
R&D
since
1999.
As
Director
of
Research
&
Development, I supervise the District’s Research & Development Department, which has a staffof
340.
Prior
to
becoming
Director of Research
&
Development,
I
was
the
Assistant
Director of
Research & Development.
I held this position from
1975 until
1999.
I have been employed by the
District since
1963.
I am submitting this statement
as a rebuttal to the September
8, 2004,
comments of Professor
Walter K. Dodds which supported the subject Illinois Environmental Protection Agency (“Agency”)
proposal.
On Page 1, paragraph 2 of Professor Dodds’
comments he states that nutrient “problems are
common
in
lakes
above
approximately
0.03
mg/l
total
phosphorus and
0.4
mg/i
total
nitrogen.”
On Page 2, first full paragraph of Professor Dodds’
comments he states that
1.0 mg/I effluent limits
have “been attained in many
areas draining into the Great
Lakes.”
Nowhere in his comments does
Professor Dodds discuss appropriate phosphorus concentrations for Illinois rivers, which is what the
Agency proposal is
dealing with.
On Page
1, paragraph 2 Professor Dodds cites an article by Smith et al. (2003).
This article
discusses methods for estimating what nutrient concentrations in U.
S. rivers and lakes were prior to
the arrival of European settlers.
It is unclear as to whether Professor Dodds has advocated this as a
goal for the Agency to work towards.
Based upon Professor Dodds’ comments, it appears as
though Professor Dodds, who resides
in Kansas, may not be fully apprised as to the environmental
issues in Illinois or the specifics of the
Agency’s
proposal
in
this
rulemaking.
The
majority
of
Professor
Dodds’
comments
relate
to
appropriate phosphorus levels for lakes
that is
irrelevant to
the
Agency proposal.
His
comments
also suggest that he believes that Illinois’ Publicly Owned
Treatment Works discharge
to the Great
Lakes,
which is
not the case.
For these reasons, we respectfully recommend that the
Board either
disregard Professor Dodds’
comments, or in the alternative, give them little weight.
Metropolitan Water Reclamation District
ofGreater Chicago,
By:
~
Richard Lanyon, Dir#r
of R&D
October~z~-,
2004
Metropolitan Water Reclamation
District of Greater Chicago
100 East Erie
Chicago, Illinois 60611
312.751.5190
THIS FILING IS
SUBMITTED ON RECYCLED PAPER
2

Back to top