12— 7—04;

4:30pM

;

G3;#

FROM

:

Neighborhood Law Office

PHONE NO.

:

618 271 @835

DEC. @7 2884 @5:18PM P1

CLERK’S

OFFICE

DEC 07 2(J(J~

American Bottom Conservancy

STATE

OF

ILLINOIS

914

North

7th

st., ~

~ ~

~

Hution Con rol Board

(618) 875-9960,

Faz(618) 271-0835

December

6,

2004

illinoIs Pollution Control

Board

600

S. Second Street, Suite

402

Springfield,

1L 62704

via Fax

312-814-3669

Re: R2004-026 Interim

Phosphorus Effluent Standard

—~

Dear Chaninan Novak and

Members of the Board:

American Bottom

Conservancy

(ABC) is anot-for-profit

organization working

to protect the resources,

citizens and communities of the American Bottom

floodplain in Southwestern

Illinois.

ABC is a

member

of

the

Illinois Department of

Natural

Resources Ecosystem

Partnership, Conservation

Congress

and

the

Clean Water

Network. Most of

our

area

waters

are impaired-many covered with

green algal

slime-and

are

urgently

in need ofprotection.

We strongly support the proposal ofIllinois Environmental ProtectionAgency

(IEPA)

for an interim

monthly

average phosphorus effluent

limit

of 1.

rnglL for new

or increased

discharges. Not only

is it good

for

water

quality,

but

it is also consistent with

and required

under cunentlaws

andregulations.

The Clean Water

Act

and illinois law require that

NPJES

permits control

pollutants that

may cause or

contribute to

violations

of

water quality

standards and prohibit

allowing

new pollution thathas not been.

shown

to be

necessary.

Therefore, limits on the

discharge

of phosphorus

are

needed to

prevent

violations

of

Illinois waler quality standards

and comply with

anlidegradation requirements.

In

addition, controls

are needed to prevent

violations

ofthe water

quality standards regarding

offensive, conditions, pH

and

dissolved

oxygen.

The Agency’s proposal is

limited

to new or increased

discharges.

Such discharges

are

already subject to

antidegradation regulations, tinder the anlidegradation regulations. lowering ofwater quality should only

be allowed if it can be demonstrated

through a

consideration of alternatives

and

economic analysis that it

is necessazy to

accommodate miportant

economic or social

tleveloprnent

Not

only

is JEPA’s proposal good for water quality, it is

readily

achiciiable, as demonstrated by the

longstanding and successfiul

phosphorus limit oil

mgIL established

In the 197(Ys

for

any discharges to

streams

that

flow to the Oreat Lakes. We

urge

you to adopt IEPA’s proposed

interim

discharge standard

for phosphorus of I

mg/L.

Thank you for your consideration of

our comments

Sincerely,

Kathy

Andria

President

.