ED
    DEC
    13217J4
    STATE OF ILLINOIS
    POIIUtIO~Control Board
    December 6, 2004
    Dorothy Gunn, Clerk
    Illinois Pollution Control Board
    James R. Thompson Center
    100 West Randolph Street
    Suite
    11-500
    Chicago, Illinois 60601
    RE:
    Interim Phosphorus Effluent Standard, Proposed 35111. Adm. Code, 304.123(g-k).
    Docket R04-26
    Illinois Pollution Control Board:
    I am writing to you today on behalf of the North Branch Chicago River Watershed Project
    (NBWP) parthership to support the Interim Phosphorus Effluent Standard (Docket R04-26)
    proposed by the Illinois Environmental Protection Agency. The North Branch of the Chicago••.
    River watershed is a 95square-mile area covering parts of Lake and Cook Counties and 24
    municipalities in northeastern Illinois. The NBWP is a voluntary, collaborative partnership
    involving 200+ members from non-profit organizations; municipalities; county, state and federal
    agencies; corporate and private landowners; drainage districts; and local residents. As a
    partnership, we are working to integrate multi-objective watershed management in land use
    planning and development activities.
    As you know, the Illinois EPA’s proposed standard would limit phosphorus levels to I mg/L in
    any new or expanded discharge of one million gallons per day or more. The reduction in
    phosphorous loading to Illinois’ streams resulting from the standard will reduce algae and
    bacteria growth that kills fish and other wildlife. Phosphorous controls are also needed to
    prevent violations of water quality standards that can result from excess phosphorous loading
    such as offensive and nuisance conditions, pH and low dissolved oxygen.
    The West Fork, Middle Fork and mainstem of the North Branch~ChicagoRiver are currently
    nonsupporting of their designated uses due, in part, to low dissolved oxygen conditions. One
    goal of the NBWP is to improve water quality so that the river is a class B stream
    (corresponding to a highly valued aquatic resource). The NBWP agrees that the proposed
    standard is good for water quality, is consistent with the requirements of current laws and
    regulations and will help the NBWP meet the goaI~of our comprehensive watershed-plan. This
    standard is aI~oimportant to the North Br~nchWatershed Project to help us reach our
    watershed objective of Water quality improvement in the ~iver.Therefore, at its November
    8th
    meeting, the NBWP expressed its full support for the IEPA’s proposed interim monthly average
    phosphorus effluent limit.
    The Federal Clean Water Act and Illinois law both require that NPDES permits control pollutants
    ~
    use or contribute to violations of water quality standards. To prevent violations of
    Illinois water quality standards and to comply with the antidegradation requirements to which
    new and expanded discharges are already subject, Illinois needs phosphorous discharge limits
    Under the antidegradation regulations, low~ringof water quality should only be allowed if after
    considenng alternatives and completing an economic analysis, the project is deemed necessary
    to accommodate important economic or social developments
    Perhaps most importantly, IEPA’s proposal is not only good for water quality, but it is also
    achievable. The potential for success has been demonstrated by the successful implementation
    of phosphorous limits of I mg/L established in the 1970’s for discharges to streams that flow to
    the Great Lakes. For all of the reasons stated above, the North Branch Watershed Project and
    its partners strongly urge the Pollution Control Board to adopt the IEPA’s proposed interim
    discharge standard for phosphorous of I mg/L.
    Sincerely,
    Sean S. Wiedel
    Watershed Planner
    Lake County Stormwater Management Commission
    L

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