RECEIVED
1. STATE OF ILLINOISPollution Control Boarc~

RECEIVED

December

10,

2004

CLERK’S OFFICE

Dorothy Gunn, Clerk

illinOis Pollution Control Board

James R. Thompson Center

100 West Randolph Street

• Suite 11-500

Chicago, Illinois 60601

RE:

Adm.

DEC 13 2004

STATE OF ILLINOIS

Pollution Control Boarc~

R2004-26, Interim Phosphorus Effluent Standard, Proposed

Ill.

Code 304.123 (g-k)

Dear Illinois Pollution Control Board:

The MeHenry County Defenders, a 34 year-old county-based not-for-profit

corporation dedicated to the preservation and improvement ofth~environment,

supports the Illinois EPA’s proposal to establish an interim phosphorus effluent

standard. Our organization has over 1,100 members, most ofwho live in

McHenryCounty. We suppott the interim standard because it is needed to

mamtain the quality ofthe many high quality streams and nvers found in

McHe~yCounty.,,...

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McHenry County is blessed with an abundance ofhigh quality bodies ofwater

including the Class A streams: North Branch ofNippersink Creek, Piscasaw.

Creek, Rush Creek and Kishwaukee River and numerous streams that are rated

as Class B, including Boone Creek, Fox River, and the South Branch ofthe

Kishwaukee River. Our county is also experiencing tremendous population

growth such that many conmiunities are finding the need to expand their

wastewater treatment facilities. Thus, the interim phosphorus effluent standard

of 1 mgIL phosphorus will provide immediate benefit in McHenry County by

limiting’ increases in new phosphorus discharges to numerous streams..

Both the Clean Water Act and Illinois law requirethat the permits issued to

dischargers to our state’s water bodies control pollutants that may cause or

contribute to violations ofwater quality standards and prohibit allowing new

pollution that has not been shown to be necessary. The proposed standard’s

requirementthat new and expanding dischargers ofwastewater remove

phosphorus is achievable~Since the 1970’s dischargers.to streams that flow to

the Great, Lakesliavernet

1 rngfL phosphorus liniit., Here, in McHenry::

County, in order to meet Illinois’ antidegradation requirements, the

communities. .ofRichmond, Hebron, Lakewood and McHenry have already

committed to removmg phosphorus from new and expanding wastewater

treatment plants.’..

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Preserve

•

Protect

•

Educate

Citizens working

for

a healthy environment

124 Cass Street

Woodstock, IL 60098

(815) 338-0393

www.mcdef.org

email: mcdef@owc.net

fax: (815) 338-0394

Printed on recycled paper.

The Illinois EPA is In the process ofdeveloping water quality standards fornutrients,

• including phosphorus, and expects to file a petition for the establishment of such

standards in early 2007. The current proposal for a 1 mg/L effluent phosphorus limit wjll

sunset withthe Board’s adoption ofa numeric phosphorus water quality standard. In the

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meantime, this proposal is ‘needed to protect high quality streams like those in McHemy

County from unnecessary phosphorus pollution. Unnatural levels ofphosphorus in

• streams can lead to excessive algal growth causing offensive conditions and creating

periods oflow’dissolved oxygen levels which can be harmful, and even deadly, to fish

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and other aquatic,life.

Thank you forthe opportunity to describe the, benefit which the proposal before you will

have on the aquatic resources ofMcHemy County. The McHenry County Defenders

urges the Board to adopt the interim phosphorus effluent standard of 1 mg/L phosphorus

proposed by the Illinois EPA in Rulemaking 2004-16.

Sincerely,

Lenore Beyer-Clow

Executive Director