RECEIVED
    CLERK’S OFFICE
    DEC 1420114
    STATE OF ILLINOIS
    Pollution Control Board
    STATE OF
    ILLINOIS
    Office of
    Lieutenant
    Governor
    Pat
    Quinn
    James R. Thompson Center, 15~Floor~Chicago, IL 60601 312-814-5220
    State Capitol, 2~dFloor, Springfield, IL 62706 217-782-7884
    December 7, 2004
    Hearing Officer John Knittle
    Illinois Pollution Control Board
    James R. Thompson Center
    100 West Randolph Street
    Suite 11-500
    Chicago, IL 60601
    RE: In the Matter of Interim Phosphorus Effluent Standard, Case #2004-026
    Dear Mr. Hearing Officer:
    I write to express my support forthe Illinois Environmental Protection Agency’s (IEPA)
    proposed revisions to Subpart A of the State’s General Effluent Standards. The proposed
    revisions present a strong means of improving the public health, environment, and economy of
    Illinois by reducing the serious problem of phosphorus contamination in our rivers, streams and
    lakes.
    The Illinois EPA has identified excessive nutrient pollution as one of the top causes of
    water quality impairment in our state. Overabundance of the nutrient phosphorus, in particular,
    has led to excess algae growth, eutrophication and dissolved oxygen deficiencies. Excess algae
    makes for green, foul-smelling waterthat, even when filtered, has become a source of numerous
    drinking water complaints.
    Phosphorus contamination has also contributed to poor habitat forfish and other wildlife
    throughout the state, decreasing fishing and boating, lowering lakeshore property values and
    diminishing our water’s potential as an economic and recreational resource.
    •
    Current state water quality standards limit the phosphorus content to I mg/I for all
    discharges to lakes. Though beneficial in their own right, these standards need extension to all
    surface waters if we are to effectively preserve the quality of our drinking water and the vitality of
    our rivers and streams.
    The Illinois EPA has proposed interim phosphorus standards that would limit the
    phosphorus content to I mg/I for discharges from new or expanded water treatment works to all
    general use waters, including rivers, streams and lakes. By setting an interim limit while working
    on the scientific details to extend phosphorus limits to all waters, Illinois will take a strong step
    toward improving the public health, environment, and economy.
    I would like to commend the Metropolitan Water Reclamation District of Greater Chicago
    foroutlining in this proceeding a number of inventive methods for decreasing phosphorus
    contamination, including the creation of a water quality trading program that utilizes the nutrient
    reduction capabilities of wetlands, as well as restrictions on the sale of commercial products that
    contain high levels of bio-available phosphorus.
    These measures will help establish a framework that encourages entrepreneurial,
    market-based means of reducing phosphorus pollution, strengthening the state’s economy while
    improving its public health and environment. However, it is important to have such standards to
    encourage this entrepreneurial approach, yet have the flexibility to allow and encourage measure
    that provide additional benefits in addition to compliance.
    Implementing proposals such as these, in conjunction with IEPA’s suggested
    modifications to existing standards, would give Illinois a diverse, dynamic set of tools with which
    to reduce phosphorus contamination.
    Strict effluent standards alone may not have enough inherent flexibility to effectively
    manage all significant sources of phosphorus contamination. In turn, a more flexible,
    entrepreneurial approach may not be truly effective without the backstop of a uniform effluent
    standard and enforced compliance.
    Therefore, I wish to respecifully recommend the adoption of the Illinois Environmental
    Protection Agency’s suggested revisions to current phosphorus standards. In the future, it may
    be necessary to consider the inclusion of flexible, market-based proposals. Let us take
    • advantage of the diversity of proposals put forth by those with a strong interest in Illinois’ water
    quality to create a flexible, rigorous program for phosphorus reduction that will improve our state’s
    public health, environment, and economy.
    Sincerely,
    •
    Pat Quinn
    Lieutenant Governor

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