Executive Committee
Craig Coil
Ann
PresidentCorporation
Dan Drew
The Drew Group
Vice President and Treasurer
Cy Griffith
Burke,
Vice PresidentWaned,
MacKay & Seri PC
.
Bryan Whitehead
PncewaterhouseCoopers
Vice President
Lois Morrison
The
SecretaryNature
Conservancy
Directors
Fred Axley
President Emeritus
Kenneth Arenberg
Kent Brown
Kate Chappell
Chicago Youth Centers
Thomas Corns
Metal Management
Grant Crowley
Crowley's Yacht Yard, Inc
.
Joel Fink
Robert Friedman
James R . King
LaSalle Bank N . A.
Charlie Kubert
Environmental Law & Policy Center
David Solzman
University of Illinois-Chicago
Max West
Willis
David M . Wong
Arthur Wong & Associates
Executive Director
Margaret Frisbie
Technical Advisors
Paul Anderson
Illinois Institute of Technology
Erin Argylan
Indiana University Northwest
James Filippini
Thomas Murphy
DePaul University
John R
. "Jack" Sheaffer
Sheaffer International, Ltd .
A . Dan Tarlock
Chicago-Kent College Law
Past Presidents
Susan Hedman
Mary E . Lambert
Jerome E . Sterling
R . A Pete Wentz
RECEIVED
Friends of the Chicago River
CLERK'S OFFICE„~
APR 2 4 2006
407 SOUTH DEARBORN •
SUITE 1580 • CHICAGO. ILLINOIS 606051119
TEL. (312) 939-0490 • FAX (312) 939 0931 • WWW.CHICAGORIVER .OR G
Pollution
STATE OF
Control
ILLINOISBoard
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF
:
)
)
R04-25
PROPOSED AMENDMENTS TO
DISSOLVED OXYGEN STANDARD 35 ILL .
ADM .CODE
302.206
)
My name is Todd Main and I am the Policy Director for the Friends of the
Chicago River . Friends of the Chicago River is 25 year old nonprofit
organization dedicated to fostering the vitality of the Chicago River for the
human, plant and animal communities within its watershed .
We represent the voices of over 1500 members and hundreds of volunteers who
support our efforts to restore the health of the river
. Friends of the Chicago River,
brings together coalitions, initiates planning solutions, connects people to the
River through public outreach programs, and supports an innovative education
program
. Our priorities are to provide public access to the Chicago River and to
show that the Chicago River can be both ecologically healthy and a catalyst for
community revitalization
.
We wish to thank the Board for the opportunity to submit comments and
participate in this process
. While inconvenient for some, we feel that the citizens
of Illinois are smart enough to understand the issues under consideration and
deserve to have a seat at the table
. We also know that our community is stronger
and the outcome will be better when more people participate .
We are writing to express our support for the Dissolved Oxygen standards
proposed by the IEPA and IDNR
. Since the public meeting last fall we have been
actively participating in the stakeholder meetings, and monitoring the process
. We
are pleased that the outcome has produced a much better regulatory standard for
Illinois that if properly administered
will be more protective of aquatic life
.
I
. We are pleased that the IEPA/IDNR joint proposal recommends the use of a
two tiered standard that recognizes the need for enhanced protection on waters
that require a higher standard to protect aquatic life
. We understand that this is
an interim standard and look forward to working on developing a multi-tiered
approach in the future, so that Illinois may join together with other
Midwestern states that have modernized their regulatory regimes
.
(Rulemaking
- Water)
)
Executive Committee
Craig Con
Ann Corporation
President
Dan Drew
The Drew Group
Vice President and Treasurer
Cy Griffith
Burke . Warren. MacKay & Senitella . PC .
Vce President
Bryan Whitehead
PncewaterhouseCoopers
Vice President
Lois Morrison
The Nature Conservancy
Secretary
Directors
Fred Axley
President Emeritus
Kenneth Arenberg
Kent Brown
Kate Chappell
Chicago Youth Centers
Thomas Cohrs
Metal Management
Grant Crowley
Crowley's Yacht Yard, Inc
.
Joel Fink
Robert Friedman
James R . King
-LaSalle Bank N . A
.
Charlie Kuberl
Environmental Law & Policy Center
David Solzman
University of Illinois-Chicago
Max West
Willis
David M . Wong
Arthur Wong & Associates
Executive Director
Margaret Frisbee
Technical Advisors
Paul Anderson
Illinois Institute of Technology
Erin Argyll
Indiana University Northwest
James Filippini
'homas Murphy
DePaul University
John R . "Jack' Sheafter
;heather International, Ltd .
i . Dan Tarlock
Trcago-Kent College Law
last Presidents
iusan Hedman
tary E Lambert
erome E . Sterling
A Pete Wentz
2.
We agree with the IEPA/IDNR joint recommendation that the higher
protection annual period be extended through the end of July rather than the
IAWA proposed end of June to protect sensitive early life stages of summer
spawning fish .
3 . We applaud the outstanding work of the staff of the both IEPA and IDNR who
clearly worked creatively and thoroughly to come up with a standard that was
both scientifically defensible and protective of aquatic health .
4. We have a one concern that we hope the board will address in its final
decision . The success of this proposed new standard in protecting aquatic life
will to a large degree be determined by the data collection and sampling . We
request that future dissolved oxygen sampling be conducted at a time that will
measure daily minimum levels rather than maximums . Specifically we urge
that sampling be conducted at 12 :00 am or 6 :00 am . When daily variations in
levels of dissolved oxygen can be accurately gauged .
Friends of the Chicago River
April 24, 2006
Friends of the Chicago River
407 S Dearborn, Ste. ] 580
Chicago, Illinois 60605
312.939.0490
Friends of the Chicago River
407 SOUTH DEARBORN • SUITE 1580 • CHICAGO . ILLINOIS 60605-1119
TEL (312) 9390490 • FAX (312) 939-0931
• WWW C HICAGORIVER .ORG
B
Todd Main,
]icy Director
