STATE OF ILLINOIS
)
SS
COUNTY OF SANGAMON
)
BEFORE THE ILLINOIS
POLLUTION CONTROL BOARD
Motion For Expedited Review
CITY OF SPRINGFIELD, ILLINOIS, by its attorneys, hereby moves and requests the
Board pursuant to Section 101
.512 of the Board's regulations to conduct expedited review in this
proceeding, and in support thereof states as follows
:
1 .
On February 9, 2006, Petitioner filed a Petition for Variance with the Board
seeking relief from the Board's dissolved oxygen general use water quality standard, set forth at
35111. Adm. Code 302
.206.
2.
The Board has previously granted similar requests by Petitioner for variances for
the same purpose.
3 .
On February 17, 2006, Petitioner filed a motion to incorporate the records of the
prior Board proceedings granting the similar requested variances
.
4 .
In its petition, the Petitioner also waived hearing contingent upon a positive
recommendation by the Respondent, Illinois Environmental Protection Agency
.
P
S
MAY
3.0
2006
ut o
n
OFControl
ILLINOISgoofy
,
CITY OF SPRINGFIELD, ILLINOIS
)
a municipal corporation
)
Petitioner,
)
PCB No. 2006-137
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
Respondent . )
5 .
On March 16, 2006, the Board issued an order in this matter granting Petitioner's
motion to incorporate and further directing the Petitioner to provide more information on matters
specified in the Order.
6.
In the Order, the Board also advised that pursuant to Board rule 104
.226, any
substantive amendment to the petition recommences the 120-day decision period
.
7.
Petitioner has concurrently with this motion filed an Amendment to Petition for
Variance in response to the aforementioned Board Order in this matter
.
8.
While the drainage area of Lake Springfield has received some precipitation since
February 9, 2006, and Petitioner has been able to pump millions of gallons of water from the
South Fork, the current lake level (558
.50) is still below average for this time of year
. The lake
level has increased by 1
.9 feet since the initial filing of the Petition
.
9.
However, according to the Governor's Illinois Drought Response Task Force, as
reported at its meeting on March 22, 2006, that although March and April may bring above
average precipitation in central Illinois, indicators point to a possibility of a dry summer
.
10.
Given the uncertainty of the severity and duration of the drought conditions since
spring of 2005, should the Board deem the filing of an Amendment to Petition constitutes a
recommencement of the decision period, the Petitioner requests and moves that the Board grant
expedited review to this matter .
2
WHEREFORE, Petitioner respectfully requests that the grant expedited review of the
subject matter of this proceeding .
Jenifer L . Johnson
Corporation Counsel
Municipal Center East
Springfield, Illinois 62757-2393
William A . Murray
Office of Public Utilities
Municipal Center East
Springfield, Illinois 62757-0001
Telephone : 217-789-2116 extension 501
bmurray@cwlp
.com
3
Respectfully submitted
CITY OF SPRINGFIELD, ILLINOIS
a municipal corporation
By:
STATE OF ILLINOIS
)
SS
COUNTY OF SANGAMON
)
BEFORE THE ILLINOIS
POLLUTION CONTROL BOARD
CITY OF SPRINGFIELD, ILLINOIS
)
a municipal corporation
)
Petitioner,
)
PCB No
. 06-137
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
Respondent . )
AMENDMENT TO PETITION FOR VARIANCE
CITY OF SPRINGFIELD, ILLINOIS, by its attorneys, hereby amends its petition to the
Illinois Pollution Control Board (Board) to grant Petitioner a variance from 35 111
. Adm. Code
203.206
of the Board's regulations, and in support thereof states as follows
:
1 .
Petitioner filed its Petition for Variance in this matter on February 9, 2006
.
2 .
On March 16, 2006, the Board issued an Order requesting that the Petitioner
provide additional information to certain matters specified in that Order
.
3 .
Petitioner hereby restates and adopts all statements set forth in its original Petition
including all exhibits thereto
.
4
.
Petitioner hereby provides the following information in response to the Board's
request of said March 16 Order in the same order as the requests were presented by the Board
:
Please provide a map of the locations of the proposed dams and pools that
would be created from those dams
. Please provide a general indication of
the expected perimeter of pool formations on the map
. 35 Ill . Adm . Code
104
.204(b)(1).
RECEIVED
CLERKS MAY 3 0 2006
Pollution
STATE OF
Control
ILLINOIS
Board
Response :
Maps showing the locations of the two proposed dams and the pool
to be created by installation of the dams can be found at Exhibit 9 of Report of
Proceedings in PCB 88-113 in Book II of the Record of Proceedings for that
docket
. By the Board's Order of March 16, 2006, these records were incorporated
into this proceeding
. Petitioner's description of the pool to be created is at
Paragraph 3b of its Petition
. The pool to be created by the dams would essentially
be contained within the existing banks of the Sangamon River and the South Fork
of the Sangamon River for the distances set forth in the Petition
. Where there are
unnamed tributaries to these Rivers or other backwater areas adjacent to the
Rivers in the distances upstream of the pool, the pool would enter these unnamed
tributaries and backwater areas as well
. Modeling required by the Illinois
Department of Natural Resources demonstrated that the installation of the dams
would cause no flood impacts during flood events with the temporary dams in
place
. Attached hereto as Exhibit 12 to the Petition is an additional map depicting
the two rivers and the unnamed tributaries and backwater areas comprising the
pool .
2.
Please provide the proposed locations of dissolved oxygen monitoring
stations that Condition 6 of PCB 00-179 requires both above and below
the proposed dams
. If there is not yet a proposed location, please provide
the kind of evaluation that would be used to determine the location of
dissolved oxygen monitoring . 35 Ill . Adm. Code 104
.204(b)(1).
Response :
Petitioner would propose to monitor dissolved oxygen at locations
100 feet above and below the temporary dam on the Sangamon River and at the
South Fork at a location near Mechanicsburg Road, about one-half mile above the
location of the temporary dam on the South Fork of the Sangamon River
.
3 .
Springfield mentions that a cascade aerator was proposed on the
downstream side of at least one of the temporary dams in the dissolved
oxygen analysis submitted as Exhibit 6 to the 1998 petition
. Is a cascade
aerator considered in the design and cost estimates of this petition for
variance? If not, will Springfield install one if the temporary dams are
constructed? If so, should the installation of the cascade aerator be a
variance condition? 35 Ill. Adm. Code 104
.204(b)(7) .
Response
:
The original design of the temporary dam on the Sangamon River
(1988) provided for a discharge pipe to accommodate the required release rate of
41 cfs which would be installed prior to installation of the dam
. The discharge
pipe would have run from a point above the dam through the north bank of the
River to a discharge point below the dam adjacent to the bank of the River
discharging across rip rap down to the river water level or bed, as the case may
be
. Subsequent to the issuance of the most recent variance in 2000 (PCB No
. 00-
179), the design of the temporary dam was changed when the Petitioner
conducted new hydrologic modeling of the streams with the dam in place
. Due to
2
concern with the required head being adequate for the discharge on the original
design, the discharge pipe is now contemplated as being placed in the base of the
dam, and more likely to be discharging at the channel bed level below the dam
.
The only supplemental aeration that would occur below the dam would be during
periods when the pool exceeded the height of the temporary dam and cascaded on
the rip rap supporting the dam on its downstream side
. The installation of the
cascade aerator should not be a variance condition .
4.
The petition states that "Hanson Engineers was retained on July 5, 2005 to
provide requested updated summary information regarding project
alternatives and additional environmental impacts related to the proposed
village sewer projects."
Pet. At 34-35 . Please provide the Board with the
updated information . 35 III
. Adm. Code 104 .204(c) .
Response :
The updated information to be compiled by Hanson Engineers is
with respect to the Petitioner's long-term supplemental water supply, namely the
Hunter Lake Project and its alternatives
. The endeavor did not produce updated
information with respect to the Emergency Water Supply Plan (including the
emergency diversion of the Sangamon River)
. The following information is
provided regarding the Petitioner's ongoing efforts to secure a long-term
supplemental water supply, unrelated to the Emergency Water Supply Plan
elements, and which water supply would be intended to eliminate the need for the
emergency measures that would utilize the temporary dams on the Sangamon
River and its South Fork .
Sewage issues .
A proposed sewage treatment plan would provide for a sewer
forcemain from the three communities upstream of Hunter Lake (Virden,
Divernon and Pawnee) to be routed to the Springfield Metro Sanitary District,
thereby eliminating the current discharges in the Hunter Lake watershed
.
Evaluation of environmental impacts associated with the joint sewer pipeline will
be included as updates to the Final Environmental Impact Statement (FEIS) for
the Hunter Lake project.
Design changes that affect the Hunter Lake project area footprint or changes in
the project area conditions that may have occurred since the completion of the
FEIS.
A proposed Horse Creek channel re-alignment in Pawnee is the only
design change proposed aside from the sewage issues mentioned above
. The only
new change to project
area conditions is that the Sangamon County Highway
Department has initiated construction on the replacement of the New City Road
Bridge over Horse Creek .
The bridge is being constructed to specifications
suitable to alleviate any impact associated with the possible construction of
Hunter Lake .
Revised costs of Hunter Lake and FEIS alternatives
. Costs for the Hunter Lake
project
and long-term water supply alternatives consistent with the revised
3
demand analysis for a future supplemental supply will be evaluated
. See item 5
below regarding a revised demand analysis
.
5 .
The petition states that technical evaluations of Springfield's long-term
water supply needs were completed in 1957, 1965, 1972, 1980, 1981, and
1986. Pet . at 4
. Has Springfield conducted any technical evaluation of the
long-term water supply needs in the past 20 years? If so, what are the
results? If not, why? 35 Ill
. Adm. Code 104
.204(c) .
Response :
Subsequent to the 1957, 1965, 1972, 1980, 1981 and 1986
evaluations of long-term water supply needs for Springfield, the Petitioner
conducted a water supply evaluation in 1991, which determined that the shortfall
between water demand and yield for a period representing the 100-year drought
condition in the year 2025 was 15
.3 mgd
. This analysis formed the basis of
Springfield's application for construction of Hunter Lake as the City's long-term
supplemental water supply
. This study is discussed in Paragraph 26 of the
original Petition in this proceeding
. In 2005 Springfield re-evaluated yield and
demand and concluded that after implementation of various conservation and
water management strategies, the shortfall in supply would be reduced, but still as
high as 9.2
mgd, indicating that a long-term supplemental supply should still be
pursued.
6.
Please clarify the time frames for completing the temporary lake for the
Sangamon River diversion project and Hunter Lake
. See Pet
. at 4, 9-10,
and 39
. Please include the phases of the projects from initiation of design
to project completion
. 35 Ill . Adm. Code 104
.204(f)(2).
Response
:
The Petitioner estimates that it would take approximately 30 days
to install the temporary dams on the Sangamon River and its South Fork once the
determination was made that it was necessary to activate this element of the
emergency water supply plan
. The Petitioner estimates that if a permit is issued
by the Corps of Engineers for the Hunter Lake project, that it would take a
minimum of five years to complete detailed design, secure project funding,
complete land acquisition, construct the necessary facilities, and fill the new lake
.
7.
Springfield indicates that it has submitted a new permit application to the
Army Corps of Engineers to construct a dam on the Sangamon River that
is required by Springfield's emergency water supply plan
. Pet at 11 .
Please provide a copy of the part of the permit application to which this
variance would apply
. 35 111 . Adm
. Code 104 .204(i).
Response :
There is no particular part of the permit application with the Corps
of Engineers that specifically pertains to the variance requested
. The permit
application is actually a multi-part application that is concurrently reviewed by
the Corps, the Illinois Environmental Protection Agency (IEPA) and the Illinois
Department of Natural Resources (formerly handled by the Illinois Department of
Transportation)
. See Paragraph 4 of the Petition
. Issuance of the variance would
4
enable IEPA to complete its review and issue its water quality certification for the
project
. The Petitioner does note that when the Corps issued its new permit in
2000 one of the permit special conditions was that all conditions listed in the
Board's order in PCB 00-179 were deemed to be a part of the Corps permit
. A
copy of that permit is attached hereto as Exhibit 13
.
8.
Springfield requests the same variance language as is contained in PCB
00-179
. The variance in PCB 00-179 applies to dissolved oxygen in the
Sangamon River.
Please clarify whether Springfield would like the
variance also to apply to the South Fork of the Sangamon River and Sugar
Creek as well
. Also, please indicate whether a distance along each river
should be specified, rather than applying the variance to the entire water
body. 35 Ill . Adm. Code 104
.204(j).
Response :
Petitioner requests that the scope of the variance be applicable to
the pool created by the temporary dams in both the Sangamon River and the
South Fork of the Sangamon River
.
For the Sangamon River this would
constitute the 6 mile pool that would be created on the Sangamon River and the
5
.5 mile pool on the South Fork
. The variance should also apply on the South
Fork below the dam to its confluence with the Sangamon River
. The variance
should apply below the dam on the Sangamon River until the rock and crib dam
which is located at the river mile 73 .07
. Petitioner does not believe it is necessary
to apply the variance to Sugar Creek as this stream is not physically changed, and
its confluence with the South Fork of the Sangamon River is below the dam on
the South Fork
. Note that the dam on the South Fork diverts water from its
normal channel to its high water channel to a confluence with the Sangamon
River.
9.
In condition 2 of the PCB 00-179 variance, please indicate whether
Springfield interprets "normal" to mean "average" as used in Pet
. Exh. 2 .
35 111. Adm. Code 104 .204(j).
Response :
Yes, the Petitioner would equate the term "normal" in Condition 2
of the PCB 00-179 variance with the term "average" as used in Exhibit 2 to its
Petition .
WHEREFORE, Petitioner requests that the Board grant it a variance from 35 Ill
. Adm .
Code 300.026
for the duration of any Corps of Engineers permit for a temporary diversion of the
Sangamon River and the South Fork of the Sangamon River during drought events for which the
Illinois Environmental Protection Agency is required to give certification under the FWPCA
.
5
Petitioner further waives a hearing on this petition in anticipation that the Illinois Environmental
Protection Agency will respond favorably to the variance request
. Alternatively, should said
Agency oppose the variance request, Petitioner would request that the Board schedule a hearing
on this petition.
Respectfully submitted,
CITY OF SPRINGFIELD, ILLINOIS
a municipal corporation
By
Jenifer L. Johnson
Corporation Counsel
3`d Floor; Municipal Center East
Springfield, Illinois 62701
Telephone : 217-789-2323
William A. Murray
Office of Public Utilities
4`h Floor, Municipal Center East
Springfield, Illinois 62757
Telephone
: 217-789-2116 extension 501
bmurray@cwlp .com
6
City of Springfield, Illinois
EMERGENCY WATER
SUPPLY PLAN
Flowoge of Songomon
and Sdatn Fork Rivers
Under Proposed Plan
Exhibit 12
DEPARTMENT OF THE ARMY PERMIT
Permit Number : CEMVR-OD-P-391820
Section
: 10/404
Permittee :
City of Springfield
POC : Thomas Skelly
Department of Public Utilities
Tel : 217-789-2116
800 East Monroe - Municipal Center East
ext 501
Springfield, Illinois 62757
Effective Date :
September 5, 2000
Expiration Date :
June 8, 2005
Issuing Office :
U .S. Army Corps of Engineers, Rock Island District
Clock Tower Building - P.O . Box 2004
Rock Island, Illinois 61204-2004
You are authorized to perform work in accordance with the terms and conditions specified below .
NOTE : The term "you" and its derivatives, as used in this permit, means the permittee or any
future transferee . The term "this office" refers to the appropriate district or division office of the
Corps of Engineers having jurisdiction over the permitted activity or the appropriate official of that
office acting under the authority of the commanding officer.
Project Description : To implement a drought management plan and to divert the Sangamon River
to maintain adequate pool levels in Lake Springfield during periods of low precipitation . The
trigger for implementation of conservation measures is when the pool level reaches elevation 558
during June .
1
. The Sangamon River Emergency Plan includes the installation of temporary diversion
dams at the confluence of the Sangamon River, the South Fork, and Sugar Creek . The
topography of the Sangamon River and South Fork valleys will allow a 250-foot-long temporary
dam to be constructed at Sangamon River mile 85 .24 to impound water in the river channels such
that existing pumping facilities at Lake Springfield could be utilized . A secondary structure
(approximately 100 feet long) blocking the low arm of South Fork River also will be installed .
The top elevation of the structures will be 525 feet msl
. The structures will create a pool
extending approximately 5
.2 miles upstream of the dam on the Sangamon River, approximately
6 miles up the South Fork to the existing pumping facilities near Lake Springfield and 8 miles
farther upstream of the pump station . The depth of the pool at the Sangamon River structure will
be approximately 14 feet . The temporary diversion dams will be constructed of driven steel sheet
pilings . The final design of the diversion structure will include a conduit and valve configuration
that will be of sufficient capacity to maintain a constant downstream release rate of 41 cfs
whenever available in the river
. A second option instead of the pipeline around the north side of
the dam on the Sangamon River is a release pipe placed directly in the river and keyed into the
sheet pile dam
. A crest weir and riprap spillway will be constructed to permit higher river
discharges to be passed at or near river elevation 525 msl, The riprap spillway base will also
serve as a pad for construction equipment from which they can drive the sheet piling
. River
discharge gauging will be provided at the site
.
Exhibit 13
2. The 525 foot elevation will be maintained within the existing Sangamon River basin
and several low floodplain areas
. Existing tributaries and mouths of intermittent streams along
the Sangamon River approximately 5
.2 miles upstream of the dam will experience more water
than otherwise would occur
. In the South Fork, the diverted water will be maintained within the
channel except for one eight-acre stand of timber which will be inundated .
3. Installation of the temporary dams will be triggered by a lake elevation of 557 or less
during . June . Pumping will begin upon completion of the dams subject to available river discharge
quantities . The temporary dams will be removed upon the resumption of normal lake levels
during any given month (see following table) .
4. Minimal clearing will occur at the ends of both dams where the sheet pile is driven into
the banks of the rivers and for access of equipment (approximately 40-foot maximum
circumference around the ends of the dams) . Tree clearing will be avoided where possible .
Project Location : Section 27, Township 16 North, Range 4 West
; 1 .25 miles east of the
unincorporated Village of Clear Lake, Sangamon County, Illinois
; at the confluence of
Sangamon River, South Fork, and Sugar Creek .
in accordance with the plans and drawings attached hereto which are incorporated in and made a
part of this permit .
Drawings No . CEMVR-OD-P-391820 . Sheet 1 of 2, Vicinity Map
Sheet 2 of 2, Site Plan
la
Month
Elevation
Month
Elevation
Month
Elevation
January
558.00
May
559 .73
September
558 .37
February
558.15
June
559 .80
October
558 .86
March
558
.72
July
559 .44
November
557
.81
April
559
.33
August
558.93
December
557
.90
Permit Conditions :
General Conditions :
1 . The time limit for completing the work authorized ends on the date specified on page
1
. If you find that you need more time to complete the authorized activity, submit your request for
a time extension to this office for consideration at least one month before that date is reached .
2
. You must maintain the activity authorized by this permit in good condition and in
conformance with the terms and conditions of this permit
. You are not relieved of this
requirement if you abandon the permitted activity, although you may make a good faith transfer to
a third party, in compliance with General Condition 4 below
. Should you wish to cease to
maintain the authorized activity or should you desire to abandon it without a good faith transfer,
you must obtain a modification of this permit from this office, which may require restoration of the
area.
3. If you discover any previously unknown historic or archaeological remains while
accomplishing the activity authorized by this permit, you must immediately notify this office of
what you have found
. We will initiate the Federal and state coordination required to determine if
the remains warrant a recovery effort or if the site is eligible for listing in the National Register of
Historic Places .
4
. If you sell the property associated with this permit, you must obtain the signature of
the new owner in the space provided and forward a copy of the permit to this office to validate the
transfer of this authorization .
5 . If a conditioned water quality certification has been issued for your project, you must
comply with the conditions specified in the certification as special conditions to this permit
. For
your convenience, a copy of the certification is attached if it contains such conditions . (Condition
is not applicable for Section 10 Permits,)
6
. You must allow representatives from this office to inspect the authorized activity at any
time deemed necessary to ensure that it is being or has been accomplished in accordance with
the terms and conditions of your permit .
Special Conditions
:
1 . The permitee understands and agrees that, if future operations by the United States
require the removal, relocation, or other alteration, of the structure or work herein authorized, or if,
in the opinion of the Secretary of the Army or his authorized representative, said structure or work
shall cause unreasonable obstruction to the free navigation of the navigable waters, the permittee
will be required, upon due notice from the Corps of Engineers, to remove, relocate, or alter the
structural work or obstructions caused thereby, without expense to the United States
. No claim
shall be made against the United States on account
of any such removal or alteration .
2. That the conditions listed in the attached variance granted by the Illinois Pollution
Control Board (PCB 00-179) dated June 8, 2000, are considered to be part
of this permit .
2
Further information :
1 . Congressional Authorities : You have been authorized to undertake the activity
described above pursuant to :
(X ) Section 10 of the Rivers and Harbors Act of 1899 (33 U .S.C . 403) .
(X) Section 404 of the Clean Water Act (33 U .S.C . 1344) .
( ) Section 103 of the Marine Protection, Research and Sanctuaries Act of 1972
(33 U .S .C . 1413) .
2 . Limits of this authorization,
a. This permit does not obviate the need to obtain other Federal, state, or local
authorizations required by law.
b . This permit does not grant any property rights or exclusive privileges .
c. This permit does not authorize any injury to the property or rights of others
.
d
. This permit does not authorize interference with any existing or proposed Federal
project .
3. Limits of Federal Liability
. In issuing this permit, the Federal Government does not
assume any liability for the following :
a
. Damages to the permitted project or uses thereof as a result of other permitted or
unpermitted activities or from natural causes
.
b . Damages to the permitted project or uses thereof as a result of current or future
activities undertaken by or on behalf of the United States in the public interest .
c. Damages to persons, property, or to other permitted or unpermitted activities or
structures caused by the activity authorized by this permit .
d
. Design or construction deficiencies associated with the permitted work .
e
. Damage claims associated with any future modification, suspension, or revocation
of this permit .
4
. Reliance on Applicant's Data
: The determination of this office that issuance of this
permit is not contrary to the public interest was made in reliance on the information you provided
.
5. Reevaluation of Permit Decision
. This office may reevaluate its decision on this
permit at any time the circumstances warrant
. Circumstances that could require a reevaluation
include, but are not limited to, the following :
a
. You fail to comply with the terms and conditions of this permit
.
b . The information provided by you in support of your permit application proves to
have been false, incomplete, or inaccurate (See 4 above) .
3
c. Significant new information surfaces which this office did not consider in reaching
the original public interest decision
.
Such a reevaluation may result in a determination that it is appropriate to use the
suspension, modification, and revocation procedures contained in 33 CFR 325 .7 or enforcement
procedures such as those contained in 33 CFR 326 .4 and 326 .5. The referenced enforcement
procedures provide for the issuance of an administrative order requiring you to comply with the
terms and conditions of your permit and for the initiation of legal action where appropriate. You
will be required to pay for any corrective measures ordered by this office, and if you fail to comply
with such directive, this office may in certain situations (such as those specified in 33 CFR
209 .170) accomplish the corrective measures by contract or otherwise and bill you for the cost .
6
. Extensions . General condition 1 establishes a time limit for the completion of the
activity authorized by this permit . Unless there are circumstances requiring either a prompt
completion of the authorized activity or a reevaluation of the public interest decision, the Corps
will normally give favorable consideration to a request for an extension of this time limit .
Your signature below, as permittee, indicates that you accept and agree to comply with
the terms and conditions of this permit
.
Permittee
/Y!
cr
Date
The issuing officer for this permit is William J . Bayles, Colonel, U .S . Army,
District Engineer, Rock Island District
.
This permit becomes effective when the Federal official, designated to act for the
Secretary of the Army, and in accordance with CEMVR-OD-P appointment order dated
28 March 2000, has signed below
.
Way ne annel
Dare
Project Manager
Regulatory Branch
When the structures or work authorized by this permit are still in existence at the time the
property is transferred, the terms and conditions of this permit will continue to be binding on the
new owner(s) of the property . To validate the transfer of this permit and the associated liabilities
associated with compliance with its terms and conditions, have the transferee sign and date
below .
Transferee
Date
4
STATE OF ILLINOIS
)
COUNTY OF SANGAMON
)
NOTARY
RUTHANN
PUBLIC STATE
LSHEETS
OF
k
MY COMMISSION
EXPI$12I2009
AFFIDAVIT
After first being duly sworn and under oath, the undersign, Thomas M
. Skelly, states as
follows :
1 .
I am the Water Division Manager, Office of Public Utilities, City of Springfield,
Illinois, and I have served in such capacity since July, 1991 .
2.
In such capacity, I am responsible for all activities of the Water Division relating
to source of supply, water purification and distribution of potable water
. I report
directly to the General Manager of the Office of Public Utilities
. I have primary
responsibility for implementation of the City's emergency water supply plan
. I
also am the Project Manager for Hunter Lake
.
3.
From November, 1984, until my appointment as Water Division Manager, I
served as Supervisor of Water Resources and was responsible for development of
certain aspects of the city's emergency water supply plan
. In such capacity, I
participated in the proceedings in PCB 88-113
.
4.
I have read the foregoing Amendment to Petition for Variance and based upon my
best knowledge and belief, the allegations contained herein are true and accurate
.
5 .
If I were called to testify to the same with regard to the Petition before a hearing
of the Illinois Pollution Control Board, my testimony would support the
allegations of said Petition .
Subscribed and sworn to before me this
)5'4'day of
Notary Public
