Dorothy Gunn, Clerk
Illinois Pollution Control Board
James R. Thompson Center
100 W. Randolph Street, Suite 11-500
Chicago, IL 60601
Re:
R 04-25, Proposed Amendments to Dissolved Oxygen Standard 35 Ill. Adm.
Code 302.206
Dear Ms. Gunn,
The Chemical Industry Council of Illinois (“CICI”) would like to register its voice
in support of the amendment to the Board’s regulations which is proposed in this
proceeding. CICI is a statewide trade association representing the chemical industry in
Illinois. CICI has a 196 member companies employing over 54,000 workers in 745
manufacturing facilities and 975 wholesale and distribution facilities in Illinois.
CICI has reviewed the testimony of all parties involved in this proposed
rulemaking and believe that the data presented on behalf of the Illinois Association of
Wastewater Agency’s (IAWA) testimony represents sound science which supports the
petition and a proposed set of standards which are attainable. The IAWA petition
proposed to establish a seasonal dissolved oxygen standard that is protective of the early
live stages of fish, aquatic insects and benthic organisms and establishes a minimum
standard that is more stringent than that suggested by the U.S. Environmental Protection
Agency in its National Criteria Document.
CICI has also reviewed the testimony of the Illinois Department of Natural
Resources and Illinois Environmental Protection Agency. CICI does not believe that
these agencies have provided the scientific evidence to support their proposed
modifications of the IAWA petition. CICI opposes the establishment of river segments
that would be subject to an even more stringent standard without the scientific basis to
support the agencies’ recommendation.
It is therefore that CICI supports the Illinois Association of Wastewater Agency
(IAWA) petition designated R04-25.
Respectfully submitted,
Lisa Frede
Director of Regulatory Affairs
Chemical Industry Council of Illinois
Headquarters
2250 E. Devon Ave., Suite 239, Des Plaines, IL 60018
•
Tel: (847) 544-5995
•
Fax: (847) 544-5999
Springfield
400 W. Monroe, Suite 205, Springfield, IL 62704
•
Tel: (217) 522-5805
•
Fax: (217) 522-5815
Website
: www.cicil.net
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, DECEMBER 19, 2006
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