BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF:
)
)
PROPOSED AMENDMENTS TO
)
R2004-025
DISSOLVED OXYGEN STANDARD
)
Rulemaking
-
Public Water
35 ILL ADM. CODE 302.206
)
NOTICE OF FILING
TO: See Attached Service List
PLEASE TAKE NOTICE that the Environmental Law and Policy Center of the
Midwest ("ELPC"), Prairie Rivers Network and the Sierra Club today have electronically
filed
Post-Hearing Comments of the Environmental Law
&
Policy Center, Prairie
Rivers Network and Sierra Club
Respectfully submitted,
Albert F. Ettinger
(Reg. No. 3 125045)
Counsel for Environmental Law
&
Policy Center, Prairie Rivers
Network and Sierra Club
DATED: December 20,2006
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BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF:
PROPOSED AMENDMENTS TO
R2004-025
DISSOLVED OXYGEN STANDARD
Rulemaking
-
Public Water
35 ILL ADM. CODE 302.206
Post-Hearing Comments of the Environmental Law
&
Policy Center,
Prairie Rivers Network and Sierra Club
Two years of hearings, studies and informal discussions have shown that the current Illinois
dissolved oxygen
(DO) standard is too simple. The current DO standard of 35 Ill. Adm. Code 302.206,
as applied by the Illinois Environmental Protection Agency (IEPA) in evaluating whether DO
conditions are unhealthful to Illinois aquatic life, produces both false positives
(i.e. it indicates DO
problems where DO levels are healthy) and false negatives (indicates that DO levels are healthy where
they are not).
Adoption by the Board of the proposal made jointly by the IEPA and the Illinois Department of
Natural Resources (the "IEPNIDNR Proposal"), if modified to take into account considerations
regarding saturation levels presented during the hearing by Professor Thomas Murphy, would improve
on the current standard by reducing the number of false positives without necessarily allowing
dangerous conditions.
Adoption of the IEPNIDNR Proposal, even with the improvements suggested by Professor
Murphy, would not reduce the number of false negatives that are created by testing water bodies at sites
or times when DO levels are not likely to be at their lowest. The testimony of numerous witnesses
makes clear that to avoid often drawing the conclusion that a water body has healthy DO levels when it
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does not actually maintain such levels, IEPA will have to follow rigorous monitoring practices and
interpret the standard properly. Further, although the issue is not directly before the Board at this time,
hearing testimony makes clear that proper protection of Illinois aquatic life requires changes to the way
that EPA writes permit limits for discharges of deoxygenating wastes.
Nonetheless, Prairie Rivers Network (PRN), Sierra Club and the Environmental Law and Policy
Center (ELPC) urge the Board to adopt the
EPAIIDNR proposal with refinements regarding cold
water conditions that were suggested by Professor Murphy.
I.
If IEPA interprets and applies the standard properly, adoption of the IEPAIIDNR
Proposal would not dangerously weaken the DO Standard during summer months.
As a practical matter, at issue is how much the Board is going to loosen the Illinois dissolved
oxygen standard. The current DO standard provides that:
Dissolved oxygen shall not be less than 6.0
mg/L during at least 16 hours
of any 24 hour period, nor less than 5.0
mg/l at any time.
The proposal of the Illinois Association of Wastewater Agencies (IAWA) would leave the
standard as it is for March through June. However, for the period of July through February, IAWA
proposes to loosen that standard for all Illinois waters as follows:
During the months of July through February, dissolved oxygen shall not
be less than a one day minimum concentration of 3.5
mg/L, and a seven
day mean minimum of 4.0
mg/L.
(Initial IAWA filing, Doc
#
42201, p. 12).'
1
The IAWA Proposal also has provisions defining averages and providing various monitoring
requirements. However, nothing has been developed in the record as to how these provisions would be
implemented by IEPA and it does not appear that they will be.
2
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The IAWA has stated in testimony that it would accept an additional provision that the thirty (30)
day average may not fall below 5.5
mg/L although IAWA's expert, Dr. James E. Gamey believes it has
little biological support. (Gamey, Nov. 2-3,2006 Tr. 90)
Like the IAWA Proposal, the
EPNIDNR Proposal also will "pare down" the number of water
bodies identified as having
DO problems as explained by IEPA's Toby Frevert. (Frevert, Nov. 2-3,
2006, Tr. 32) The IEPNIDNR Proposal also loosens the standard as to the period of August through
February. As agreed by
IAWA's Dennis Streicher and IEPA, the only element of the IEPNDNR
Proposal that can be said to be tighter than the current standard relates to a small number of water
segments that IEPA and IDNR have determined to be habitat for low oxygen sensitive
species.(Frevert,
Streicher, Nov. 2-3,2006, Tr. 173-4,208-09) It is "theoretically possible" for a water body designated
as
containing low oxygen sensitive species to violate the IEPNIDNR Proposal standard and not the
current standard if the water body violates the 6.25
mg/L seven day average provision during the March
through July period without violating the 6.0
mg/l 16 hour average. (Frevert, Nov. 2-3,2006, Tr. 210)
The significant issues, then, between the IAWA Proposal and the IEPNIDNR Proposal are
i)
whether the current standard should be maintained for all waters during July, and ii) whether the
current standard should be loosened as much as to waters that IEPA and IDNR have identified as
providing habitat for oxygen sensitive species as it is for other waters.
A. The standard should continue to protect July spawning.
EPNIDNR science is based on a lot more data than the IAWA Proposal as to breeding periods
for fish. IEPA and
IDlW looked at species across the state and a broad range of species. (Ex. 23) They
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, DECEMBER 20, 2006
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concluded, as explained by IDNR's Steve Pescitelli, "there's lots of species that spawn after July 1
."
(Pescitelli, Nov. 2-3,2006, Tr. 36)
On the other hand, the IAWA Proposal, a "one size fits all standard" as to the relevant water
bodies, is based almost entirely on studies of fish in southern lllinois supplemented recently by one
study of a backwater lake near
Grafton. (Garvey, Nov. 2-3,2006, Tr. 126) Further, IAWA argues that
most fish complete most of their breeding before July without breaking down the larval periods for
species (Garvey Nov. 2-3,2006, Tr. 177-78) or recognizing that the known late spawn may be
important for species to compensate for high flow periods in spring. (Pescitelli, Nov. 2-3,2006, Tr. 35-
7)
IAWA also implicitly argues through various filings that the Board should loosen the standard
during July because it would make it cheaper for Illinois dischargers to comply with the standard. This
suggestion should be rejected because it is not supported by any economic data. (See Streicher, Aug.
25, 2005, Tr. 61) Indeed, for this argument to make sense there must be a number of dischargers that
would face substantial costs to meet the current standard in July that they would not incur if they only
had to meet the current standard in June and a 3.5
mg/L standard in July. It is particularly hard to
imagine how this could be done given, first, that many dischargers are currently discharging to water
bodies known to violate standards in June, a month that everyone agrees should continue to be
governed by the 5
mg/L minimum and, second, that IEPA only very rarely uses the DO standard in
permit writing. (Frevert, Nov. 2-3,2006, Tr. 255-6) Still further, a standard that is not protective of
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, DECEMBER 20, 2006
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aquatic life cannot legally be approved by U.S. EPA under 33 U.S.C. 1313(c) on the basis of
compliance cost
consideration^.^
B. The Board should adopt the IEPAfIDNR Position that Low DO
sensitive species should be protected
IEPNIDNR properly drew segment lines using available data as to the location of species'
requiring higher DO levels. The methodology for designating the water bodies having DO sensitive
species was explained by
IEPA's Frevert and IDNR's Joel Cross. (Frevert, Cross, Nov. 2-3,2006, Tr.
pp.29-3
1,44,214)
The IAWA's basic argument against giving this very modest level of extra protection to areas
known to harbor species requiring more DO is to show that low DO levels have been found in these
,waters and argue that the aquatic life there must have adapted to the low DO levels. (See, Streicher,
Nov. 2-3,2006, Tr. 75). But the fact that low DO conditions have been found at a few sites in streams
with DO sensitive fish does not mean that whole water body could be allowed to fall to that DO level
without ecological damage. Most obviously, if the whole Fox River had hit the extremely low DO
levels found by some monitoring stations in 2005 and 2006, there would have been no live fish in the
2
The Board has stated that under Illinois law compliance costs are relevant to its consideration of
water quality criteria. However, under federal law, economic factors may not be taken into account in
setting the numeric standards that are protective of uses. Water quality criteria that protect the
designated uses "must be based on a sound scientific rationale" and must protect the "most sensitive
use." 40 C.F.R. 13 1.1
l(a); Economic factors are irrelevant to setting such criteria. Mississippi
Commission on Natural Resources v. Costle, 625
F.2d 1269, 1277 (5th Cir. 1980). Fortunately, the
situation has not been encountered in which the Board felt compelled by state law to adopt a standard
that U.S. EPA would be required to reject under 33 U.S.C.
ยง1313(c)(3), as that would require that U.S.
EPA reject the Board adopted standard and publish a standard that complied with the Clean Water Act
under 33 U.S.C.
1313(c)(4)(A).
5
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river. (Garvey, Nov. 2-3,2006, Tr.154-55) Plainly, at that time the fish in the affected segments found
a place to swim. (Pescitelli and Garvey, Nov. 2-3,2006, Tr. 34, 155)
Leibig's law of the minimum should not be twisted to imply that fish must be adapted to every
environment, including unstable environments, in which they can be found. Species populations may
be lost in particular areas and over time. A species that is plentiful one year may be scarce the next and
a species may be harmed by assorted blows to its natural range occurring over a number of
years.3 It
would not have been correct for a person in 1870 to look at the huge number of passenger pigeons still
around and conclude that the bird had adapted to the European settlement of North
~rnerica.~
Similarly, the fact that DO sensitive fish are present in a water segment despite findings of low DO in
some reaches of the segment for some period does not prove that the population is not already under
some stress and would not be affected if the entire segment were hit with such low DO levels
constantly or in combination with high flows, a series of droughts or other stressors. (See Frevert,
Cross, and Pescitelli, Nov. 2-3,2006, Tr. 30-4)
11.
The Board should protect aquatic life against low winter DO saturation levels.
The logic of Dr. Murphy's testimony regarding the need to look at percentage saturation levels
was not refuted during the hearings (See Murphy, Aug. 25,2005, Tr.
88,94; Garvey Nov. 2,2006, Tr.
122), but it was claimed that his concerns should be rejected on the basis that it was impractical to use
percentage saturation as part of the standard.
Wilson, E.O., The Diversity of Life, (Belknap Harvard Press 1992) pp. 234,254.
Of course, we now know that, while still huge, the population of passenger pigeons was crashing and
that human activities would cause the bird to be extinct in 1914. Greenberg, Joel, A Natural History of
the
Clcago Region, (U. of Clcago Press, 2002) pp. 348-49.
6
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The practical problems of considering percentage saturation can be overcome by using
technology no more complex than a thermometer. To ensure sufficient DO saturation during periods of
cold temperature, the IEPNIDNR Proposal should be revised to include a minimum DO level of 6.5
mg/L when water temperature is 10 degrees centigrade or below.
At the November 2006 hearing, Dr. Cynthia
Skrukrud of the Sierra Club recommended the
IEPNIDNR Proposal be revised to set this minimum DO level for all waters during the winter months.
However, given concerns raised at the hearing that basing this additional requirement on time of year
was too broad, Sierra Club, PRN and ELPC now offer a revised recommendation to be based on the
water
temperature.5 In hs testimony, Dr. Murphy also indicated that such a requirement would address
the need to ensure sufficient DO saturation during periods of cold temperature. (See Murphy,
Skrukrud, Nov. 2-3,2006, Tr. 53-, 256)
111.
Proper interpretation of the standard is needed.
ELPC, PRN and the Sierra Club believe that the IEPA/IDNR proposed rules are capable of being
interpreted in a way that is protective of Illinois aquatic life. We wish, however, to register our concern
that a number of the terms in the proposed rules, such as "quiescent", "lake" and "isolated are
sufficiently vague that they are capable of being interpreted in a way that would not be protective.
Certainly, it would be intolerable if major stretches of rivers with dams, such as the Illinois River, the
Du Page River or the Fox River, were allowed to have DO levels that are below that necessary to
support a balanced aquatic environment.
5
Particularly given the testimony of IAWAYs Michael Callahan and Dennis Streicher that discharge
from a sewage treatment plant raises ambient water temperatures in the winter (Callahan, Streicher,
Aug. 12,2004, Tr.
106-07), it is clear that making the adjustment proposed by Professor Murphy is
unlikely to affect many streams or dischargers.
7
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IV.
Implementation procedures remain to be developed and steps must be taken to
improve
IEPA permitting of the discharge of deoxygenating wastes.
Issues of measurement and implementation have not been worked out. The IAWA apparently
believes that IEPA will develop implementation rules to require continuous monitoring and monitoring
that utilizes certain safeguards, but IEPA has not agreed to such monitoring as a general rule and has
objected to
IAWA's view of what rules will be developed as a result of a change in the DO standard.
(See June 29,2004 Tr. 1 1 8, 144,200; November 2-3,2006, Tr. 2 13). IEPA has not generally
committed to doing pre-dawn monitoring (Frevert, Nov. 2-3,2006, Tr.
17) although the experts and the
data clearly show that pre-dawn DO levels need to be measured. (Garvey, Aug. 12,2004, Tr. 79, Nov.
2-3,2006, Tr.
11 1) Because neither the IAWA nor IEPNIDNR Proposals set forth the required
monitoring regime, the Metropolitan Water Reclamation District of Greater Chicago (MWRDGC)
cannot fully support either proposal. (Kollias, Nov. 2-3,2006, Tr. 242)
Environmentalists will oppose removing water bodies from the TMDL list based on the new
standards unless new data shows that the water body is actually meeting the new standards as the new
standards are implemented properly. For example, August data showing that the water body never fell
below a DO level of 4.9
mg/L would not show that the water body has adequate DO levels if the
samples were taken during daylight hours. Dr. Gamey made clear that nighttime DO levels might easily
drop 3
mg/L and that in impaired streams DO might fluctuate as much as 6 or 7 mg/L and that in some
waters algae and aquatic plants might cause fluctuation ever greater. (Gamey, Aug. 12,2004, Tr. 79,
Aug. 25,2005, Tr. 65). The Fox River data produced by the IAWA shows huge DO swings. (Gamey,
Nov. 2-3,2006 Tr. 110-1 1) Indeed, a daytime reading of 4.9
mg/L in a water body known to be
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affected by nutrient pollution would be virtual proof that the DO was being violated severely during
early morning
hours.'
It appears that sewage treatment plants are having a major effect on DO levels. The data on
flow/DO relationship shows DO levels sink as effluent makes up a larger part of the flow in low
gradient steams. (Garvey Nov. 2,2006 Tr. 112, 149) The testimony of Richard Lanyon, General
Superintendent of the MWRDGC, supports this
testifllng that DO cannot be maintained in slow
moving streams taking a lot of effluent
(e.g. the lower Des Plaines). (Lanyon, Nov. 2-3,2006, Tr. 220-
21,232-33)
Finally, the record in this proceeding shows the need to reconsider
IEPA's reliance on the
Deoxygenating Waste rule, 35
Ill. Adm. Code 304.120, as almost the sole basis for setting limits on
discharges of biological oxygen demanding pollutants. Under this rule,
EPA is currently granting
permits for the discharge of such wastes under conditions in which the discharge will cause dissolved
oxygen levels to fall below the 5.0
mg/L specified by 35 Ill. Adm. Code 302.206.
Although the cause of low DO levels is basically irrelevant to this proceeding (Gamey, Nov. 2-3,
2006, Tr.
136), it is suggested in Dr. Gamey's October 2006 pre-filed testimony that nutrient levels are
not the cause of DO problems. Actually, the conclusion of the David studies cited by Dr. Garvey is
that, given the high levels of nutrients in certain east Illinois streams heavily affected by agriculture,
differences in nutrient levels within the ranges present in those streams did not explain DO levels and
that in such water bodies "it might not be possible to reduce nutrient concentrations sufficiently to limit
filamentous algal blooms." (Exhibit 2 to Hearing Exhibit 30) Given
Leibig's law of the minimum and
the fact that nutrients are necessary for growth of periphyton and macrophytes, Dodds, W.K.,
Freshwater
Ecoloav, (Academic Press, 2002) pp. 321-26, nutrients certainly have a dramatic impact on
Illinois waters as shown by the massive diurnal variation in certain Illinois waters. Contrary to the
understanding of Dr. Gamey, nutrient pollution is not now controlled by the Clean Water Act because
nutrients from farms and sewage treatment plants are not now generally subject to permit limits.
Indeed, a David paper, published in 2000, indicates that nitrogen levels have continued to rise to the
present and phosphorus levels only stabilized in the 1990s. (Hearing Ex. 38)
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In pre-filed testimony, Richard Lanyon testified that:
Approximately 70 percent of the annual flow leaving the [Chicago area
waterways] at
Lockport consists of treated water reclamation plant
effluent. Effluent also contains biological oxygen demand (BOD) and
suspended solids (SS) at concentrations less than 5
ma. Therefore, the
oxygen standard demanding substances in the effluent easily consume
the available oxygen in the effluent, making it difficult for effluent alone
to provide sufficient oxygen to maintain compliance with the DO water
quality standard. (Lanyon, Nov. 2-3,2006, Tr. 220-2 1)).
Mr. Lanyon confirmed and further explained these facts in his oral testimony given November
3,2006, stating that, where the receiving water is slow moving and the water has a high level of
effluent, discharges at the level of 5
ma BOD5 can cause DO concentrations to fall below 5 ma. As
General Superintendent Lanyon said, "that's the nature of the science." (Lanyon, Nov. 2-3,2006, Tr.
233)
Under the Illinois deoxygenating waste rule, 35
Ill. Adm. Code 304.120, the tightest limit that
Illinois EPA requires in NPDES permits is
10
mg/L CBODS.
Because total BOD includes NBOD as
well
as CBOD, the lowest level required in permits by the Illinois rule then is over twice the level that
Mr. Lanyon stated could cause violations.
During the dissolved oxygen hearing, Illinois
EPA's Toby Frevert testified that the Illinois
dissolved oxygen water quality standard was only rarely, if ever, used to set permit limits because the
agency uses its deoxygenating waste rule to establish permit limits. (Frevert, Nov. 2-3,2006, Transcript
pp. 18,255-56) Further, we learned during the hearing that the Fox River and certain other Illinois
waters that receive high levels of sewerage discharges experience extremely low DO levels. No
wonder; that's the nature of the science.
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IEPA should not continue to issue NPDES permits that allow discharges that may cause or
contribute to violations of state quality standards. Other states use well-established models to
determine the maximum amount of deoxygenating wastes that may be discharged without causing
violations of dissolved oxygen standards. This should be done in Illinois.
CONCLUSIOI\T
The Board should adopt the proposed standard proposed by IEPA and IDNR but should also
provide that waters should not fall below 6.5
mg/L of DO if water temperatures are below 10 degrees
centigrade.
Respectfully submitted,
Albert
F. Ettinger (Reg. NO. 3 125045)
Counsel for Environmental Law
&
Policy Center, Prairie
Rivers Network and Sierra Club
DATED: December 20,2006
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, DECEMBER 20, 2006
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CERTIFICATE OF SERVICE
I, Albert Ettinger, being duly sworn on oath, certify that I caused a copy of the above
Notice and attached
Post-Hearing Comments of the Environmental Law
&
Policy
Center, Prairie Rivers Network and Sierra Club
to be sent via first-class U.S. Mail to
the individuals identified on the attached service-list, at their address as shown, with
proper postage prepaid, on this day, December 20,2006.
Respectfully submitted,
Albert
F. Ettinger
(Reg. No. 3125045)
Counsel for Environmental Law
&
Policy Center, Prairie Rivers
Network and Sierra Club
DATED: December 20,2006
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, DECEMBER 20, 2006
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Service List
R2004-025
Fred L Hubbard
16 West Madison
P.O. Box 12
Danville, IL 6 1 834-0012
Bernard Sawyer
Metropolitan Water Reclamation District
6001 W. Pershing Rd.
Cicero, IL 60650-41 12
Claire A. Manning
Brown Hay
&
Stephens LLP
205 S Fifth St. Suite 700
Springfield, IL 62701
Deborah J. Williams
Stefanie N. Diers, Assistant Counsel
Illinois EPA
102 1 North Grand Ave.
P.O. Box 19276
Springfield, IL 62794-9276
Dorothy M.
Gunn
Illinois Pollution Control Board
100 W. Randolph Street Suite 1 1-500
Chicago, IL 60601
Frederick D. Keady
Verrnillion Coal
1979 Johns Drive
Glenview, IL 60028
James T.
Harrington
Ross
&
Hardies
150 N. Michigan Ave. Suite 2500
Chicago, IL 60601-7567
John
Donahue
City of Geneva
22 South First Street
Geneva, IL 601 34-2203
Alex Messina
Illinois Environmental Regulatory Group
3 1 5 0 Roland Ave.
Springfield, IL 62703
Charles W. Wesselhoft
Ross
&
Hardies
150 N. Michigan Ave Suite 2500
Chicago, IL 60601 -7567
Erika K. Powers
Barnes
&
Thornburg
1 N. Wacker Dr. Suite 4400
Chicago, IL 60606
Dennis L. Duffield
City of Joliet
Department of Public Works and Utilities
921 E. Washington St.
Joliet, IL 6043 1
Stanley Yonkauski
Illinos Department of Natural Resources
One Natural Resources Way
Springfield, IL 62702-1 271
James L. Daugherty
Thorn Creek Basin Sanitary Dist.
700 West End Ave
Chicago Heights, IL 6041 1
Joel J. Sternstein
Office of the Attorney General
188 W. Randolph St.
2oth Floor
Chicago, IL 60601
Connie L.
Tonsor
Illinois EPA
102 1 N. Grand Ave
P.O. Box 19276
Springfield, IL 62794-92
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Service List
R2004-025
Katherine D. Hodge
Sue Schultz
Hodge Dwyer Zeman
Illinois American Water Company
3 150 Roland Ave.
300 N. Water Works Dr.
P.O. Box 5776
P.O. Box 24040
Springfield, IL 62705-5776
Belleville, I1 62223-9040
Lisa Frede
Michael G. Rosenberg Esq.
Chemical Industrial Council of Illinois
Metropolitan Water Reclamation District
2250 E. Devon Ave- Suite 239
100 E Erie St.
Des Plaines, IL 6001 8-4509
Chicago, IL 606 1 1
Matthew
J. Dunn
Office of the Attorney General
188 W. Randolph
2oth Floor
Chicago, IL 60601
Mike
Callahan
Bloomington Normal Water Reclamation Dist.
P.O. Box 3307
Bloomington, IL 6 1702-3307
Richard
McGill
Illinois Pollution Control Board
100 W. Randolph St. Suite 1 1-500
Chicago, IL 60601
Stephanie N. Diers
IEPA
1021 N. Grand Ave E.
P.O. Box 19276
Springfield, IL 62794-9276
Susan M. Franzetti
10 S.
LaSalle St. Suite 3600
Chicago, IL 60603
Vicky McKinley
Evanston Environmental Board
233 Grey Ave.
Evanston, IL 60202
Edward Hammer
U.S. EPA
WQ-16J
77 W. Jackson Blvd
Chicago, IL 60604
Larry Cox
Downers Grove Sanitary Dist.
2701
Curtiss St.
Downers Grove, IL 605 15
Richard Lanyon
Metropolitan Reclamation Dist.
100 E. Erie St.
Chicago, I1 606 1 1
Sanjay K. Sofat
Illinois EPA
102 1 N. Grand Ave East
P.O. Box 19276
Springfield, IL 62794-9276
Tom Muth
Fox Metro Water Reclamation District
682 State Route 3 1
Oswego, IL 60543
Margaret P. Howard
2601 S. Fifth Street
Springfield, IL 62703
W.C. Blanton
Blackwell Sanders Peper Martin LLP
2300 Main Street Suite 1000
Kansas City, MO 6401 8
Roy M. Harsch
Gardner Carton
&
Douglas LLP
191 Wacker Dr. Suite 3700
Chicago, IL 60606
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, DECEMBER 20, 2006
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Service List
R2004-025
Todd Main
Director of Policy and Planning
Friends of
the Chicago River
407 S. Dearborn- Suite 1580
Chicago, I1 60605
N. LaDonner Driver
Illinois Environmental Regulatory Group
3 15 0 Roland Ave
Springfield, IL 62703
Marc Miller, Senior Policy Advisor
Michael
J. Fischer, Policy Advisor
Office of Lt. Governor Pat Quinn
Room 2 14 State House
Springfield, IL 62706
Irwin Polls,
Ecological Monitoring Assessment
3206 Maple Leaf Drive
Glenview,
IL 60025
Tracy Elzemeyer
General Counsel
Ameircan Water Company
727 Craig Road
St. Louis MO 63141
Dr. Thomas
J. Murphy
2325
N. Clifton St.
Chicago, IL 60614
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, DECEMBER 20, 2006
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