BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF:
WATER QUALITY STANDARDS AND
EFFLUENT
LIMITATIONS FOR THE
CHICAGO AREA WATERWAY SYSTEM
AND THE LOWER DES PLAINES RIVER:
PROPOSED AMENDMENTS TO 35 ILL..
ADM.
CODE PARTS 301, 302, 303 and 304
)
)
)
) R08-9
) (Rulemaking - Water)
)
)
)
NOTICE OF FILING
To: see attached Service List
PLEASE TAKE NOTICE that on the 20lh Day of April, 2009, I filed with the Office of
the Clerk of the Illinois Pollution Control Board the attached:
The Southeast Environmental Task Force's Motion To Withdraw Alan Mammoser
as a
Witness to Testify, and For the Illinois
Pollution Control Board To Accept His Pre-filed
Testimony as Public Comment
a copy
of which is hereby served upon you.
By:
Keith Harley,
/{uifU
Chicago Legal Clinic Inc.
Dated: April
20, 2009
Keith Harley
Chicago Legal Clinic, Inc.
205 W. Monroe, 41h Floor
Chicago, IL
60617
(312) 726-2938
1
CERTIFICATE OF SERVICE
I,
Keith Harley, the undersigned attorney, hereby certify that I have served the attached
Motion To Withdraw Alan Mammoser
as a Witness to Testify, and For the Illinois
Pollution Control Board To Accept His Pre-filed Testimony
as Public Comment, on all
parties
of record (Service List attached), by depositing said documents in the United
States Mail, postage prepaid, from 227 W. Monroe, Chicago, IL 60606, before the hour
of 5:00 p.m., on this 20
th
Day of April, 2009.
(?vrAx/~l
Keith Harley, Chicago Legal Clinic,
I/le.
2
Roy M. Harsch
Drinker, Biddle, Gardner, Carton
191
N. Wacker Drive, Suite 3700
Chicago, IL 60606-1698
Deborah
1.
Williams and Stefanie N. Diers
Assistant Counsel, Division
of Legal Counsel
Illinois Enviromnental Protection Agency
1021 North Grand Avenue East
P.O. Box 19276
Springfield, IL 62794-9276
Kevin
G. Desharnais, Thomas W. DianlOnd,
Thomas
V.
Skinner and lennifer
A.
Simon
Mayer, Brown
LLP
71 South Wacker Drive
Chicago,
IL 60606-4637
Robert
YanGyseghem
City of Geneva
1800 South Street
Geneva, IL
60134-2203
Matthew
1.
Dnnn, Chief
Office of tile Attorney General
Environmental Bureau Nortll
69 West Washington, Suite 1800
Chicago, IL 60602
Charles W. WesseJhoft and lames T. Harrington
Ross
&
Hardies
150 Nortll Michigan Avenue
Suite 2500
Chicago, IL 60601-7567
Service
List
Bernard Sawyer and Thomas Granto
Metropolitan Water Reclamation District
6001 West Pershing Road
Cicero, IL
60650-4112
lames L. Daugherty, District Manager
Thorn Creele Basin Sanitary District
700 West End Avenue
Chicago Heights,
IL 60411
Tracy E1zemeyer, General Counsel
American Water Company Central Regiou
72 7 Craig Road
St. Louis, MO 63141
Claire Manning
Brown, Hay
&
Stephens
LLP
700 First Mercantile Building
205 SOUtil Fifth St., P.O. Box 2459
Springfield, IL 62705-2459
Katilerine
D. Hodge, Monica T. Rios, Alec M. Davis
~md
Matthew C. Read
Hodge Dwyer Zeman
3150 Roland Avenue
P.O. Box 5776
Springfield, IL 62705-5776
Margaret
P. Howard
Hedinger Law
Office
260
I Soutil FifUl Street
Springfield, IL
62703
3
Electronic Filing - Received, Clerk's Office, March 20, 2009
Jerry Paulsen and Cindy Skrukrud
McHenry County Defenders
132 Cass
Street
Woodstock, IL 60098
Lyman C. Welch
Alliance for the Great Lakes
17 N. State St., Suite 1390
Chicago, IL 60602
Lisa Frede
Chemical Industry Council
of Illinois
1400 E. Touhy Ave.
Suite 100
Des Plaines, IL 60018-3338
Sharon Neal
CommonwealUI Edison Company
125 SOUUI Clark Street
Chicago, IL 60603
James HuIf, Vice-President
Huff
&
HuIf, Inc.
915 Harger Road, Suite 330
Oak Brook, IL 60523
CaUlY Hudzik
City
of Chicago, Mayor's Office ofIntergovernmenta! Affairs
121 NOrOl LaSalle Street
City Hall - Room 406
Chicago, IL 60602
Irwin Polls
Ecological Monitoring and Assessment
3206 Maple Leaf Drive
Glenview, IL
60025
Marc Miller, Senior Policy Advisor
Jamie
S. Caston, Policy Advisor
Office
of Lt. Governor Pat Quinn
Room
414 State House
Springfield, IL
62706
Keith
I.
Harley and ElizabeUI Schenkier
Chicago Legal Clinic, Inc.
205 West Monroe, 4th Floor
Chicago, IL
60606
Fred L. Hubbard
Attorney at Law
16 West Madison
P.O. Box 12
Danville, IL 61834
W.e. Blanton
Husch Blackwell
Sanders LLP
4801 Main Street
Suite 1000
Kansas City, MO 64112
Traci Barldey
Prairie Rivers Networks
1902 Fox Drive
Suite 6
Champaign, IL
61820
Mark Schultz, Regional Environmental Coordinator
Naval Training Center
201 Decatur Ave., Bldg. lA
Great Lakes, IL 60088-2801
James E. Eggen
Director
of Public Works
&
Utilities
City
of Joliet, Deparunent of Public Works
&
Utilities
921 E. Washington
Street
Joliet, IL 60431
Ann Alexander, Senior Attorney
Natural Resources Defense Council
101 North Wacker Drive, Suite 609
Chicago, IL 60606
Beth Steinhorn
2021 Timberbrook
Springfield, IL
62702
4
Frederick D. Keady, P.E., President
Vermillion Coal Company
1979 Jolms Drive
Glenview, IL
60025
Susan M. Fnmzetti
Nijman Franzetti LLP
10 S. LaSalle Street, Suite 3600
Chicago, IL
60603
Vicky McKinley
Evanston Enviromnental Board
223 Grey Avenue
Evanston, IL
60202
Albert Ettinger, Senior Staff Attorney, and Jessica Dexter
Enviromnental Law and
Policy Center
35 E. Wacker Drive, Suite 1300
Chicago, IL 60601
Tom MUUl
Fox Metro Water Reclamation District
682 State Route 31
Oswego, IL 60543
Jack Darin
Sierra Club, Illinois Chapter
70 E. Lake Street, Suite 1500
Chicago, IL 60601-7447
Kay Anderson
American Bottoms RWTF
One American Bottoms Road
Sauget, IL 62201
Kristy A.N. Bulleit and Brent Fewell
Hunton
&
Williams LLC
1900 K. Street, NW
Washington, DC 20006
Jeffrey C. Fort and Ariel Tescher
Sonnenschein
NaUl
&
Rosenthal LLP
7800 Sears Tower
233 S. Wacker Drive
Chicago, IL
60606-6404
Dr. 1110mas J. Murphy
DePaul University
2325 N. Clifton Street
Chicago, IL
60614
Marie Tipsord, Hearing Officer
John Therriault, Assistant Clerk
Illinois
Pollution Control Board
100 West Randoph, Suite 11-500
Chicago, IL
60601-7447
Stacy Myers-Glen
Openlands
25 East Washington, Suite 1650
Chicago, IL
60602
Susan Hedman and Andrew Annstrong, Environmental Counsel
EnvirolUunental Bureau
Office of the Illinois Attorney General
69 West Washington, Suite 1800
Chicago, IL 60602
KenneUl W. Liss
Andrews Enviromnental Engineering
3300 Ginger Creek Drive
Springfield, IL 62711
Bob Carter
Bloomington Nonnal Water Reclamation District
P.O. Box 3307
Bloomington, IL 61702-3307
Ronald M. Hill ,md Margaret T. Conway
Metropolitan Water Reclamation District
of Greater Chicago
100 East Erie Street, Room 301
Chicago, IL 60611
Frederic P. Andes and Erica K. Powers
Barnes
&
Thornburg LLP
One
NorUl Wacker Drive, Suite 4400
Chicago, IL 60606
Willimn Richardson, Chief Legal Counsel
Illinois Deparunent
of Natural Resources
One Natural Resources Way
Springfield, IL 62702
5
Electronic Filing - Received, Clerk's Office, March 20, 2009
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF:
WATER QUALITY STANDARDS AND
EFFLUENT
LIMITATIONS FOR THE
CmCAGO AREA WATERWAY SYSTEM
AND THE LOWER DES PLAINES RIVER:
PROPOSED AMENDMENTS TO 35 ILL.
ADM.
CODE PARTS 301, 302, 303 and 304
)
)
)
) R08-9
) (Rulemaking - Water)
)
)
)
The Southeast Envit'onmental Task Force's Motion To Withdraw Alan MammoseI'
as a Witness to Testify. and For the IIIinois Pollution Control Board To Accept His
Pre-filed Testimony as
Public Comment
Pursuant to 35
Ill.
Adm. Code 101.500, Keith Harley of the Chicago Legal Clinic, Inc.
on behalf
of his client, the Southeast Environmental Task Force, respectfully submits this
Motion
To Withdraw Alan Mammoser as a Witness to Testify, and To Accept His Pre-
filed Testimony as Public Comment, and in support of its Motion states as follows:
1. At the time of the preparation of his pre-filed testimony, Alan Mammoser was
the Executive Director
of The Southeast Environmental Task Force ("SETF").
2. By the time of filing his pre-filed testimony, Alan Mammoser left SETF to
pursue other career opportunities, but remained willing to testify as the former Executive
Director
of SETF, anticipating that he would be testifying shortly after his pre-filed
testimony was submitted.
3. Due to the elapsing of time since Alan Mammoser's pre-filed testimony was
submitted, and due to other responsibilities Mr. Mammoser must meet which affect his
6
Electronic Filing - Received, Clerk's Office, March 20, 2009
availability to participate in hearings, SETF no longer seeks to have him testify as a
witness on its
behalf
4. Victor Crivello, who also pre-filed his testimony as a witness for SETF, is still
prepared to testify and will address many
of the issues contained in Alan Mammoser's
pre-filed testimony, and will be able to address many
of the substantive pre-filed
questions submitted for Mr. Mammoser, at the discretion
of the parties that submitted
these questions.
5. Although he is no longer available to testify on its behalf, SETF asserts Alan
Mammoser's pre-filed testimony can contribute
as part of a full and complete record for
the Board
in its review, and requests his pre-filed testimony be regarded as public
comment effective as
of the date it was originally filed with the Board.
Wherefore,
SETF respectfully requests the Illinois Pollution Control Board to remove
Alan Mammoser as a testifying witness and to accept his pre-filed testimony as public
comment.
Respectfully Submitted,
K'(,~~
Chicago Legal Clinic, Inc.
Attorney for the Southeast Environmental Task Force
Date: April
20, 2009
7
Electronic Filing - Received, Clerk's Office, March 20, 2009
