CLERK’S
OFFICE
NOV
0
2009
STATE
OF
ILLINOIS
November
2,
2009
Pollution
Control
Board
John
Therriault,
Assistant
Clerk
Illinois
Pollution
Control
Board
100
West
Randolph
Street,
Suite
11-500
Chicago,
Illinois
60601
Re.’
Rulemaking
R08-009
Dear
Illinois
Pollution
Control
Board:
I am
writing
to
express
my
strong
support
for
the proposal
by
the Illinois
Environmental
Protection
Agency
to
require
disinfection
of
treated
water
discharged
into
the Chicago
River
system
by the
Metropolitan
Water
Reclamation
District.
I am
a
certified
sea
kayak
instructor
who
has paddled
extensively
both
on
the Chicago
River
and
on
other,
cleaner
waters
in
our
region.
I
am
also
a
participant
in
the
CHEERS
epidemiological
study
being
conducted
by
the UIC,
and
have
serious
doubts
based
on
my
own
experience
whether
a study
of this
nature
can
capture
the
radical
difference
between
the way
paddlers
use
polluted
versus
clean
waters.
I have
been
paddling
in
the greater
Chicago
area
for
approximately
nine
years,
and have
been
a
certified
instructor
and coach
since
2007.
I paddle
on
the
DuPage,
Vermillion,
Fox
and
Chicago
rivers,
as well
as
along
Lake
Michigan’s
shoreline.
I
frequently
assist
with
beginner
kayak
trips offered
by
the
Chicago
Whitewater
Association.
Most
of
my teaching
is on
Lake
Michigan,
the
Fox
River
and
in
the
Big
Rock
Quarry
(in
Sugar
Grove),
but
I occasionally
teach
in
the
Skokie
Lagoons.
Because
of the
bacterial
pollution
in
the
Chicago
River,
there
is
a
huge
difference
between
the
way
I paddle
there
and they
way
I do so
in
cleaner
waters,
and
I
almost
never
teach
on the
Chicago
River.
When
I
take
kayakers
on waterways
that
are
relatively
clean
— Lake
Michigan,
the
DuPage
and
Vermillion
rivers
—
we deliberately
get very
wet.
Beginners
practice
hanging
upside
down
in
their
boats
while
awaiting
a
rescue,
and
swimming
out of
their
overturned
boats
to
safety—essential
skills
for
safe paddling.
More
advanced
paddlers
purposely capsize
as we
push
the limits
of our
skills
and
practice
rolls
and rescues.
In other
words,
we
not only
don’t
worry
about
getting
wet
on these
rivers--we
encourage
it.
Paddling
on the
Chicago
River,
however,
is
a
completely
different
experience.
I
am not
willing
to
teach
most
kayaking
skills
on
the
Chicago
River
because,
as
noted
above,
teaching
those
skills
requires
getting
quite
wet.
I have
only
led
one
sightseeing
trip on
the
Chicago
River.
We did
our
best
to
stay
dry,
and
I warned
people
to avoid
touching
the
water.
We
thoroughly
washed
ourselves
and
our
gear
afterwards.
Beginners
can
and
do
capsize
on
occasion,
of
course,
even
on
a
flat
river
like
the
Chicago
River.
But
in my
experience
and
that
of
other
paddlers I’ve
talked
to, people
are
very
cautious.
I
am
a
member
of
several
local
paddling
listservs,
so
I requested
information
from
anyone
who
had
paddled
on
the
Chicago
River.
All
of
them
expressed
a
general
cautiousness
about
paddling
on the
Chicago
River,
similar
to
mine.
When
fellow
instructors
take
beginners
on
the
river,
they don’t
take
risks.
Students
don’t
hang
upside
down
and
get
water
up
their
noses,
as
they
do
on
cleaner
rivers.
In
fact,
beginners
aren’t
generally permitted
to
wear
spray
skirts,
so they would
likely
fall
out
of
their
boats
long
before
they
were
completely
upside
down.
As
noted
above,
I have
participated
in
the
UIC
CHEERS
study,
and
completed
the
required
questionnaire.
I recall
that
several
of
the questions
attempted
to
ascertain
how
wet
I got
while
paddling
and
how
much
water
I
swallowed.
However,
in
light
of my
experiences,
I
am
profoundly
skeptical
that
the
questions
in
the
CHEERS
study
are
sufficient
to
get
at the
huge
difference
between
the way
kayakers
are
exposed
to
water
in
the
Chicago
River
and
the
way
we
are
exposed
to the
water
in cleaner
rivers.
The
survey
questions
are
very
general.
They
ask,
as I
recall,
how
wet
each
of
various named
body
parts
got
on
the river
trip,
with
a
list
of
choices
from
“sprinkled”
to
“submerged.”
This
type
of question
does
not
get
at
the
profound
difference
between
getting
wet
once,
accidentally,
and
a
full
day
of constant
and
intentional
submersion.
I also
doubt
that
the
CHEERS
study
questionnaire
is
likely
to
produce
an
accurate
picture
of how
much
water
people
ingest
in
these
different
venues.
The
questionnaire
asks
participants
to
estimate
how
much
water
they
swallowed.
However, in
my
judgment
and
experience,
it is
simply
not
possible
for
kayakers
— particularly
beginners,
who
spend
the
most
time
in
the
water
— to
give
anything
close
to
an
accurate
estimate
of that.
Hence,
it is
unlikely
that
participants’
answers
will
provide
an
accurate
picture
ofjust
how much
more
water
we
routinely
swallow
in
clean
water
bodies.
When
we
are
on
the
Vermillion
River,
Lake
Michigan
or
other
place
where
we
are
not
worried
about
water
quality,
we
are
underwater
or in
the
water
for
large
amounts
of
time.
It
is next
to impossible,
at
the
end
of
a
full
day
of that,
to make
an accurate
estimate
of
how
much
water
we
have
ingested.
We
certainly
get
some
in
our
mouths
and
noses
every
time
we
fall
in
(intentionally
or
not)
but
we
aren’t
going
to have
an accurate
tally
at the
end
of
the day.
Moreover,
when
beginners
capsize,
they tend
to panic
and
forget
really
basic
things,
like
the
instructions
they
were
given
to
hold
onto
the
boat
and
the
paddle.
I
seriously
doubt
that
when
they
can’t
recall
such
basic
safety
instructions,
they
can
realistically
remember
how
much
they
swallowed
with
any
sort
of accuracy.
It is
simply
not
credible
to
me
that
the
wild-guess
estimates
of ingestion
volume
provided
in
response
to
the CHEERS
questionnaire
are
going
to
provide
good
data
on the
different
amounts
of
water
ingested
in
different
places
and
circumstances.
As
I mentioned
earlier,
I
posted
questions
regarding
others’
experiences
on
several
paddling
listservs.
Below
are
some
examples
of
the
responses
I
received.
•
Scott
Fairly,
General
Manager,
Geneva
Kayak
Center:
“At
Geneva
Kayak
Center,
we
have
specifically
chosen
not
to use
the
river
for
any
tours
or
instructional
programs;
it simply
isn’t
clean
enough.
When
we
introduce
new
paddlers
to
the sport
of kayaking
we
want the
experience
to be as
positive
as
possible.
If we
were
to
first have
to
warn
our clients
to not
get water
splashed
in
their faces,
and
not to
paddle
if they
have
open cuts
or
sores,
it
would
pretty
much
suck
the fun
right
out of
the
day. We
would
certainly
utilize
the
river
if
it
were
cleaner.”
Sarah
Hartman,
Rolling
Meadows.
“On
this river
[the
Chicago
River],
I
paddle
in such
a way
as to minimize
contact
with
the
water.
I keep
my
paddle
angle
extremely
low
to minimize
drips
onto
my
spray
skirt
and
to reduce
chances
of splashes
on
my face.
My
launch
is seal
launch
to minimize
foot
and leg
contact
wit the
water.
When
I
get home,
all
gear
and
boat are
washed
with warm
soapy
water
(the
boat
gets
a dose
of
bleach
as well).
I take
a hot
soapy
shower
after
contact
with
the river,
including
washing
my hair
to
minimize
any
chemical
or
biological
impact.”
Steven
E. Gross,
Chicago:
“Whenever
I
do paddle
[on
the
Chicago
River]
I
try
very
hard not
to
splash
water
in my face.”
Many
of my
fellow
paddlers
avoid
the
Chicago
River
altogether
because
of
the
contamination
issue.
I would
paddle
on it
more
frequently
and
entirely
differently
if
the
Water
Reclamation
District
would
disinfect
wastewater,
the way
pretty
much
every other
town with
a
river
flowing
through
it
does.
It’s
not
an answer
to just
tell people
to
be
careful.
As
Mr. Fairty
of the
Geneva
Kayak
Center
pointed
out,
that
kind
of warning
threatens
to “suck
the
fun right
out
of
the
day”
and
prevents
us from
fully engaging
in the
sport of
kayaking
in
the way
we
can
other
places.
Moreover,
as
more and
more
groups
use the
Chicago
River
to
train
for
rowing
and
other races
— as
is happening
now —
it will
be
harder
and
harder
to
address
the
contamination
problem
by
telling people
to
take
precautions.
Racing
boats
are
very tippy
by
nature;
it’s
not
possible
to train
hard
and keep
from
getting
wet.
I
urge
you,
in making
your
decision
whether
or
not
to support
the
Illinois
EPA’s
proposal,
to
consider
the
Chicago
River
not just
as
it is
now
but as
it
could
be. Right
now,
despite
the really
very
problematic
bacterial
contamination
from
the
District’s
plants,
the
river
is
a wonderful
venue
for
sightseeing.
It could
be
a
venue where
people
can
have that
experience
without
following
it up
with a
day of
cleaning
their
boats
and
gear and
worrying
that
they
might
get sick.
Thank
you for
considering
my comments.
Sincerely,
lloyd-Peshkin
1027
Gunderson
Ave.
Oak
Park,
IL
60304
708.524.0863