The Illinois Affiliate of the National Wildlife Federation
BOARD OF DIRECTORS
Jon McNussen
President
Charles Goodall
Treasurer
Eric Freyfogle
Secretary
Brian Anderson
Maggie Bruns
Clark Bullard
Dan Deeb
Jean Flemma
Jason Lindsey
Chad McKenzie
Michael Rosenthal
PRAIRIE RIVERS NETWORK
1902 Fox Drive, Suite G
Champaign, Illinois 61820
217 / 344-2371
217 / 344-2381 fax
www.prairierivers.org
June 15, 2010
Amy Walkenbach
Illinois Environmental Protection Agency
Bureau of Water
P.O. Box 19276
Springfield, IL 62794-9276
Re: comments on draft Illinois Green Infrastructure Study
Dear Ms. Walkenbach:
On behalf of Prairie Rivers Network, I am submitting the following comments on the draft
final report of the Illinois Green Infrastructure Study. I realize the authors may not have
adequate time to address some of the comments, but I think the report would be more
informative if some additional information was provided.
General –
Somewhere in the report, there should also be information about how long each
practice can be expected to last. There are references to a 30-year life-cycle, but what
is this based on?
The report could possibly benefit from a Definitions section. Example: some readers
might not know the difference between detention and retention.
The report assesses percent pollutant removal, but toward the end there is brief mention
of possible problems using percent removal. In the face of this criticism, the authors
should at the beginning explain why they used percent removal and discuss the pitfalls.
I think it would be helpful for the readers if, in addition to Table 1, there was a table
that listed the universe of practices that can be considered green infrastructure.
I think it would be helpful if there was a lifetime maintenance schedule for each of the
featured practices.
Tables are not always able to stand alone as they should; sometimes, in order to
understand the table (because of names of column headings, lack of caption, etc.), one
must have read the text.
The report should more thoroughly address the issue of pollutant buildup within certain
green infrastructures, and the options/costs for removal.
I think it would be very helpful if the report included a section that discussed the annual
cost to IEPA of implementing the recommendations of the report. How many staff
