Fixing the Illinois Pension System by Investing in Local Economies

JC Whitney DevelopmentToday we read an article, INTERVIEW: When a State Doesn’t Realize Its Best, City-Level Assets, in which Pennsylvania Treasurer Rob McCord talked about the impact that the transfer of funding of education from a state to local responsibility would have on his state's economy. While we might not have totally agreed with his hesitation to transfer at least some of this responsibility, his comment of "..that’s coming at the expense of other basic investments in services that could yield a return, and we’re seeing this downward spiral" made us think more about the synergy between state and local finances. As Rob was pointing out, the development of economic drivers really happens at the local level. And when a city makes this local investment to attract and develop business, the state benefits from the additional revenue generated. This is of course not news to any of us in government – it is why Illinois, the state we happen to live in, already has so many programs that provide economic development money to cities. But what it did make us start thinking about is how the state's pension fund could fit into this equation. Could the pension fund in Illinois be used to invest in local economies to increase state revenues and as a side benefit provide better and more secure returns to the pension fund?

While we are not financial experts nor did we stay in a Holiday Inn Express, we do have some background and familiarity in working with the funding systems in Illinois for economic development and investment in infrastructure. We realize from this experience that the framework and support for this is already in place for the state to provide monies to local agencies to support and attract businesses through construction of infrastructure. Some monies are provided through loans such as the revolving loan funds at the IEPA while other programs like IDOT's EDP  provide funds through grants that do not have to be paid back. So we wondered why not do something similar with the pension funds? 

The approach we were thinking about would be to use pension funds as the source of loan funds that are made available to local agencies for the sole purpose of supporting an infrastructure project tied to economic development. The loans would be provided at a range of interest rates depending on whether or not the local agency had an actual commitment from a business to locate in the community. For example, if a city did not have a specific business in mind and instead was only creating a business park, the rate could be set at 5%. But if the city was able to get a business to sign something like a 10-year commitment and needed a loan to build the infrastructure to attract that business, the loan rate could be 3%. There are many other factors that could be used in a formula to determine interest rate such as expected jobs, sales tax, real estate tax, etc. Perhaps the state could even start out with a small pilot program to test the feasibility of this concept and allow for a testing of the parameters that would need to be in place to ensure its success.

They key to all this is that right now we are relying on Wall Street for our returns for our pension fund investments, and there is no guarantee on the rate of return nor does it necessarily put money back into the economic engine of our own state. If we instead made pension fund investments in our local economy through a system that guaranteed a rate of return from reliable sources – local agencies – we would know we were making money each year, we would know how much, and we would be using our money to make more money. It might not fix the whole problem, but it seems like it has potential to at least contribute some benefit.

 

 

Share

“We are engineers; we are not gamers”

Photo from the Cheesecake Sim in Second Life

Over the past several years, most people I knew in the industry chose to ignore what was going on with 3D immersive technology. At one point they might have taken a quick look, realized gaming engines like Second Life were not easily compatible with the CAD products we used, and moved on. Until more recently this compatibility issue might have been true. But thanks to some innovative developments over the last year, it's probably a good idea for the industry to start paying more attention.

There are a few examples out there that were created over the past few years by some of us in the AEC industry demonstrating what can be done with software like Second Life and related tools like OpenSimulator (OpenSim). While most of us set up small concept builds, some people like Jon Brouchoud developed larger models to assist cities in urban planning using products like Unity3D. And companies like Daden have taken a project from concepts created in Second Life through to the final construction and ribbon cutting of the actual building (Birmingham Library). But the challenge was always integrating our work in CAD with these 3D software packages – there just was no capability to move our work between the two environments. Initially it seemed it could not be done because software like Second Life or OpenSimulator would not allow imports of 3D objects created in CAD or other 3D software. But eventually Second Life and OpenSim developed the ability to allow mesh objects to be brought into the environment. Then the problem became trying to apply the textures or images to those imported 3D objects. We were used to easily and quickly applying textures to 3D objects created in Second Life/OpenSim. However, we did not have this same functionality with imported 3D models. Below is a building I created entirely in OpenSim. The textures you see on the building were also applied directly to the building in that software. If I wanted to change one of them all I would have to do is choose the element I want to change then select a new color or texture.

Building created in OpenSim

But if this object had been imported, I could not as easily change the images or colors applied to it since the textures would have been created and mapped to specific elements of the object in another program. You can only change the individual colors or textures by going back into a 3D editing program or another graphic program and changing the texture or the mapping there. You could not swap them out in Second Life/OpenSim or Unity3D.

Another problem was that you could not easily export a 3D build created in a place like Second Life or OpenSim for use in CAD or other 3D programs. This functionality would be highly useful for engineers and architects who could develop a concept build in Second Life/OpenSim and then export to a CAD program for development of final plans. It would also be useful to export objects for use in Unity3D because builds created in that software can be set up to be viewed by anyone through a web browser – no special software viewer is needed. This lack of ability to export work turned away a lot of engineers because they would not want to spend a lot of time building something in Second Life or OpenSim then have to recreate it in CAD.

The good news is that all these issues with importing, exporting, and texturing seem to have been solved. The solution came about through a third party provider of the viewer software used to access the 3D environment of places like Second Life and OpenSim. In the photo below I am using the most recent Singularity viewer to export the 3D object I created in OpenSim. As part of the the export process, the textures are automatically mapped to the right locations. It took no time at all to export the building to my computer as a Collada file.

Building export from OpenSim

After exporting the building and textures, I opened up Unity3D to see how easy it would be to bring the building into that environment. I imported the 3D object I had exported from OpenSim. Then I imported each texture I had used in OpenSim. They mapped into the correct place for each component as I brought them into the folder. All I had to do was change the color for the floor since the original texture is white rather than dark gray. As you can see from the image below, the only texture issue I still need to address is the transparency of the windows. (If you want to try visiting this very simple build, just click this link and wait for it to load. You can move around using your mouse and arrow keys once it is loaded. Public Works Group Building Test Site)

Test import of OpenSim object into Unity3D

So the bottom line on this is that because of the developments in the Second Life and OpenSim software and in the Singularity viewer, 3D objects and their textures can now be easily and quickly exported from these environments and brought into any other software that accepts a Collada file. And any Collada file can easily be imported into the Second Life/OpenSim environment. Because of this we can now make a 3D object that is textured and to scale using software like Second Life or OpenSim (which by the way is free to download and use although Second Life does charge a very small fee for texture uploads) then export this object for use in any other program that accepts a Collada file. Now, the surprising point in all this for me was that at no point in this work flow did I use CAD at all to create these objects. I guess I had always thought I would want to create the object in CAD and only bring it into these environments for visualization and simulation. But because of these developments now I can do all that entirely without using CAD. 

However, I was still thinking I would eventually want to bring this into CAD when I am ready to create the actual plans. But based on a few conversations I had over the last week I'm starting to wonder if that is the direction I should be thinking. The first feedback I received was from a representative of one of the two major civil CAD companies. We talked a little about integrating CAD with gaming engines before he gave a presentation at a conference I attended. Then during his presentation, he announced, "we are engineers; we are not gamers." After hearing this definitive rejection by a major CAD company of all that looks, smells, or feels like a gaming engine, I was happy to find a totally opposite viewpoint from a representative of the other large civil CAD company. That person had called me to share his excitement at seeing how his company is integrating the code used for their own 3D and animation products into their Civil CAD product. He also said they were adding the ability to read and use data in the CAD environment and were about to release a cloud subscription package. While I was excited to hear about these advances, I was particularly interested in the cloud package. His company's software can already import/export 3D models while the other cannot. And If the cloud package is affordable enough, I was thinking I might be able to take advantage of that option.

My final conversation regarding 3D models occurred with another engineer during a meeting. He shared with us a picture of a culvert he created in Google Sketchup. He was impressed because he could use free software to easily create something that allowed all of us to better visualize his design. His opinion was basically why use something as complicated and expensive as CAD when you get such great results from a low cost program that is so easy to use.

So after mulling all that over in my mind, I started wondering if someday we won't need CAD anymore. Perhaps one day engineers will build entirely in a "gaming engine" then export the file to suppliers and contractors who have their own software driven equipment that can calculate quantities, order materials, and develop and ship what is needed to assemble it all on site. I realize this might seem a little farfetched today, but is it really impossible? After all, without ever touching CAD, I already have the ability to take the file I exported of my 3D building built entirely in OpenSim that you see in the photos above and send it to any one of the many 3D printing companies and have it "constructed." So, is it really so wrong to think this could some day be done on a larger scale?

 

Share

Infographic of the Month – June 2013

This month's infographic, Improving Healthcare Buildings with BIM, is brought to you by one of my very favorite companies, Autodesk. Just like infographics, BIM makes use of visualization techniques to convey a message in a more interesing way that makes ideas easier to understand.

Improving Healthcare Buildings with BIM from Autodesk

If you have an interesting infographic related to public works or any other topic typically covered by the Public Works Group and want to have it featured as Infographic of the Month, just send it to pwg@publicworksgroup.com.

 

 

Share

Asphalt Infographic

The next infographic up for your viewing pleasure comes from the National Asphalt Pavement Association - definitely a site you'll want to check out for everything asphalt. Thanks to T. Carter Ross, vice president for communications, for sharing their infographic "7 Keys to Highly Successful Parking Lots."  This infographic is based upon an informative and helpful brochure: "Seven Steps to to a Highly Successful Parking Lot" published by PAIKY - Plantmix Asphalt Industry of Kentucky. (You can click on it to get a larger image.)

7 Keys to Highly Successful Parking Lots

 

 

 

Share

The Virtual Real Estate Market

Many people might be surprised to find out there is a virtual real estate market and have had a hard time understanding how someone could pay money for something that you can't physically touch like virtual land. Before visiting virtual worlds myself, I would not have believed people would pay money for something like that. It was only after spending time in places like Second Life that I began to see the value people found in having a virtual space and virtual objects. Over the years I've watched as this value increased to create a billion dollar virtual goods industry – reported by TechCrunch to have reached $2.3 billion by the end of 2011. 

Drafting Table in Second Life

But while the virtual goods market has increased, the virtual land market, at least in places like Second Life, has seemed to follow a trend similar to that of the physical real estate market in the U.S. In both places, land values have dropped and the amount of vacant and abandoned land has increased resulting in a surplus of properties. Because of the similarities I've seen in the offline and online markets and their affects on communities, I thought it would be interesting to look at a comparison of the physical and virtual markets and explore movements towards recovery.

To get an idea of the amount of land available for sale in Second Life, I took a screenshot showing the large number of parcels for sale in an area of Second Life. Each dollar sign indicates a parcel on the market. (The green dots represent people who are visiting a space.)

SLmapJan2013

In most offline communities the number of vacant and abandoned parcels would not appear to be as large as what is seen in the virtual land market in Second Life. But there is one place where it does seem close – Detroit. Below is a screen shot of a website called Why Don't We Own This by Loveland Technologies showing the number of foreclosed or tax-distressed parcels in an area of Detroit.

Why Don't We Own This - Detroit

To better understand the performance of the virtual land market, we need to know how land is handled in a place like Second Life and what drives people to buy it. The world of Second Life is made up of many islands of virtual land also referred to as sims or regions. Each sim measures 256 m by 256 m. People enter the world in an avatar form which is a digital representation of themselves that they can use to explore the world. The basic land, sky, and ocean are provided by the company hosting the world of Second Life. Everything else that someone would see there was created by users. This can include plants, buildings, and other objects placed to enhance the user experience. People can also build upon or change the ground, water, and sky features with objects they create.

Typical customization of land, ocean, and sky in Second Life

However, all of these objects take up space in the world and use up computer resources. So Linden Lab, the company hosting Second Life, assesses a fee to users who want to leave their objects permanently displayed on a parcel of land. And because it would be chaos for people to just randomly leave things everywhere, they control where people can place their items by requiring people to own the land where their objects are displayed. At a basic level, you can think of it as renting storage space on a server where you are allowed to store your files. The only difference here is that in Second Life your files can be displayed as 3D objects and you and others can visit them in avatar form. I suppose it could also be compared to renting a storage unit where you can keep your physical possessions. Although one difference is that you are only allowed to take out objects or files in their entirety if you created them – you are not allowed to take something out of Second Life's system just because you purchased it.

Anyway, here's how the costs are assessed in the virtual world. Because the fees are dependent on the resources used, Linden Lab first sets a limit on the number of objects, which are called prims (a prim is a basic building unit), allowed on a full sim to 15,000. To get an idea of how prims are incorporated into objects you can look at the photo below taken inside of a building in Second Life. The highlighting outlines each prim used to make this building.

Prims highlighted in Second Life

Then Linden Lab offers users a choice between two different types of land for display of their items: Mainland and Private Islands. Mainland is a large group of islands or sims available to anyone to purchase and then subdivide and resell. Below is a detailed map showing parcels for sale in an area of mainland in Second Life. For reference, the large, yellow square is a full sim measuring 256 m by 256 m. Before the fall of the land market, mainland islands sold by Linden Lab through auction could cost about $1,000.

Second Life map showing land for sale

Back then, the lowest resale cost was a few dollars per square meter. Today the cheapest resale cost is $0.17 per square meter. This difference is simply a reflection of what happens when supply exceeds demand. It almost sounds exactly like what happened to many developers in the physical real estate market who had invested in subdividing land and were left with vacant lots and no buyers after the market fell. Many of those developers went bankrupt and lost the land to the bank. In Second Life, when owners abandon their parcels, they return to the ownership of Linden Lab. Below are a few statistics of the status of mainland in Second Life (these numbers come from Tyche Shepherd). Because of the amount of vacant and abandoned land, the amount of mainland has remained close to the same for some time at just over 7,000 regions with no new regions being added – there's just no demand to justify the creation of new land.

  • 46.5% of mainland is owned by Linden Lab
  • 10.6% to 11.6% of mainland is abandoned (assuming not yet returned to Linden Lab)
  • 7,121 Mainland sims in total (that's about 467 million square meters of land)

Total mainland regions in Second Life 2007 to 2013

The alternative land choice available to users is a private region or island. These are available in full sim size only and can be sold or subdivided, but ownership cannot be transferred at the parcel level. Private islands vary in cost based on how many objects you can place on the land because Linden Lab does offer full private regions with different resource allotments. A full island allowing 15,000 prims costs $1,000 to purchase, a "Homestead" island allowing 3750 prims costs $375, and an Openspace island allowing 750 prims costs $250. You also have to own a full island to be able to purchase a Homestead or Openspace sim. In 2008, there were almost 27,000 private regions. Today there are about 20,700, and the number seems to be decreasing at a steady rate.

Total private regions in Second Life 2007 to 2013

One question that some of you might be wondering, if you are not familiar with Second Life, is why would people abandon the land they bought? Why spend $1,000 for a private region then just let it go? The answer is in the fees Linden Lab charges for the use of the land you buy. These monthly costs, often referred to by users as "tier," can also be thought of as a type of rental charge for the resources used to store and display virtual objects. Tier varies depending on the size of the parcel. A full sim (65,536 sq meters) on mainland costs $195 a month while 512 sq meters costs $5 (512 sq meters of land is limited to 117 prims). A full private sim or region costs $295 a month. So just like in the offline world where you might have no mortgage yet still lose your property because you cannot afford the taxes so too in the virtual world. You might have been able to buy the land at one time, but usually it's the ongoing costs that cause you to give up your property. In the physical world it might be the real estate taxes, and in the virtual world it is the land use fees or tier.

For Sale sign on mainland in Second Life

People who have owned land in Second Life, including myself, have complained for many years that tier is too high. Many of us have said that people increasingly cannot afford land if tier is not reduced. And this seems to parallel exactly what happens in the offline world. People who cannot afford the taxes in a community complain and try to get them lowered. But while there is somewhat of a relationship in the physical world between the amount of taxes and the size of the parcel, other factors influence the rate. Real estate tax is set by government based on the school costs and cost to the government for providing services. It can only be reduced so much without cutting back on education or services or investment in assets. In the virtual world, the fees or tier are also needed to pay for services such as the hardware supporting the world, upgrading of software and features, and customer support. But a significant difference is that because the virtual world is owned and managed by a private company, fees also support profit – in the physical world, profit is never part of the equation for assessing taxes.

salesign_002

So for those of us facing high real estate taxes in our physical spaces, we can complain to our elected officials and demand taxes be reduced or frozen. But if they decide to cut or freeze our taxes, it will be by reducing services which we might not want to accept or which might cost us more in the long run. Of course we can move to a different community, but there are several down sides to this solution. Education and government services have a similar cost across the United States. Sure there might be some areas that save money because they don't have to deal with costs for handling winter weather or they have cheaper labor costs, but most people don't analyze city and school budgets and compare them to each other to figure out if the difference in tax rate is due to these factors which are actual cost savings or if they are due to a reduction in services. Uprooting your family and moving them across the country to find the most cost effective community in which to live is also a major challenge. This would require a significant investment of time and money along with the need to find a new job and perhaps if children are involved a search for a new school or daycare. Most of us just don't have that kind of mobility in our physical world so we are limited in our ability to move.

Wastelands in Second Life

Government has tried to explore other methods of reducing the cost to live in a community. There are assistance programs for those who qualify and freezing of taxes for senior citizens. Based on a comment from one of my Facebook friends, it appears the U.K. might be trying to encourage people to downsize to a home that might be more affordable for them by assessing a fee on unused bedrooms in a home. Affordability of housing is and probably will be an ongoing challenge for communities.

Living Space from 2012 SL Home Expo

In the virtual space, people have pointed out that some of the operation costs for hosting a virtual world have been reduced because of lower costs for the infrastructure so tier should be lowered to reflect this. But others have argued that fees cannot be lowered or profits will be lost. In the end, Linden Lab has not indicated in any way that tier will ever be reduced. So people who are upset with paying the level of "taxes" or tier have to make a decision between accepting the costs or moving to another virtual world. After all, Second Life is no longer the only virtual community out there.

But a downside to making that virtual move is that people can experience an "uprooting" similar to what they would feel from a move in the physical world because they are leaving their friends and community, but that is where the similarity ends. The time and investment needed to make a virtual move is significantly less than what it takes to move in the physical world. And there are usually no jobs or schools or other factors to have to worry about. People still risk the reduction in services by moving to a world with a lower cost, but it's much easier to research and explore what those reductions will be if any.

Fantasy Faire 2012

So let's finally look at what happens to a community when costs of land do not decrease, services decline, and the population becomes alienated from its caretakers. Again we will look at Detroit – in the last decade, this city has lost 25% of its population (see Wall Street Journal article). Some of the reasons cited for this loss are affordability (taxes and jobs) and a reduction in services. It almost becomes a viscious cycle because as people move out values fall, properties are abandoned, and taxes must be raised to offset losses. So many properties in Detroit were abandoned that some sections were even closed off. But as shocking as Detroit's current situation appears to be, it seems it has been steadily declining for decades. There's an interesting discussion about the causes here: The Reasons Behind Detroit’s Decline by Pete Saunders.

Population of Detroit, Michigan

Those who follow the virtual land market in Second Life might see some similarities in that declining graph. And while the elements within the virtual and physical communities might be different and the downward trend not as long, people believe Second Life's land decline is caused by management issues that sound a lot like Detroit's: a refusal to discuss or address the decline and the cost of maintaining land, a focus on meeting the needs of one or two primary groups, and a lack of investment in the community to the point where people sense a feeling of neglect. And when I say this, I don't mean the company managing Second Life is actually neglecting the world. As a person working in government I am well aware of the essential work and effort that goes into operating a community – work that no one knows about or wants to know about. And I believe Linden Lab is taking care of all those operational duties much like a public works department works in the background to make sure a city keeps functioning. The neglect comes about because in addition to keeping the gears turning, a community needs nurturing to be successful.

Old Packard Plant Detroit - from AcrylicArtist on morgueFile

Even if you think you are meeting the needs of the people, if the population thinks you are not, then you are not. For those of you who used to play Sim City it is kind of like the newsflash you would get telling you what the people in your city thought about the job you were doing. When they were unhappy, you would try to figure out what you could do next to change their opinion to one that was more positive. Well, unless you were the type who liked to inflict disasters and mayhem on your city just to see how bad it could get.

After 60 years, Detroit is now working hard to stop their decline. They are engaging the public and offering incentives to encourage people and business to move to their community knowing it can ultimately lead to lower costs for everyone as revenue increases. And they are no longer listening to only one industry – now everyone in the community has the potential to voice their ideas and opinions through online sites and public meetings and workshops like the one shown in the image below. The people who love and care about Detroit do not want it to slip into oblivion.

Detroit Can Do Camp

Those of us who love Second Life also do not want it to slip away, but we do not seem to have reached the point yet where the owners of the world have expressed any concern about the loss of land and investment. And we face a challenge somewhat different from people in places like Detroit. Those running our community do so to make a profit and they alone have ownership. In places like Detroit, the people own the community – in the end, they have the power to keep the lights on or turn them off and walk away. In Second Life, this decision is ultimately up to the company owning that world.

Waymount in Second Life

Perhaps the owners of Second Life are content to make as much money off the world as possible while allowing the decline to occur until expenditures exceed revenue. Then at that point, they just shut it all down and go on to their next thing. Or they might expect the decline to eventually stabilize and as long as they are still making an acceptable profit, they will be content to leave the world at that size. After all, not every community wants to become a metropolis. And some communities only want a demographic that can afford to "live" there.

Land company in Second Life

Finally the other option is what Detroit has chosen – address the decline and determine a path to turn it around. And just as Detroit is investing significant effort now to accomplish growth, this option would also be the most work for Linden Lab. There are some who have suggested Linden Lab is pursuing this option by launching other potential revenue streams. And some have suggested imposing new fees unrelated to land. If these steps were taken, the company could choose to use new revenues to help meet costs of operating Second Life and still ensure profit while allowing for a reduction in tier. This is somewhat similar to a city adding new taxes or service fees or a city that works to attract a heavy sales tax or industrial base and uses the additional revenues to offset a reduction in taxes for residents. But if the company chooses to build a new revenue base, the key will be to diversify, because history shows relying on one group or industry or revenue stream eventually leads to a collapse. The video below is a trailer for a documentary about communities and the aftermath of this type of collapse.

As the young man points out in this video the "The soul of the city . . .are the people." So if Linden Lab chooses to follow Detroit's path, they need to also follow their example of engaging and informing the community and embracing the people because the people really are Second Life. Without them, there is only water, ground, and sky. And people cannot be expected to invest time and money in a community without knowing its plan for the future or feeling like they have a say in that future. As decades of emigration and our example of Detroit have shown, when people have no clear path to the future and lose faith in leadership on top of facing high costs, they will eventually seek out a new world and opportunities.

Statue of Liberty

 

 

 

 

 

 

 

Share

Why is the Illinois Department of Agriculture Determining Stormwater Rules for Cities?

Winter flooding across a farm field

Recently I wrote about the draft release of Post-Development Stormwater Runoff Performance Standards for Illinois. And in discussions with colleagues over the last few weeks, I have not heard any positive support from anyone who has a professional background in stormwater management or regulation. Instead the consensus among stormwater professionals regarding the draft is that the entire document should be rewritten and the recommendations reconsidered because they are based on few facts, will not work, and will increase project costs significantly. So it makes you wonder how did something that so poorly addresses the reality of stormwater management get this far, and why is the IEPA seriously considering accepting recommendations from a group with a majority of members who have absolutely no background in stormwater management or regulation?

To begin answering this question, you need to look at who is running the show. This was one of the first questions I heard from everyone – why in the world did the IEPA arrange to have the Association of Illinois Soil and Water Conservation Districts (AISWCD) lead this effort? There are so many counties who could have been consulted instead – they bring decades of stormwater management and regulation to the table. Yet none were contacted. They could have reached out to engineers who have spent their career formulating stormwater designs, managing stormwater projects, and maintaining and regulating stormwater facilities. Yet only one recognized engineering expert with a background in all of these was picked to be in the workgroup.

So again, why the AISWCD? And just who is the AISWCD? Their website explains the group is

"a not-for-profit organization governed by a board of directors who represent the state’s 98 Illinois Soil and Water Conservation Districts."

So the purpose of this private group is to represent the Soil and Water Conservation Districts in Illinois – a group of governmental agencies. In 2010, the group received $231,663.09 in dues from these districts. So the next question is what are the Soil and Water Conservation Districts? (Of course a side question is why does a group of governmental agencies need a private, non-profit group to represent their interests, but that's another story.) The districts were created through an act of the Illinois Legislature and appear to be part of the Department of Agriculture. There is an advisory board to oversee these districts – here is the State's page indicating those board members: http://appointments.illinois.gov/appointmentsDetail.cfm?id=256

As you can see, the members of the advisory board for the Districts are supposed to come from Agriculture – not stormwater related professions. This is particularly interesting to note when you take into consideration that one of the first statements made at the public hearing held in Aurora regarding the new stormwater recommendations was that anything related to agriculture was not on the table – would not even be considered. It is also interesting when you read the recommendations and see that there is no mention of relying on the State's 303d list of impaired waters to make any decisions. Of course when you look at the State's official report regarding land uses contributing to pollution of these streams, you will see that agriculture is one of top contributors – much more so than what is contributed by stormwater runoff from communities and significantly more so than what is contributed from highways.

Sources of Stream Impairments
Potential Source Stream Miles Impaired
Source Unknown 7097
Atmospheric Deposition – Toxics 3050
Crop Production (Crop Land or Dry Land) 2576
Channelization 2471
Agriculture 1395
Municipal Point Discharges 1374
Loss of Riparian Habitat 1245
Urban Runoff/Storm Sewers 1207
Animal Feeding Operations 652
Livestock (Grazing or Feeding Ops) 290
Combined Sewer Overflows 253
Highway/Road/Bridge Runoff 110

Table Source: ILLINOIS INTEGRATED WATER QUALITY REPORT AND SECTION 303(d) LIST, 2012

It also makes you wonder when you ask a work group member what the goals were for the recommendations and cleaning up the environment or improving our water quality was not the answer. So to summarize, the IEPA put the wolf in charge of the hen house – oh, I mean, the IEPA put the Department of Agriculture in charge of deciding stormwater standards and regulations to be imposed only on home and business owners, municipalities, and developers. And because no obvious goal has been stated in the recommendations, it makes you wonder is the goal really environmentally related or is it a protection of agricultural interests cloaked in the benevolent perception of helping the environment?

 

Share