Water Policy in Illinois:
The Search for Balance
Part 6 of "Water Resources in Illinois"
Illinois Issues introduction: Simplicity was the hallmark of Illinois's earliest water policy. But as the state's population has grown and the opportunities for exploitation have increased, water policy has become enormously complicated. Today there are 14 state agencies dealing with various aspects of water in Illinois: floods, drinking water, soil erosion, mine pollution, navigation, recreation, research, and pollution. Like too many cooks in the kitchen, these agencies have sometimes duplicated each other's functions or operated at cross purposes. In an attempt to rectify these shortcomings, a State Water Plan Task Force, comprised of representatives of the 14 state water agencies was established in 1980. Its goal was to delineate the problems facing Illinois' water resources and to formulate a "total water management system" that would eliminate or mitigate these problems.
How successful has the task force been since its inception? Can the citizens of Illinois rely on the future quantity and quality of their water supplies? These questions and related issues are explored in this, the final article in our series on water resources in Illinois.
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Water policy in Illinois used to be a simple matter of first come, first served. The use, and abuse, of water was a purely local concern. As populations grew with the capacity to exploit the resource, the effects of the local water decisions spread downstream. Municipal governments became involved first, usually at the point at which unrestricted dumping of sewage into the local creek made it undrinkable.
Gradually the state involved itself, first as a mediator of conflicting public and private interests. Later the state became an interested party in its own right as it sought to provide services which were beyond the jurisdiction or the means of its local governments. The state remained the preeminent decision-maker on water policy into the 1970s.
In a century and a half a sizable and varied water bureaucracy has sprouted in Illinois. The official count of Illinois water agencies is 14. The major ones are these.
• Illinois Department of Transportation. IDOT's Division of Water Resources (DWR) is Illinois' water development agency. It has authority over urban flood control, water supplies (including Lake Michigan allocations), and navigation. It is also the designated state agency in charge of federal programs in such areas as dam safety and flood insurance. Donald Vonnahme, DWR's acting director, says, "You might say we are the state equivalent of the U.S. Army Corps of Engineers."
• Illinois Pollution Control Board (IPCB). Formed in 1970 with the passage of the Illinois Environmental Protection Act, the IPCB sets the regulations for clean water in Illinois, consistent with the 1970 Illinois act and with subsequent federal clean water legislation.
• Illinois Environmental Protection Agency (IEPA) is the IPCB's eyes and hands. The IEPA monitors water pollution, enforces the IPCB regulations, and conducts research. The IEPA also administers the USEPA clean water programs in Illinois, including the construction grants program for sewage treatment plants.
• Governors. A governor's potential influence on water policy is considerable. He appoints members of key boards and commissions such as the IPCB. His Bureau of the Budget helps determine how much money executive agencies like IEPA and IDOT have to spend, and thus indirectly sets their agendas.
• Illinois Department of Agriculture (IDA). The IDA was made responsible in 1980 for implementing the state's USEPA-approved plan for controlling soil erosion. The IDA is also responsible for rural flood control planning.
• Illinois Department of Conservation (DOC). DOC is responsible for protecting the state's recreation waters for fishing and boating and preserving what is left of its natural wetlands and rivers.
• Illinois Department of Commerce and Community Affairs (DCCA). A dispenser of advice, the DCCA's Resource Conservation Division, for example, offers instruction in water conservation to both homeowners and municipalities. It also offers certain emergency services to communities during water emergencies such as droughts.
• Illinois Department of Mines and Minerals (IDMM). Under legislation originally passed in 1965 and subsequently expanded by state (1975) and federal (1977) laws, IDMM is responsible for protecting Illinois waters from spoliation by pollution from both underground and surface mining operations.
• Illinois Department of Public Health (IDPH). The IDPH administers state laws insuring the safety of public drinking water and swimming facilities.
• Illinois Department of Energy and Natural Resources (DENR). It is the parent agency of the Illinois State Water Survey (ISWS) in Urbana, which is the source of information and advice about matters meteorological and hydrological. DENR also, like many other water agencies, plays a part in the permit review process for such water-consumptive projects as coal synfuels and hydroelectric plants. DENR also sponsors some water research.
• Water Resources Center (WRC). Located on the Urbana campus of the University of Illinois, the WRC awards grants and coordinates water-related research projects at the state's universities and its three scientific surveys.
State task force on water
As one might expect, coherence has not been a conspicuous virtue of Illinois water policy in the past. Like all agencies, each of the state's water bureaucracies has its own interest group clientele, its own institutional priorities, its own style. Events of the 1970s made it clear that water policy would have to be rescued from its own specialists. More and more of the issues confronting the state appeared on official agendas under the heading, "Cross-cutting topics." The rise in the cost of classic structural solutions to water problems—flood control dams, centralized water supply systems, big sewage treatment plants—made alternative management solutions more imperative.
Illinois had drafted a state water plan to guide policy-making in 1967, but the plan was hopelessly out of date within a decade. In 1980, therefore, Gov. James R. Thompson established a State Water Plan Task Force comprised of representatives of the 14 state water agencies, to work under the direction of IDOT's DWR. The goal was to develop what the task force came to call a "total water management system" for "resource utilization." The task force would focus on what it called "problems at the margin of attention." Preliminary discussions (including public hearings) yielded ten such problems: erosion; integration of water quality and quantity management; conservation; flood damages; water competition; water habitat; recreation; atmospheric modification; drought planning; and water law.
A final plan remains a long way from completion. But task force members agree that merely meeting monthly has been helpful. Glenn Stout, director of the WRC, is one of these. "Water policy in Illinois is fragmented," he explains. "However, since this planning effort began, there has been an improvement in coordination. Water users used to have to get three separate permits from the Corps of Engineers, IDOT and IEPA before they could build anything. Now there is a single permit application process. DOC, ISWS, and IEPA all used to do their own monitoring work. Now that research is coordinated to provide a congruent base of data."
Such improvements are welcome. But the broader goals of the task force will be much harder to realize. The task force's mission argues for a water management system that is "socially acceptable." But inoffensive policies are usually ineffective policies; no one fears being bitten by a creature which has no teeth. Further, the task force assigned the job of drafting various parts of the plan to its member agencies. This strategy saves time and duplication, but it also risks perpetuating existing policies.
Role of local governments
Although in many ways the state is the ideal policy maker for water issues, local governments in Illinois still play a vital, if reduced, role. Water supply is still largely a local responsibility, in spite of the trend toward regional systems. And flood control is ultimately a land use question, whose answer (in the opinion of people who have tried other ways) is in the hands of local planning and zoning boards.
Take floods. Flood damages have been rising steadily in Illinois in recent years, largely because of increased building on floodplains. Yet the response to flood damages by property owners and local officials alike is to demand more federal and state flood control projects. Such complaints were most recently heard in Chicago's northern suburbs, where a flood control plan proposed in 1974 but still under study by the Corps of Engineers would have prevented millions of dollars in damages in the summer of 1981.
Controls on building in the flood-plain might have accomplished much the same ends at less cost, and indeed it is IDOT's aim to make sure that people don't (quoting one official there) "build themselves into a problem we have to build them out of." But the state is not eager to expand its regulatory authority over local governments, and local officials have little incentive to do anything as long as state and federal agencies "build them out" of their flood problems.
The State Water Plan Task Force recommends that state and local governments "strengthen" floodplain regulations, but doesn't say how. Not only do people continue to build on floodplains, they typically return to such homes even after being flooded out. Warnings of possible economic loss seem to have little effect either; state officials were shocked to find that only 118 of 1,000 flooded homeowners in Deerfield in 1981 carried flood insurance.
A similar shortsightedness hampers water supply planning. Water supplies are like oil wells: the easiest supplies are tapped first. As old reservoirs silt up, wells dry up, water mains corrode, the costs of providing water rise. The cost of replacing 24-inch pipe can run as high as $200,000 a mile. Energy (mainly for pumping) now makes up an average of 16 percent of the operating budgets of Illinois water systems. And since debt service already accounts for half the budget of the typical Illinois water system, high interest rates add special burdens.
The financial weight of new water supply systems is forcing many Illinois municipalities to act together to support what each of them could not support separately. Inevitably such cooperative ventures pose their own kinds of problems. A National Well Water Association official recently proposed that water-starved Chicago suburbs build deep wells to pump Lake Michigan water below ground to replenish depleted aquifers rather than build new surface distribution systems. IDOT officials pointed out to reporters that such a scheme would require "almost impossible" cooperation among the 50 municipalities involved. Concluded the official, "We all know how people feel about the RTA. How would they feel about the RWA?"
Intergovernmental dustups over water promise to become more frequent. A referendum in which Du Page County voters were to decide whether to issue $85 million in bonds as part of a new Lake Michigan water distribution system was recently canceled by the county board. The cause was feuding over control of the system between the board and the DuPage Water Commission, which is made up of the municipalities involved. Chicago's new western suburbs are resembling the Old West more and more.
Most of the political struggles over water supply systems are attempts to avoid the blame for rising rates. (The new system in Du Page County, for instance, is expected to cost $284 million to build. Paying for it will help push water rates from their present 90 cents per 1,000 gallons to as much as four dollars per 1,000, according to one estimate.) Experts in Illinois agree that water is generally priced much too low. Often rates are too low even to cover routine maintenance costs. Thus the real cost of providing dependable water is disguised by deferring needed capital investments. In effect, elected officials transfer the costs of running their water systems from people voting today to people who won't vote until some distant tomorrow.
When it comes to water projects, Congress can be as parochial as any city hall. The federal government has been a presence in Illinois water policy-making since the U.S. Army Corps of Engineers began clearing shipping channels on the Mississippi River in the 1820s. Washington remained preoccupied with navigation and flood control through the 1960s. The principal change in such projects over those 140 years was their scale; the agency which began by pulling logs out of rivers eventually became able to reroute them and remodel their valleys.
It was not until the 1970s that Congress took an interest in water quality issues as keen as its historical interest in water quantity issues. A new environmental consciousness embodied itself in the chapters of a half-dozen new water laws passed in that busy decade. Congress first passed amendments to the existing federal Water Pollution Control Act in 1972. They were followed by the Safe Drinking Water Act of 1974, the Water Resources Act in 1974, the Resource Conservation and Recovery Act of 1976, a Clean Water Act in 1977, and the Comprehensive Environmental Response, Compensation and Liability Act of 1980.
There had always been a certain philosophical necessity in the federal role in water policy. Water by its nature is a form of interstate commerce. Like many arranged marriages, the union of state and federal bureaucracies—each with the same general aims but differing in legal responsibilities, resources, history and clientele—has been more a matter of convenience than love. The federal half came with a generous dowry, however. Traditional water projects tend by their nature to be expensive, and only Washington had the money to undertake so many of them. A flood of loans and grants gushed from Washington to the states in the 1970s, and not just for dams and levees and sewage treatment plants. Federal money largely built an extensive new bureaucracy to manage it, with grants for planning, enforcement and research.
The states, including Illinois, often complained about the inflexibility, the irrelevance, the arrogance of their federal benefactors' rule. Nonetheless, most regarded it as a bargain well made. Illinois, for example, was able to have its water projects and balance its budget too. Operating expenditures at IEPA (of which about a third is spent on water) rose by 300 percent between 1971 and 1979. In 1971, federal funds accounted for only 7 percent of the total; by 1979 the feds' share had gone up to 47 percent. Increases in state funding for the Illinois State Water Survey during the 1970s were modest, with the result that today more than 60 percent of its research work is paid for by outside money. (Notes one survey staffer, with scant exaggeration, "The Survey is really funded by the USEPA.") The same situation obtains at the University of Illinois's Institute of Environmental Studies in Urbana, where roughly 75 percent of its budget comes from contracts with federal agencies.
The IEPA admits in its current water pollution control plan that "the realization of this work plan is heavily dependent on federal resources." The same could also be said by most of the state's water agencies. Such dependency has its risks, however. When Ronald Reagan pledged to restore to the states responsibility for running federal programs, the states applauded. They have been less enthusiastic about accepting the responsibility for paying for them. The Reagan administration's budget cuts were an inevitable result of his "new federalism." "New Federalism" has been variously defined, usually according to the temper of the nation's governors and mayors. Some programs would be cut altogether; others maintained but with funding responsibilities shifted to the states. According to one recent version, for example, responsibility for a total of $2.9 billion in money for water and sewer grants and loans would be shifted from Washington.
Whether such budget reforms flow from the doctrine or the doctrine is merely a pretext for budget cuts is arguable, even if the effects on Illinois's water establishment is not. Either way the budget cuts signal a revolution not just in the ways certain public services are funded, but the way they are thought about. The Reagan administration has insisted that the costs of things like waterways and sewage plants be more fully borne by those who benefit most directly from them. It has asserted the primacy of the national economic interest over regional interest, and of energy and economic development over the environment as criteria in evaluating water projects. And it has hinted that certain services long regarded as the imperative of public bodies might be better and more economically provided by private entities.
Effects of budget cuts
One need not be a full-blooded Reaganite to agree that very often government has indeed been the problem in water policy-making. For example, federal grants and subsidies to local governments for things like water supply projects distort demand by making water cheaper than it ought to be. Accordingly, funds for such projects from such agencies as the FmHA are now subject to tighter controls. In Pike County, a $3 million expansion of a rural water system has been postponed because of the lack of grant money, and low-cost FmHA loans of the sort which brought piped water to many an Illinois subdivision are now available only for projects which serve poor areas or are needed to correct a public health problem.
Congress has not agreed to all of Reagan's cuts. The Illinois Water Resources Center, for one example, wasn't funded at all under Reagan's proposed 1982 budget, but Congress restored funding for it and the other state centers that were established in 1964 under part of the federal Water Resources Research Act. Says WRC director Stout, "Congress still realizes there is a pending water crisis, and that we need money to prepare for it. But the White House seems to think that water is a local problem."
The same lament can be heard, in varying tones, from agency after agency. USEPA's proposed 1983 budget for water quality programs is down 40 percent from 1981 spending. Federal spending for new sewage treatment plants in Illinois had already slipped to $98 million in 1981 after a high of $363 million in 1975, and Reagan's proposed cuts are expected to result in the suspension of 50 projects in the state.
The need to set priorities among projects is obvious; there are literally hundreds of projects in Illinois being planned, designed, or built. The local effects of federal cuts can be seen in Decatur. That city is facing IEPA sanctions because of inadequate sewer capacity. An expansion has been proposed, one phase of which alone would cost $57 million. But Congress in its compromise budget bill of 1981 agreed to reduce the federal share of such projects begun after 1984 from its present 75 percent to 55 percent. The difference, as one Decatur sanitary official told reporters, is a "whopping amount of money."
The state has had its share of money troubles in recent years too, of course. Illinois's commitment to clean water, both fiscal and administrative, somewhat antedates that of Washington. As early as 1970 Illinois set about funding its own sewage treatment plants, for instance, through the $750 million in bond funds authorized under the Anti-Pollution Bond Act. To date that act has helped build more than 200 treatment projects. But most of that $750 million has already been obligated, and in any event (quoting IEPA) "the fiscal position of the State required curtailment of bond obligations [for the 1983 budget]."
General revenues are just as scarce. For example, in the fall of 1979 the Illinois Department of Agriculture was made responsible for implementing Illinois's USEPA-approved soil erosion control program. But a cost-sharing program designed to get farmers to try reduced tillage methods was cut. Soil conservation professionals insist that more money is also needed to treble local conservation staffs. Lacking support for flat grants, the Illinois Association of Soil and Water Conservation Districts lobbied for adoption of a "risk share" program which would guarantee farmers against any losses from trying reduced tillage methods. The General Assembly refused even this modest program, pleading lack of funds. So parsimonious have federal and state lawmakers become that the IASWCD has established a $150,000 private endowment intended to fund conservation staff.
Finding a balance among what is necessary, what is desirable and what is affordable is the soul of good policy. It seems fair to say that the search for that balance has led Congress down a few dead ends. Consider pollution. It is probably not accurate to insist that Congress in the 1970s committed the U.S. to spend more than it could afford to clean up its water. It just seems that way because governments in 1982 can afford to spend so much less than they could in 1972.
Inevitably, the disputes over pollution control strategies are being increasingly argued in economic terms, specifically their costs and benefits. There is a point at which it costs more to clean a stream than it is worth, whether that worth is measured in infants who don't die prematurely or fish that otherwise couldn't spawn.
Nitrates are a case in point. The IPCB has set a limit on the amounts of nitrates allowable in Illinois drinking water. Nitrates enter Illinois water from farm fertilizers or feedlots, as well as natural sources. Acted upon by the human digestive system, they can be transformed into nitrites (the cause of hemoglobin anemia or "blue baby" syndrome) or nitrosamines (a suspected carcinogen). Many downstate community water systems routinely exceed this limit, especially in the spring.
Nitrates can be removed, but only at great expense. Rather than require removal, IEPA relies on public warnings when nitrate levels get too high. Officials point out that the risk to infants—a small population in more ways than one—is easily reduced by the temporary use of bottled water. Among adults, the incidence of stomach cancers associated with nitrosamines has been declining. Warnings and common sense are only slightly less effective protectors of the public health than elaborate removal requirements and vastly cheaper.
Many clean water standards are precautionary, based on still-unsubstantiated assumptions of risk. The result is that local water officials must often weigh hypothetical, long-term risks to public health against the short-term risks to the public pocketbook. In 1978, when the USEPA was holding hearings on a proposed new standard limiting trihalomethanes in drinking water, Springfield's water commissioner testified that such a standard would increase his system's revenue needs by 25 percent and (assuming EPA's own estimates of the links between THM and cancer were accurate) would prevent one cancer tumor every three years at a cost of roughly $900,000 per tumor. Even by the standards of the day, that is preventive medicine of the most egregiously expensive sort.
Costs have always been a factor in pollution planning in Illinois. One of the criteria set forth for wastewater treatment in the seminal 1970 Illinois Environmental Protection Act was "economic reasonableness." The federal largesse of the 1970s, however, kept state and local officials alike busy thinking up ways to spend money, not save it.
With the scaling back of public budgets has come a proportionate scaling back of official ambitions for the environment. The current IEPA water pollution control plan carefully describes its mission as realizing the best water conditions possible "consistent with the social and economic needs of the people"—a far cry from the "zero discharge" promises of the 1970s.
The future of water policy
Economics is behind the most significant revision of clean water rules since the state and federal acts were passed a decade ago—IEPA's gradual conversion from general pollution standards which now apply to most of the state's waters to site-specific standards based on use. Extensive public hearings were begun in the late 1970s which sought to establish the most feasible uses for 123 stream "segments" around Illinois. Streams running through unpopulated rural areas, for example, might be made to support more fish, but such cleanup efforts would be irrelevant if no one near them wanted to fish. In urban areas, in contrast, streams now befouled might be made subject to stiffer cleanup standards in order to upgrade them into badly needed recreational resources.
The IEPA insists that redefining its regulations from "a localized point of view" will "offer the opportunity to optimize water pollution control resource expenditures." Example: After three years of complaints, the Northeastern Illinois Planning Commission agreed that Lake County wouldn't have to spend $1.4 billion on a new sewer interceptor to meet biochemical oxygen demand (BOD) limits because there simply is not presently a BOD problem in Lake Michigan.
In retrospect it is apparent, then, that Congress spent millions of dollars in the 1970s solving problems which didn't exist, and in the process often created new ones. It is for these reasons that the retrenchment in spending on large, centralized, automated pollution control facilities does not strike some experts as wholly bad news.
John Pfeffer, an environmental engineer at the U of I's Department of Civil Engineering at Urbana, believes that the easy availability of federal grants "made it too easy for municipalities to meet the regulations" for wastewater treatment; as a result, he says, "no one questioned whether those regulations were wise."
Pfeffer cites the example of a $20 million tertiary treatment plant built in Champaign-Urbana which led to water quality improvements worth no more than $10,000 to local fishermen. "You get a lot more improvement in water quality for the money," Pfeffer believes, "if you spend it instead on erosion control or controlling urban storm water runoff."
It may be that in the 1980s the questions which heretofore have been asked mainly by environmentalists—namely, how to dispose of sewage in less capital-intensive, energy-intensive, land-intensive ways—will be asked by sanitary engineers and budget officers. Such technologies exist, in the form of lagoons, land treatment systems, improved septic tanks, even waterless composting home toilets. What has been lacking is a commitment to their use.
Ultimately (according to theory at any rate) it will be the public who will decide who will do what with water, where and why. Michael Witte, director of DENR, spoke to that point at his department's 1982 annual conference entitled, "Competition for Water: Can Illinois Stay Afloat?" Witte noted, "Many of the solutions reside in the political process," although he cautioned, "This is not to say that those solutions necessarily reside in government agencies." Indeed, one can infer from the 1980 national election results a certain expression of political will by voters on resource issues such as water.
The question is, how informed are the choices which cumulatively comprise resource politics? Witte notes of water that the "public perception of the crisis is low." The limits of public resources have been recognized, even if their effects are not yet widely appreciated. But of the even more pressing limits of technology, and of nature, little is known outside a coterie of experts.
Betty Reed, the Lake County legislator who is chairman of the Illinois Water Resources Commission, made much the same point to the same audience. The General Assembly has not reformed Illinois water policy, she explained, because most of its members "do not know there is a problem yet." Legislators, like their constituents, remain resolutely crisis-oriented. Agency coordination, more rational funding, better data can all enhance the making and carrying out of water policy. But major policy innovations themselves, one suspects, await some catastrophe. Droughts and smelly wells and epidemics, like hangings, concentrate peoples' minds wonderfully. As Illinois Times environmental reporter Harold Henderson wrote about Wilsonville, "The political heat from the struggle . . . has helped prod the usually torpid Illinois legislature into [passing] some of the toughest waste control bills in the U.S.—bills which could not even get out of committee before Wilsonville erupted."
Every state, it seems, needs its Love Canal. ●
Sidebar: Water: Who owns it?
Naturally, the first question to be asked about water is, "Who owns it?" If the law is a clue to public purpose, then the public purpose for water is very confused. Water "ownership" in water-rich states like Illinois is based on traditional notions of riparian rights. Any person owning land along a natural watercourse has the right to take water from that watercourse for his own use as an incident of land ownership. All other owners of land along that watercourse enjoy equal rights of access, however, with the result that they are all limited to making reasonable use of the resource.
"Reasonable use" in such cases has been defined in a vast body of court cases. Who is a riparian landowner is fairly straightforward. (There are a few exceptions; Illinois law grants access rights to municipalities and certain other public bodies even if their territories do not abut a watercourse.) The issue of how much water such landowners may reasonably withdraw is much less clear. Riparian water law by its nature is exploitative. As one Illinois state agency describes the problem, "New users can tap a source until the supply is inadequate for all."
However, the exercise of riparian rights is constrained by assorted Illinois statutes. Under the Rivers and Lakes Act of 1911, for instance, the legislature asserted the state's power to protect the public interest in the use of "public waters." The problem is that no one quite agrees on what "public waters" are. Several other states have defined "public waters" in the process of spelling out non-riparian users' rights to water and setting priorities of use during droughts. Most of the tests of Illinois law have been made to establish an individual's right to water; the powers public bodies enjoy to regulate water use under the law remain much less clearly defined.
The legal waters are muddied even further by the fact that roughly half of Illinois's population is subject to a water allocation system similar to those in the water-poor Western states. Under terms of a 1967 U.S. Supreme Court decree, the amount of water which may be withdrawn from Lake Michigan for all purposes is strictly limited. That court decree also places conditions on the use of that water by municipalities, such as the adoption of water conservation plans.
The Lake Michigan allocation system is administered by a state agency (the Illinois Department of Transportation, or IDOT) and some experts see in this so-far anomalous arrangement a precedent for the rest of Illinois. Water conflicts have not risen to the pitch they sometimes attain in the West, mainly because there has usually been enough water in Illinois to go around. But riparian law makes certain conflicts inevitable in an era of increased demand for a dwindling resource. A city which builds a reservoir on a stream has few protections against poaching by other riparian owners. And the use of groundwater need not even be reasonable under the law. Farmers in Saline and Gallatin counties were appalled to learn that new municipal wells proposed during that region's drought in 1981 might suck their own wells dry, even though the new wells would be sunk nearly two miles away—and that under Illinois statutes no one would be liable for the loss.
The issue is not fully resolved even in the West. In New Mexico, for example, water is considered public property, while in neighboring Texas it is still classed as private property. It is a point of relevance to more than just a few southern Illinois farmers. New Mexico is suing Texas to stop the appropriation by El Paso of groundwater which underlies Las Cruces, across the state line. The states of Missouri, Iowa and Nebraska have sued to stop North Dakota from selling Missouri River water to Wyoming for a coal slurry pipeline.
The ownership of water could soon be an issue in other parts of the wet Midwest, where water is increasingly seen as a weapon in the economic wars with the Sunbelt. There has been talk by some governors of exporting water, a la OPEC. Gov. James R. Thompson, who has concluded that it is wiser for Illinois to import new water-based industries rather than to export its water, is not among them. ●