BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

IN THE MATTER OF:

)

)

WATER QUALITY STANDARDS AND

)

EFFLUENT LIMITATIONS FOR THE

)

R08-9

CHICAGO AREA WATERWAY SYSTEM

)

(Rulemaking – Water)

AND THE LOWER DES PLAINES RIVER:

)

PROPOSED AMENDMENTS TO 35 ILL.

)

Adm. Code Parts 301, 302, 303, and 304

)

NOTICE OF FILING

To:

John Therriault, Clerk

Illinois Pollution Control Board

James R. Thompson Center

100 West Randolph St., Suite 11-500

Chicago, IL 60601

Marie Tipsord, Hearing Officer

Illinois Pollution Control Board

James R. Thompson Center

100 West Randolph St, Suite 11-500

Chicago, Il 60601

Deborah J. Williams, Assistant Counsel

Stefanie N. Diers, Assistant Counsel

Illinois Environmental Protection Agency

1021 North Grand Avenue East

P.O. Box 19276

Springfield, IL 62794-9276

Persons included on the attached

SERVICE LIST

PLEASE TAKE NOTICE that I have today filed with the Office of the Clerk of the

Pollution Control Board

PRE-FILED TESTIMONY OF DR. WILLIAM VAN BONN

on

behalf of Environmental Groups, Environmental Law and Policy Center, Natural Resources

Defense Council, Prairie Rivers Network, Sierra Club – Illinois Chapter, Friends of the Chicago

River, and Openlands, a copy of which is herewith served upon you.

Respectfully Submitted,

Albert Ettinger

Senior Staff Attorney

Environmental Law & Policy Center

35 E. Wacker Dr. Suite 1300

Chicago, Il 60601

DATED: August 4, 2008

(312) 795-3707

Electronic Filing - Received, Clerk's Office, August 4, 2008

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BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

IN THE MATTER OF:

)

)

WATER QUALITY STANDARDS AND

)

EFFLUENT LIMITATIONS FOR THE

)

R08-09

CHICAGO AREA WATERWAY SYSTEM

)

(Rulemaking – Water)

AND THE LOWER DES PLAINES RIVER:

)

PROPOSED AMENDMENTS TO 35 ILL.

)

ADM. CODE PARTS 301, 302, 303, AND 304

)

Testimony of Dr. William Van Bonn

John G. Shedd Aquarium

(August 4, 2008)

I.

Introduction

My name is Dr. William Van Bonn, and I am Senior Director for Animal Health

at the John G. Shedd Aquarium. I am testifying today in support of the regulation

proposed by the Illinois Environmental Protection Agency (IEPA) to strengthen water

quality standards for the Chicago Area Waterways System (CAWS) and Lower Des

Plaines River (LDPR).

Scientists and scholars tell us the Great Lakes basin was created by glacial

activity over 10,000 years ago. The glaciers left in their wake a magnificent fresh water

ecosystem that contains approximately 20 percent of the globe’s total fresh water

resources. The Great Lakes basin, including the CAWS and LDPR, remained un-

impacted by human activity for nearly ten millennia.

As people settled in the Chicago area, they manipulated and changed the

waterways until significant environmental harm to these unique aquatic systems was

obvious to the casual observer. One of the most notable human influences on the river

systems was the massive influx of effluent from wastewater treatment plants. In addition

to reversing the direction of the Chicago River, we introduced dramatic stressors by

Electronic Filing - Received, Clerk's Office, August 4, 2008

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altering the waters’ natural cycle and flow, and installing massive infrastructure to handle

large concentrations of biological waste. Industrial facilities situated along our rivers

have also affected the temperature and composition of these river systems.

The stressors caused by altering our waterways can result in serious health

implications for the entire ecosystem, from microscopic organisms to humans. People

are the only ones that have the choice and capacity to direct and implement change to

restore balance to the CAWS and LDPR. The proposed rules mandate that Metropolitan

Water Reclamation District of Greater Chicago (MWRD) dramatically reduce pathogens

that it discharges into our waters by disinfecting approximately 1.17 billion gallons of

effluent daily at its Calumet, Stickney and North Side wastewater treatment plants.

Industrial facilities will be required to lower the temperature of their effluent to increase

the amount of oxygen in the water for fish and other aquatic life. When evaluating these

and other proposed changes, it is important to consider the benefits not only to a

particular species, but to all life dependent upon the waterways.

II.

Qualifications

I was raised in, on and around the lakes, ponds and rivers of the state of Michigan.

I graduated from the College of Veterinary Medicine at Michigan State University in

1986. While employed in traditional private practice, my aquatic interests led me in 1991

to enroll in an inaugural Envirovet program – an intensive, in-residence short course

regarding aquatic animal medicine and environmental toxicology.

Following this experience, I was commissioned into the U.S. Army Veterinary

Corps, and assigned duty at the U.S. Navy’s Marine Mammal Program in San Diego. I

spent four years on active duty, followed by an additional eleven years as a civilian with

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the program. My last position at that location was as Managing Veterinarian for

Research and Advanced Clinical Technologies.

In 2005, I accepted the position of Senior Director for Animal Health at the John

G. Shedd Aquarium in Chicago, coming home to the Great Lakes. As part of my

responsibilities, I oversee the preventative medicine program for more than 25,000

individual animals, with over 2,500 species housed in intensively managed aquatic

systems.

Overall, my duties and professional interests are focused on preventative

medicine and enhanced clinical veterinary services for aquatic animals under human care.

I am Past-President of the International Association for Aquatic Animal Medicine, an

elected member of the World Aquatic Veterinary Medical Association executive board,

and invited member of that association’s Ethics and Governance Committee. I have

authored numerous scientific articles, abstracts and several book chapters.

I am founding faculty of Marvet, a short course in marine veterinary medicine

regarding both animals under human care and free-ranging populations. I hold Adjunct

Clinical Assistant Professor status at both the University of Illinois’ College of

Veterinary Medicine and Northwestern University’s Feinberg School of Medicine. I also

serve as client mentor under a master agreement with the Robert R. McCormick School

of Engineering and Applied Science at Northwestern University.

III.

Background: Healthy Ecosystems Require Balance

Optimal health is all about balance. Natural systems are complex and subject to

multiple factors. All wildlife share their immediate environment with organisms that

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may be detrimental to their health if conditions “tip the balance” in favor of one species

over another.

Discharging over a billion gallons of effluent into the CAWS every day influences

this balance, and may place the health of resident wildlife at risk. This massive amount

of effluent can lead to a significant influx of pathogens in the waterways, increasing the

opportunity for disease to strike. From this perspective, it is not hard to appreciate how

disinfecting wastewater will lead to a more natural, balanced healthy ecosystem.

IV.

Potential Effects of Pathogens in Effluent from Wastewater Treatment Plants

on Wildlife Dependent Upon the CAWS and LDPR – the Otter Example

The Shedd Aquarium hosts both sea otters (

Enhydra lutris

) and river otters (

Lontra

canadensis

) at its facility. Otters attract a lot of attention. They are often characterized in

Zoological and Aquarium facilities as “charismatic mustelids.” Most of us are familiar

with the devastation associated with the Exxon Valdez disaster in 1989. Sea otters were

among the most visible and publicized animals negatively impacted by that event.

During the follow up to this incident, specific programs were established to better

survey and understand the sea otter and its health status. As a result, a significant amount

of data has been collected and published in scientific literature. Of note, studies found

that several parasites introduced into the environment by human activity, specifically

effluent from wastewater treatment plants, are recognized as the most common causes of

disease and death in free ranging sea otters off the California coast.

Sea otters are closely related to North American River Otters, which are indigenous

to the CAWS and LDPR. Although river otters once flourished in the region, they were

heavily impacted by human exploitation, such as fur trade, loss of habitat and degraded

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water quality. Kimber, Kollias,

Infectious and Parasitic Diseases and Contaminant-

Related Problems of North American River Otters (Lontra Canadensis): A Review

, J Zoo

and Wildlife Medicine, 2000: 31(4):452. In the late 1970’s, the Illinois Department of

Natural Resources (IDNR) estimated that fewer than 100 river otters remained statewide.

In 1989, they were placed on the Illinois state-endangered species list.

To help reverse this trend, in 1994, IDNR reintroduced 300 river otters from

Louisiana to wetlands in Illinois. Reported results have been promising. River otters

were delisted in Illinois in February 2004. According to the Forest Preserve District of

Cook County, a river otter was sighted in December 2007 in the Chicago River near the

back steps of the Lyric Opera House. Their presence is important because such fish

eating wildlife are environmental sentinels, reflecting the water quality and aquatic

habitat in their ecosystem.

See e.g.

Kimber, Kollias,

Infectious and Parasitic Diseases

and Contaminant-Related Problems of North American River Otters (Lontra

Canadensis): A Review

, J Zoo and Wildlife Medicine, 2000: 31(4):465-67. If we want

otters and other native species to successfully return to the area and once again be a part

of our life experience, it is important to understand what organisms threaten their health,

and how we can avoid needlessly tipping the balance in favor of those threats.

A.

Toxoplasmosis

Toxoplasma gondii

, a widely studied protozoan parasite found in cat feces, has

caused toxoplasmosis in sea otters. “Warmblooded” animals, such as otters, that ingest

the infective parasite, can develop brain lesions, seizures, severe depression and death.

Colleagues at the Wildlife Health Center at the School of Veterinary Medicine,

University of California at Davis (and others) concluded the parasite was most likely

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transported by freshwater runoff into the marine ecosystem. Conrad et al., Int J Parasitol,

2005 Oct; 35(11-12):1155-68; see also Miller et al., Int J Parasitol, 2008 Feb 26 [Epub

ahead of print]. Scientists involved in these studies have expressed that sea otters are

more vulnerable to parasites and bacteria, such as

Toxoplasma Gondii

because pollution

and other disturbances have weakened their immune systems.

Although less is known about toxoplasmosis in river otters, a study in North

Carolina showed that 45% of 103 live trapped river otters had antibodies for

Toxoplasma

gondii

, showing that river otters are susceptible to this parasite. Kimber,

Serologic Survey

for Toxoplasmosis in River Otters

, J Wildlife Diseases, 1997; 33(3): 649-652.

B.

Giardia and Cryptosporidium

“Environmental pollution with human and domestic animal fecal material is

recognized as a potential pathogen pathway for wildlife infections with

zooanthropomorphic protozoan parasites such as

Giardia

and

Cryptosporidium

; such

infections can put wildlife populations at risk.” Applebee, et al., Giardia

and

Cryptosporidium

in mammalian wildlife – current status and future needs

(Giardia

and

Cryptosporidium

in mammalian wildlife

), TRENDS in Parasitol

, 2005 Aug; 21(8):370.

“To date, Giardia of human origin appears to be the main source of water contamination

and as such may impact negatively on ecosystem health leading to infections in aquatic

wildlife.” Thompson,

The zoonotic significance of molecular epidemiology of Giardia

and giardiasis

” Vet Parasitol 2004;126:17. In determining the effect on sea otters, the

study found that, “in addition to the impact that chemical pollution has on marine

mammal immunocompetency, the discharge of agricultural waste and raw or improperly

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treated sewage can introduce pathogens into the environment.” Giardia

and

Cryptosporidium

in mammalian wildlife

, TRENDS in Parasitol, 2005 Aug; 21(8):374.

“Both Giardia cysts and Cryptosporidium oocysts have been detected in marine

water samples from areas of treated-sewage disposal.”

Id

. Although few studies have

been done to investigate infection of Giardia and Cryptosporidium in river otters,

Cryptosporidium and Giardia oocysts have been detected in marine-foraging river otter

fecal samples. “Four of 57 or 7% of river otters in the marine waters of the Puget Sound

region were shedding Cryptosporidium sp. at the time of sampling, and 11 of 57 or 19%

were shedding Giardia sp. in Washington.” Gaydos, et al., Cryptosporidium

and

Giardia

in Marine-Foraging Otters

, J Parasitol, 2007 Feb; 93(1):200.

C.

Bacteria: Salmonella, Streptococcus, and Mycobacteria-Tuberculosis

Otters in reintroduction programs have manifested bacteria-associated problems

“on the basis of prevalence and pathogenicity, includ[ing]

Clostridium perfringens

-

related enterotoxemia,

Streptococcus

species related wound abscesses [otherwise known

as Strep],

Salmonella

species-related enterotoxemia, and

Mycobacterium

species-related

exposure in captivity.” Kimber, Kollias,

Infectious and Parasitic Diseases and

Contaminant-Related Problems of North American River Otters (Lontra Canadensis): A

Review

, J Zoo and Wildlife Medicine

, 2000: 31(4):459. Species of Salmonella have been

isolated from wild and captive river otters throughout the United States. “Although

infected animals may be asymptomatic, salmonellosis can be fatal in North American

river otters.”

Id.

According to the Kimber and Kollias study, “otters are susceptible to

Mycobacterium avium, Mycobacterium bovis, and Mycobacterium Tuberculosis var.

hominis.

Tuberculosis was listed in necropsy reports from 4 of 88 unidentified zoo

Electronic Filing - Received, Clerk's Office, August 4, 2008

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otters.…” Tuberculosis due to

M. Tuberculosis

var.

hominis

was reported in a European

river otter from a Swedish zoo. Kimber, Kollias,

Infectious and Parasitic Diseases and

Contaminant-Related Problems of North American River Otters (Lontra Canadensis): A

Review

, J Zoo and Wildlife Medicine, 2000: 31(4):461.

I am not aware of any similar published studies concerning the CAWS and LDPR.

However, river otters (as well as humans) are clearly threatened by many of these same

pathogens.

V.

The Source – the Origin of Organisms Found in Effluent

Pathogens in effluent from wastewater treatment plants are clearly a global threat

to public health. Disease outbreaks are often associated with contaminated water.

Ingesting pathogens is arguably one of the most effective and common routes of

contracting and transmitting disease. Pathogens originate from human and animal feces

(both wild and domestic) in partially treated sewage and terrestrial waste carried in

stormwater runoff.

According to MWRD, it has tested for several of the pathogens discussed above,

and has verified their presence in effluent discharged from its wastewater treatment

plants. Of note, MWRD reported finding enteric viruses,

Cryptosporidium Parvum,

Giardia lamblia

, Salmonella,

Pseudomonas aeruginosa, Escherichia coli

and

Enterococci. Since cat feces in discarded litter has been found to contaminate

wastewater, the effluent discharged by MWRD’s three plants could also pose a risk of

toxoplasmosis to resident river otters in the CAWS and LDPR. For a broader viewpoint,

Yan and Sadowsky with the University of Minnesota recently wrote an excellent review

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9

of fecal bacterial sources in waterways, and methods to determine these sources. Yan

and Sadowsky,

Environ Monit Assess

(2007) 129:97-106.

VI.

Conclusion

Health is all about balance. Natural waterways are not sterile. They are teeming

with trillions of organisms that potentially threaten the health of other native species

when conditions tip the natural balance in their favor. Dr. Mark Jerome Walters, a

veterinary colleague and trained journalist, eloquently describes the human influence on

the natural world and resulting disease in his book, Six Modern Plagues and How We are

Causing Them Shearwater Books, Washington, DC, USA, 2003, ISBN: 155963992X .

Dr. Walters discusses the rate of change in the natural environment today as result of

human activities. In his words, “…microscopic predators are taking full advantage of the

instability.”

If effluent from wastewater treatment plants is not disinfected, it will contain

pathogens that potentially cause disease in both wildlife and humans. Wastewater that is

collected, concentrated and discharged by the billions of gallons into the CAWS

artificially tips the balance in their favor. By controlling the level of pathogens in our

wastewater to what is found in a healthy river system, we can minimize stressors on

resident species. Human beings are uniquely positioned to exercise this control.

Submitted by: Dr. William Van Bonn

Date: August 4, 2008

Senior Director for Animal Health

John G. Shedd Aquarium

Electronic Filing - Received, Clerk's Office, August 4, 2008

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1

Curriculum Vitae

William Van Bonn, D.V.M.

2511 Caddy Street

Senior Director for Animal Health

Flossmoor, IL 60422

John G. Shedd Aquarium

708-922-2866

1200 South Lake Shore Drive

Chicago, Illinois 60422

312-692-3387

EXPERIENCE:

March 2005- Present, John G. Shedd Aquarium, Chicago, Illinois 60605, Animal Health

Department, Senior Director.

Supervisor: Jeffery R. Boehm, DVM. Senior Vice President,

Conservation and Veterinary Services, 312-692-3232. Serve as team lead for daily operations of

three divisions, Environmental Quality, Microbiology and Veterinary Services. Develop and

direct contemporary comprehensive preventive medicine program designed to reduce animal

morbidity, mortality and the cost of doing so. Provide management and leadership oversight to

three Division Managers and eleven direct reporting team members. Serve as department liaison

to other departments and extramural program leads to include University of Illinois Zoological

Pathology Program and the Chicago Zoo and Aquatic Animal Residency. Mentor junior clinical

staff, visiting veterinary student externs, interns and residents. Focus on prevention,

advancement and excellence.

October 1998- September 2005, U.S. Navy Space and Naval Warfare Systems Center

(SPAWARSYSCEN) San Diego, CA, 92152-5000, Code 2351 as DP-0701-03 (GS-14

equivalent) Scientist/Veterinarian.

Supervisor: Mr. Patrick Moore, SPAWARSYCEN San

Diego Code 2351, 619-553-0888. Provided state-of-the-art clinical care to all Navy marine

mammals in San Diego as well as numerous continental United States (CONUS) and outside the

continental United States (OCONUS) animal movements. Interacted with host-nation

Convention on International Trade in Endangered Species (CITES) Management Authorities

enabling Navy Marine Mammal Program (NMMP) participation in NATO sponsored training

exercises. Designed, procured, outfitted and deployed multiple mobile marine mammal clinics

(3MC) that are now standard of care for veterinary support to deployed NMMP animals.

Directed completion of custom relational database for all aspects of medical record keeping.

Drafted Memorandum of Understanding (MOU) with Virginia-Maryland Regional College of

Veterinary Medicine’s Center for Corporate and Government Veterinary Medicine establishing

veterinary student preceptorship program at NMMP. Served as Managing Veterinarian for

Research and Advanced Clinical Technologies. Established research project to conduct first

formal infectious disease risk assessment for NMMP and development of specific DNA vaccines

against identified threats to animal health. Served as Principal Investigator on project, Research

Advisor to three Post-Doctoral Associates (two of whom have been hired by 235) and secured

over $ 1 million in extra and intramural funding over the life of the project. Acted as Technical

POC on “VetLab” Technical Direction Letter (TDL) under existing animal care contract.

Intermittently served as acting Branch Head 2351.

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2

November 1995- September 1998, Self-employed and Upstream Associates, P.O. Box 60680

San Diego, CA 92166. General Partner

, consultant specializing in advanced clinical care of

marine mammals under contract to U.S. NMMP. Established accounting methods, invoicing and

Contract Deliverables Requirements List methodology in support of contract with NMMP.

Wrote and conducted annual training course “Concepts in Marine Mammal Medicine” offered to

upperclassmen veterinary students and recent graduate veterinarians.

December 1991- October 1995, Captain (0-3), U.S. Army Veterinary Corps, with duty at

Naval Command, Control and Ocean Surveillance Center, RDT&E Division (NRaD).

Chief, Clinical Veterinary Services.

Supervisor: Dr. Sam H. Ridgway, SPAWARSYSCEN

Code 235, 619-553-1374. Sole active duty military veterinarian providing clinical care to all

Navy animals housed in San Diego and on over 50 animal transports to both CONUS and

OCONUS locations with zero animal casualties. Provided direct veterinary input to procedures

development and direct animal care during first ever Shipboard Forward Deployment of Navy

marine mammals. Completed first annual Command DoD Animal Use and Cost Survey and

ensured command readiness for DoD and Navy IG inspections of animal use facilities. Served as

advisor to commanding admiral Space and Naval Warfare Systems during congressionally

directed negotiations with the Humane Society of the United States. Wrote MOU between

commanding officer NRaD and District Commander, Veterinary Services, Fort Jackson for

provision of veterinary care to Navy animals assigned to Explosive Ordnance Mobile Unit Six

(EODMU6) in Charleston, S.C. Wrote first program description leading to successful

accreditation by the Association for Accreditation and Assessment of Laboratory Animal Care

International (AAALAC) in accordance with DoD Directive 3216.1 of 17 April 1995.

Established monthly all hands “Animal Care Briefs” training that has now become Division

standard to meet mandatory training requirements.

September 1988- December 1991, Professional Veterinary Hospitals of America, Inc. Chief

of Staff Veterinarian at Farmington Hills, Michigan location.

Supervisor: Dr. Andrew

Dworkis. Served as lead clinical veterinarian in busy companion animal facility. Responsible for

hospital productivity and oversight to staff of six veterinary technicians and affiliated clerical

personnel.

June 1986- July 1988. Dr. R.J. Keeran, D.V.M., P.C. New Hudson, Michigan. Associate

Veterinarian.

Provided full spectrum of medical and surgical services for referral equine

surgical practice including emergency care and ambulatory services. Established arthroscopic

surgical capability for practice. Established Herd Health Program for practice.

EDUCATION:

Doctor of Veterinary Medicine, with high honor, June 1986 from Michigan State University

College of Veterinary Medicine, East Lansing, Michigan 48824.

Bachelors of Science in Veterinary Science, with high honor, June 1984 from Michigan State

University. East Lansing, Michigan 48824.

OTHER TECHNICAL TRAINING:

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