Re: Propose4 amendments to dissolved oxygen standard (R04-25)

NOV 05 20

Dorothy Gunn, Clerk

~STATE

OF ‘LL,.Nf~

Illinois Pollution Control Board

0UUtIOfl

Controg ~j!S

James R. Thompson Center

100 W. Randolph St.

Suite 11-500

Chicago, IL 60601

Dear Ms Gunn,

In April 2004, the illinois Association of Wastewater Agencies (JAWA) submitted a proposal to the Ilhnois Pollution

Control Board proposing to lower the dissolved oxygen cnteria from

0 mg/I to 3

mg/I dunng the months of July

through February I am writing you to ask that you reject IAWA’ s request The proposed reduction in dissolved

oxygen criteria wiji not improve the condition of Illinois streams such as the Fox River, rather

will have the

opposite effect by further degrading water quality and harming aquatic life The current Illinois standard for

dissolved oxygen follows U S Environmental Protection Agency guidelines andpast scie~itificstudies do not

support a lower standard. Therefore, the Illinois Pollution Control Board should reject the proposal to lower

dissolved oxygen standards.

In 2002, the Fox River was categorized as impaired by the Illinois Environmental Protection Agency. One of the

reasons for the river’s impairment is low dissolved oxygen. The effects of low dissolved oxygen in rivers such as

Fox are well documented. At extremely low çxygen levels, fish kills result. Low dissolved oxygen levels in the Fox

River will also negatively impact fish species That ~pa1v~’n

in late sumnier, ands~bftfishs~chas smallmouth bass are

sensitive to low dissolved oxygen levels. Freshwater mussels and other aquatic macroinvertebrates are also

negatively affected by low dissolved oxygen. The aquatic fauna in the Fox River is already threatened by

deteriorating water quality with several species becoming extirpated from the watershed in recent decades. Lower

dissolved oxygen will only exacerbate the problems the Fox River faces.

Robert Schanzel made the following comments on behalf of the Illinois Chapter of the American Fisheries Society

regarding the proposal: “The Illinois Chapter of the American Fisheries Society does not support relaxing illinois’

existing dissolved oxygen standards because insufficient evidence~.is-availab.lethat.suchaction will not have serious

and irrevocable consequences for the state’s aquatic biota

that is, the science does not support the proposed

changes” Schanzel also states “To lower quality standards now, would not serve the best interests either of Illinois’

citizens or it’s aquatic resources.”

The condition of the Fox River is impacted by multiple, stressors. As these stressors b~pOmeintensified the

ecosystem detei~iorates.The degradation of the Fox.River has andwill continue to affectthe well being of its

residents. In February 2004, over 150,00q residents in Aurora were recommended to boil their water. A report

prepared by Weston Solutions indicated tl~atthe majority of the blame for the boil order could be placed on the

deterioration of water quality in the Fox River. The proposed rule change by IAWA will not improve the condition

of the Fox River, but it has the potential to accelerate its declining condition: Thus, it should be rejected by the

Illinois Pollution Control Board.

ThanI~you very much for your time and consideration.

Sincerely,

3~r&x0~

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Dorothy Gunn, Clerk

Illinois Pollution Control Board

James R. Thompson Center

100 W. Randolph Street

Suite 11-500

Chicago, IL 60601

RECE~VED

CLERK’S OFFICE

NOV

5 2004

STATE OF ILLINOIS

PoIIut~onControl Board

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