6—14—04
6:30PM
21 77936939;
2
The
Illinois Chapter
of the
~Anieiican Fisheries Society’
founded 1963
•
RECEIVED
CLERK’S OFFICE
JUN 15 2004
STATE OF QLINOIS
Pollution Control Board
June 14, 2004
flhinois Pollution Conirol Board
100 West Randolph
Suite 11-500
Chicago, Illinois 60601-3286
Re~
R 04-025
Dear.Sir/Madam:
The American Fisheries Society was founded in 1870 and is the world’s largest and oldest
organization ofprofessional fisheries biologists and aquatic resource scientists. The Illinois
Chapterrepresents more than
250
fisheries and aquatic scientists
within
the State of flhlnois. Our
members include a diverse cross section ofprofessionals from regulatory agencies, research
institutions, universities, and private consulting firms. The Chapterhas the expressed mission
L~tO
support the conservation and stewardship ofthe fisheries and aquatic ecosystems in Illinois
by promoting professional excellence in fisheries science, management, and education.” We
recognize that the fisheries and overall aquatic biodiversity of Illinois are dependent on high
quality water supplied by natural hydrologic cycles.
The Chapter has reviewed and debated the Illinois Association of Wastewater Agencies’(IAWA)
proposed revisions to illinois’ dissolved oxygen standards. We have also reviewed the
supporting documentalfon provided by James B. Garvey and Matt R. Whiles ofSouthern Illinois
University in theirApril 2004 report entitled-An
Assess?nent ofNational and illinois Dissolved
Oxygen Water Quality Criteria.
Although the Chaptercommends Drs, Garvey and Whiles for
the thoroughness of their review ofthe existing literature on the subject, theirsubsequent
recommendatiOns, in our
view,
are not adequately supported by the data.
-
• Specifically, the Chapter is quite concerned by the proposal to lower the state’~dissolved oxygen
standard from its existing one-day minimum of
5.0
rnglL to a one-day minimum of3.5 mg/L and
•a seven-day mea~i~ninimuinof 4.0 mgIL during the period ofJuly through Februar~r. Our
• arguments against the proposed revisioirare summarized as follows:.
-
-
•
Most of the research cited in the Garvey arid Whiles report deals with acute, short term
effects such as fish mortality associated with hypoxia However, the authors admit “no
-
standardized method for conducting acute tests with dissolved oxygen yet exists”
2l77e36e~~~
Further, studies of longer term, chronic effects, such as those involving growth,
reproduction, arid feeding, “are rarer than acute ones”. This lack ofempirical evidence
does not support the conclusion that lowered standards of protection will result in little or
no impairment of aquatic life.
Nearly all ofthe work cited in the supporting document involves laboratory studies,
presumably utilizing clean water subjected to controlled levels ofdissolved oxygen. The
results obtained may not be applicable to field conditions, particularly in Illinois, where
fish and other organisms are subjectedto a suite ofphysical and chemical perturbations
involving temperature, sediments, pH, ammonia, nutrients and heavy metals. There are
synergistic effects and interactions among these constituents which are difficult or
-
impossible to replicate in a laboratory setting.
•
The fish species utilized in earlier studies, particularly those referenced in Chapman’s
(1986) review, are primarily spoii species and do riot reflect the diversity of taxa or even
ecological guilds present in Illinois’ waters. For instance, Sniale and Rabeni
(1995)
--
included only one sucker, the extremely tolerant white sucker, in their analysis. The
sucker family has many Illinois representatives, some of which (e.g. the nGrthem
•
hogsucker arid various redhorses), are quite sensitive to environmental stresses. Other
than .Smale and Rabeni, there are no studies cited which include minnows
—
numerically
dominant in most Illinois streams
—
or darters, our most “intolerant” family offishes as a
whole.
•
By categorizing fishes as either “coidwatef’ (salmon and trout) or “warmwater” (virtually
everything else), the often cited Chapman report lumps all native, stream dwelling illinois
fish into the same tolerance category when, in reality, they present a continuum. More
research is needed to criticallyexamine the envirorimentaJ requirements ofthe various
“waunwatef’ fishes arid to recognize more subtle variations in their needs. At the very
least, an intermediate category such as “coolwater” should be applied to species including
smaliniouth bass, sculpins, daces and other fishes that are clearly limited in their
geographic distribution by temperature and/or dissolved oxygen regimes.
-
-
•
Streams supporting these less tolerant forms should be categorized with a different use
designation than those in the southern part of the state which regularly show dissolved
oxygen violations under “natural”- conditions (that is, without point source effluent). A
-
comprehensive statewide review ofbiological, physical and chemical data from Illinois’
streams and rivers would provide the. framework for assigning more specific d~signations
- •
than the current~genera1 use”. Stthicl~rdsfor dissolved oxygen, aswelll as other
• -• - -•
•
•
consti~u~nts,couldth~iibe adjusted in a context of scientifically defensible, regional
expectations
-
5:30PM
Illinois Pollution Control Board
June 14, 2004
PageTwo
7793s9.J~
3~i4~O4
5:30PM
Illinois Pollution Control Board
• June 14, 2004
Page Three
Although the Chapter understands and concurs with a seasonally stratified standard to
reflect temporal changes in life history stages and theirrequirements, we believe, the
proposed March thrc~ughJune period recommended to protect “early life stages” falls
short of doing so. Many important stream fishes (freshwater drum, flathead catfish,
various minnows) spawn later into the summer, and their larvae are present into July.
• Therefore, if a temporally adjusted standard is applied, it should be extended at least
through July 31.
In summary, the illinois Chapter ofthe American Fisheries Society does not support relaxing
-
Illinois’ existing dissolved oxygen standards because insufficient evidence isavailable that such
action will riot have serious and irrevocable consequences for the state’s aquatic biota—. that is,
the science does not support the proposed changes The Garvey and Whiles report bears this out;
the authors admit “many gaps in our knowledge”, recommend further research to “develop more
precise and meaningful criteria”, and suggest “improved criteria that are relevant on a regional
and habitat-specific basis”. Such statements accurately depict the imperfect state of our
knowledge and strongly argue for a more measured approach to changing standards.
The Chapter urges the Pollution Control Board to retain Illinois’ existing dissolved oxygen
-
standards unchanged p,enthng additional critical research. At a very minimum, studies which
involve a wider variety of native Illinois fish species and examine both acute and chronic
responses to dissolved oxygen in concert with other typical chemical constituents are warranted.
This must be coupled with a revision in Illinois’ use attainability designations which is sensitive
to the state’s wide geographic and ecological diversity. To lower water quality standards now,
given
the uncertain but possibly severe consequences, would not serve the best interests either of
Illinois’ citizens or its aquatic resources.
Sincerely.
•
•
-
Robert W. Schanzle, President
•
•
• -
•
Illinois
Chapter
•,
-
-
American Fisheries
Society
•
• -
RWS;rs
•
•
-
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