Illinois Pollution Control Board

Dorothy Gunn, Clerk

JRTC

100 Randolph Street, Suite 11-500

Chicago, Illinois 60601

RE : Proposed Amendments

to Dissolved Oxygen Standard

35 ILL

. ADM .CODE 302.206

Pollution Control Board Rule R04-025

Dear Ms Gunn

:

The City of St

. Charles would like to record its support for the Illinois Association of Wastewater

Agency (IAWA), petition R04-025 .

We have followed the hearings and reviewed the transcripts from the hearings closely and feel

that the evidence supports the position of the IAWA as originally filed

. The IAWA petition

establishes a dissolved oxygen water quality standard that would safely protect the surface waters

and biological resources of the State of Illinois . We feel that the petition is founded in good

science and is generally attainable in water systems throughout the state

. The IAWA petition

contains a seasonal dissolved oxygen standard that is comprehensively protective of early live

stages of fish, aquatic insects and benthic organisms and establishes a minimum concentration of

3

.5 mg/L, that is more protective than suggested in the USEPA National Criteria Document .

We cannot agree with the position supported by the Illinois Department of Natural Resources and

the Illinois Environmental Protection Agency . The agencies have not scientifically proven the

case for their proposed oxygen concentrations in surface waters

. The data in the record indicates

that adoption of the agency proposed dissolved oxygen concentrations would continue a water

quality standard that for the most part is unattainable, even in the least disturbed surface water

systems

. We are especially opposed to the establishment of river segments held to a different

standard with out having conducted the scientific due diligence required to produce evidence to

justify such a designation .

We encourage the Board to adopt the IAWA petition R04-025 as filed .

Sincerely,

Clifford L . White, Jr.

Environmental Services Superintendent

City of St. Charles

RECEIVED

CLERK'S

OFFICE

DEC

1 3 2006

Pollution

STATEOF

Control

ILLINOISBoard

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BRIAN'FOWNSE:Np (li'ndndrrlshaIor

Two EAST MAIN STREET

Si . (HANEES

I1 60174-1984

PHONE : 630-377-4400

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FAX : 630-377-4440