Board of Trustees
Donald E
. Eckmann
President
Wallace D . Van Buren
Vice President
Edward C . Richard
Clerk
Legal Counsel
Michael C . Wiedel
Pollution Control Board
Dorothy Gunn, Clerk
J RTC
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 R04-25
Dear Ms. Gunn:
The Downers Grove Sanitary District would like to record its support for the Illinois Association
of Wastewater Agency (IAWA), petition R04-25 .
We have followed the hearings closely and feel that the evidence supports the position of IAWA
as originally filed . The IAWA petition would establish a dissolved oxygen water quality standard
that is founded in good science, is protective of Illinois surface waters and biological resources
and is attainable . The standard proposed by IAWA would establish a seasonal dissolved oxygen
standard that is protective of early life stages of fish, aquatic insects and benthic organisms and
establish a minimum concentration, 3.5 mg/L, which is more protective than the USEPA
National Criteria Document .
We do not agree with the position supported by the Illinois Department of Natural Resources and
the Illinois Environmental Protection Agency
. These agencies have not proven the case for their
proposed oxygen concentrations in surface waters
. The data show that adoption of the agency
proposed dissolved oxygen concentrations would continue a water quality standard that is
unattainable even in the least disturbed surface water systems
. We are especially opposed to the
establishment of a different standard for certain river segments without proper evidence to justify
such a designation .
Downers Grove
Sanitary District
MOO
2710 Curtiss Street
PO . Box 1412
Downers Grove, IL 60515-0703
Phone 630-969-0664
Fax 630-969-0827
www d gsd .org
Providing a Better Environment for South Central DuPage County
December 12, 2006
Printed on Recycled Paper
Staff
Lawrence C Cox
General Manager
Nicholas
I
Menninga
Assistant General Manager
Ralph E
. Smith, Ir.
Operations Director
Sheila K . Henschel
Administrative Services
rector
CLERKS OFFIE D
DEC I ~ 2006
Pollution
STATE OF
Control
ILLINOISBoard
Dorothy Gunn
December 12, 2006
Page 2 of 2
We encourage the Board to adopt the IAWA petition R04-25 as filed
.
Very truly yours,
DOWNERS GROVE SANITARY DISTRICT
Donald E. Eckmann
President
Board of Trustees
Wallace D. Van Buren
Vice President
Board of Trustees
u
Edward C . Richard
Clerk
Board of Trustees
