The
Illinois Chapter
of -the
Arnerican Fisheries Society
founded 1963
STATE,-..
~
POll~tj0~
Control‘~ILL~JQ~Board
June 14, 2004
-
illinois Pollution Control 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 of professional fisheries biologists and aquatic resource scientists. The Illinois
Chapter represents more than 250 fisheries and aqUatic scientists within the State of Illinois. Our
members include a diverse cross section of professionals from regulatory agencies, research
institutions, universities, and private consulting firms. The Chapter has the expressed mission
“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 documentation provided by James E. Garvey and Matt R. Whiles of Southern Illinois
University in their April 2004 -report entitled
An Assessment- ofNational and Illinois Dissolved
Oxygen Water Quality Criteria.
Although the Chapter commends Drs. Garvey and Whiles for
the thoroughness of their review ofthe existing literature on the subject, their subsequent
recommendations, in our view, are not adequately supported by the data.
Specifically, the Chapter is quite concerned by the proposal to lower the state’s dissolved oxygen
standard from its existing one-day minimum of
5.0
mg/L to a one-day minimum of
3.5
mg/L and
a seven-day mean minimum of 4.0 mg/L during the period of July through February. Our
-
arguments against the proposed revision are summarized as follows:
•
Most of the research cited in the Garvey and Whiles report deals with acute, short term
effects such as fish mortality associated with hypoxia. However, the authors admit “no
standardized methodfor conducting acute tests with dissolved oxygen yet exists”.
Illinois Pollution Control Board
June 14, 2004
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Page Two
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Further, studies of longer term, chronic effects, such as those involving growth,
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reproduction, and feeding, “are rarer than acute ones”. This lack of empirical evidence.
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does not- support the conclusion that lowered standards of protection will result in little or
no impairment of aquatic life.
•
Nearly all of the work cited in the supporting document involves laboratory studies,
presumably utilizing clean water subjected to controlled levels of dissolved oxygen. The
results obtained may not be applicable to field conditions, particularly in Illinois, where
fish and other organisms arc subjected to a suite of physical aiid 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 sport species and do not reflect the diversity of taxa or even
ecological guilds present in Illinois’ waters. For instance, Smale 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 northern
hogsucker and 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 of fishes as a
whole.
•
By categorizing fishes as either “coidwater” (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 critically examine the environmental requirements of the various.
-
“warmwater”
fishes and to recognize more subtle variations in their needs. At the very
least, an intermediate category such as “coolwater” should be applied to species including
smalimouth 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 of biological, physical and chemical data from illinois’
streams and rivers would provide the framework for assigning more specific designations
than the current “general use”. Standards for dissolved oxygen, as well as other
constituents, could then be adjusted in a context of scientifically defensible, regional
expectations.
Illinois Pollution Control Board
-
-
June 14, 2004
-
Page Three
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•
Although the Chapter understands and concurs with a seasonally stratified standard to
reflect temporal changes in
life history stages and their requirements, we believe, the
proposed March. through June 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.
-
-
-
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In
summary,
the illinois Chapter of the American Fisheries Society -does not support relaxing
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Illinois’ existing dissolved oxygen standards because insufficient evidence is available that such
action will not 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 ourknowledge”, 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 pending 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,
sz#
President
Illinois Chapter
American Fisheries Society
RWS:rs
