RECE~VE~
CLERK’S OFFICE
AUG 1.O~
STATE OF ILLINOIS
Pollution Control Board
“Improve the economic well-being ofagriculture and enrich the quality offarm family life.”
Ms. Dorothy Gunn, Clerk
Illinois Pollution Control Board
James R. Thompson Center
100 West Randolph Street — Suite 1 1-500
Chicago, IL 60601
RE:
Comment on Illinois Association of Wastewater Agencies
Dissolved Oxygen Proposal
35 III. Adm. Code 302.206
Illinois Pollution Control Board Docket Number R 04-25
This letter is to express Illinois Farm Bureau’s support for the Illinois Association
of Wastewater Agencies’ (IAWA) proposal regarding the modification of the water
quality standard for dissolved oxygen (DO) in Illinois. Our comments are not
technical in nature but present our perspective on the importance of ensuring that
the state’s dissolved oxygen standard is realistic and based on sound science.
Illinois Farm Bureau is a voluntary, grassroots organization whose members
include about three-fourths of the farmers in the state. Illinois Farm Bureau
supports the use of voluntary, best management practices for agriculture to
continue the positive conservation trends we have seen in recent years.
Because farmers cannot pass along the cost of implementing programs, we
support projects that are based on current scientific data and common sense,
and that ensure farmers remain economically viable. We also believe that
programs and projects should be based on standards and tolerances established
using sound scientific information.
The proposed changes to the dissolved oxygen standard reflect the U.S.
Environmental Protection Agency’s National Criteria Document (NCD) for
dissolved oxygen. The IAWA request for changes to the standard is also based
on an IAWA-sponsored study and review of scientific literature by researchers at
Southern Illinois University, titled “An Assessment of National and Illinois
Dissolved Oxygen Water Quality Criteria.” The report states that the current
standard is overly restrictive and should be changed to reflect research on
natural fluctuations in aquatic systems and physiological tolerances of native
aquatic life.
ILLINOIS AGRICULTURAL ASSOCIATION®
1701 N. TowandaAvenue
•
P.O. 2901
•
Bloomington, Illinois
•
61702-2901
Phone:
309.557.2111
•
Fax:
309.557.2559•
http://www.ilfb.org
August 9, 2004
The IAWA recommendation is to change the dissolved oxygen standard for
surface waters in Illinois, except Lake Michigan and wetlands. The proposed
language for the DO standard (as stated in IAWA documents) is:
“Dissolved oxygen shall be determined on a monthly basis as follows:
a. During the months of July through February, dissolved oxygen shall not be
less that a one day minimum concentration of 3.5 mg/L, and a seven day
mean minimum of 4.0 mg/L. The mean minimum is defined as the
average of the minimum daily recorded dissolved oxygen concentrations
and should be based on a data recorder or representative grab samples.
b. During the months of March through June, dissolved oxygen shall not be
less than a one day minimum dissolved oxygen concentration of 5.0 mg/L,
and a seven day mean of 6.0 mg/L. The mean is defined as the average
of the daily average value and should be based on data collected by semi-
continuous data loggers or estimated from the representative daily
maxima and minima values.”
This proposal recognizes the seasonality of natural aquatic systems in Illinois
streams. At the same time, the proposed standard is protective of aquatic life in
various life stages. The proposal is also equivalent to the established national
dissolved oxygen standards.
The proposed standard is more realistic and updates the current standard that
was set almost three decades ago. Science has advanced and the
understanding of natural systems and streams in Illinois has improved greatly
since the standard was originally set.
When standards are outdated and do not accurately reflect actual conditions, the
standards will not achieve desired results. Local communities, municipalities,
and landowners bear the burden of trying to achieve standards. Implementing
standards is costly - both monetarily and time wise, It is far better to have
realistic standards that are achievable. The current, questionable standard
wastes time, efforts, and money and does not produce desired results.
The SIU research indicates that the current DO standard is not necessary to
achieve desired ecological improvements. The more prudent course of action
would be to use the IAWA proposed rule as a basis for changes to the dissolved
oxygen standard.
The flawed dissolved oxygen standard is not a “stand alone” issue. Other
programs are based on Illinois’ current outdated DO standard. The dissolved
oxygen standard is connected to the 303(d) List of Water Quality Impaired
Streams and Lakes and therefore drives the development of total maximum daily
loads (TMDLs).
Manywaters in Illinois are listed as impaired due to an existing dissolved oxygen
standard that is overly protective and does not reflect the needs of Illinois
streams. IEPA is developing TMDLs for streams on the 303(d) List. The process
of TMDL development is costly by itself, not to mention the millions of dollars
necessary for point and nonpoint sources to implement the plans to achieve load
reductions. It is therefore increasingly critical to ensure that the dissolved oxygen
standard used for the development of the 303(d) List is appropriate for Illinois
streams.
According to the research study conducted by SlU, there is little scientific or
ecological justification for continuation of the current DO standard. The standard
proposed by IAWA helps move Illinois in the right direction by establishing valid
goals that both reflect the natural condition of Illinois streams and also are
protective of aquatic life.
In summary, Illinois Farm Bureau supports the IAWA proposed dissolved oxygen
standard because it is realistic, appropriate for Illinois, and based on sound
science.
Sincerely,
Nancy Erickson, Director
Natural and Environmental Resources
Cc:
Mr. Roy Harsh
Mr. Dennis Streicher
