Re: Proposed amendments to dissolved oxygen standard (R04-25)

Dorothy Gunn, Clerk

Illinois Pollution Control Board

Lrnes R. Thompson Center

100 W. Randolph St.

Suite 11-500

Chicago, IL 60601

Dear Ms. Gunn,

In April 2004, the illinois Association of Wastewater Agencies (IAWA) submitted a proposal to the Illinois Pollution

Control Board proposing to lower the dissolved oxygen criteria from

5.0

mgIl to

3.5

mg/I during the months of July

through February. I am writing you to ask that you rejeët JAWA’s request. The proposed reduction in dissolved

oxygen criteria will not improve the condition of Illinois streams such as the Fox River, rather it will have the

opposite effect by further degrading wate quality and harming aquatic life. The current Illinois standard for

dissolved cxygen follows U.S. Envir~

~lProtection Agency guidelines and past scientific studies do not

support a lower standard. Therefore

)jS

Pollution Control Board should reject the proposal to lower

dissolved oxygen standards.

In 2002, the Fox River was catego

reasons for the river’s impairmer

Fox are well documented. At e’

River will also negatively imp

sensitive

to low dissolved oxy

negatively affected by low dis:

deteriorating water quality with

dissolved oxygen will only exac

Robert Schanzel made the followir.

regarding the proposal: ‘The Illinois

existing dissolved oxygen standards

I

and irrevocable consequences for the

changes.” Schanzel also states ‘To lowe~

citizens or its aquatic resources.”

d 1;)’ the Illinois Environmental Protection Agency. One of the

~xygen. The effects of low dissolved oxygen in rivers such as

levels, fish kills result. Low dissolved oxygen levels in the Fox

vi~in late summer, and sportfish such as smalimouth bass are

nuss&s and other aquatic macroinvertebrates are also

~aticfauna in the Fox River is already threatened by

~-ningextirpated from the watershed in recent decades. Lower ~

~ the Fox River faces.

~n behalf of the Illinois Chapter of the American Fisheries Society

i the American Fisheries Society does not support relaxing Illinois’

nsUfficient evidence is available that such action will not have serious

aquatic biota

-

that is, the science does not support the proposed

quality standards now, would not serve the best interests either of Illinois’

The condition of the Fox River is impacted by m~iltiplestressors. As these stressors become intensified the

ecosystem deteriorates. The degradation of the Fox Rivet has and will continue to affect the well being of its

residents. In February 2004, over 150,000 residents in Aurora were recommended to boil their water. A report

prepared by Weston Solutions indicated that the majority of the blame for the boil order could be placed on the

deterioration of water quality in the Fox River. The proposed rule change by JAWA will not improve the condition

of the Fox River, but it has the potential to accelerate its declining condition. Thus, it should be rejected by the

Illinois Pollution Control Board.

~ you very much for your time and consideration.

RECE~V~

CLERK’S OFFICE

NOV

012004

STATE OF ILLINQi~

~

Con~r~Board

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Dorothy Gunn, Clerk

Illinois Pollution Control Board

James R. Thompson Center

100 W. Randolph Street

Suite 11-500

Chicago, IL 60601

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