Re: Proposed amendments to dissolved oxygen standard (R04-25)
    Dorothy Gunn, Clerk
    R E C E ~V E D
    Illinois Pollution Control Board
    CLERK’S OFFICE
    James R. Thompson Center
    100 W. Randolph St.
    Nov 032004
    Suite 11-500
    Chicago, IL 60601
    STATE OF ILLINOIS
    Pollution Control Board
    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
    mg/I to
    3.5
    mg/l
    during the months of July through February. 1 am writing you to ask that you reject IAWA’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 water quality and harming
    aquatic life. The current Illinois standard for dissolved oxygen follows U.S. Environmental Protection
    Agency guidelines and past scientific studies do not support a .lower standard. Therefore, the Illinois
    Pollution Control Board should reject the proposal to lower dissolved oxygen standards.
    In 2002, the Fox River was categorized as impaired by the Illinois Environmental Protectioh Agency. One
    of the reasons for the river’s impairment is low dissolved oxygen. The effects of low dissolved oxygen in
    rivers such as Fox are well documented, At extremely low oxygen levels, fish kills result. Low dissolved
    oxygen levels in the Fox River will also negatively impact fish species that spawn in late summer, and
    sportfish such as smalimouth bass are sensitive to low dissolved oxygen levels. Freshwater mussels and
    other aquatic macroinvertebrates are also negatively affected by low dissolvedoxygen. The aquatic fauna
    in the Fox River is already threatened by deteriorating water quality with several species becoming
    extirpated from the watershed in recent decades. Lower dissolved oxygen will only exacerbate the
    problems the Fox River faces.
    Robert Schanzel made the following comments on behalfof the Illinois Chapter of the American Fisheries
    Society regarding the proposal: “The Illinois Chapter of the American Fisheries Society does not support
    relaxing Illinois’ existing dissolved oxygen standards because insufficient evidence is available that such
    action will not have serious and ilTevocable consequences for the state’s aquatic biota
    -
    that is, the science
    does not support the proposed changes.” Schanzel also states “To lower quality standards now, would not
    serve the best interests either of Illinois’ citizens or its aquatic resources.”
    The condition of the Fox River is impacted by multiple stressors. As these stressors become intensified the
    ecosystem deteriorates. The degradation of the Fox River 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 i.t has the potential to accelerate its declining condition. Thus,
    it should be rejected by the Illinois Pollution Control Board.
    Thank you very much for your time and consideration.
    Sincerely
    Ms. Kyla
    Jacobsen
    509
    Hendee St.
    Elgin, IL 60123

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