REc~vFD

CLERKS OFFICE

Margie & Orest Szymanskyj

NOV 152004

3607 Lindsay Lane

Crystal Lake, IL 60014

STATE

OF ILLINOIS

POIIut~o~Control Boarc~

Dorothy Gunn, Clerk

November ii, 2004

Illinois Pollution Control Board

James R. Thompson Center

100W. Randolph Street

Suite 11-500

Chicago, IL 60611

Re:

Illinois Association of Wastewater Agencies

Proposal to Lower Dissolved Oxygen Criteria

DearMs.Gunn:

7:~:i~.

13

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 3.4 mg/i during

the months of July through February. I 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 a~impaired by the Illinois Environmental Protection Agency. One

of the reasons for the river’s impairment is low dissolved 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 smallmouth bass are also negatively affected by low dissolved oxygen. The aquatic

fauna in the Fox River is already threatened by deteriorating water quality with several species becoming

extirpated from the watershed I recent decades. Lower dissolved oxygen will only intensify the problems

the Fox River faces.

Robert Schanzel made the following comments on behalf of 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 irrevocable 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,

wouid 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

IAWA 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.

Thank you very much for your time and consideration.

Sincerely,

-

Margie~aE~

Orest N. Szymanskyj