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The ~

Chapter

of the

Arnerican Fisheries Society

founded 1963

DEC. 07 2OO~

December 8, 2004

•

Pollution Control Board

Illinois Pollution Control Board

.:

Li

100 West Randolph

C)

I

• Suite 11-500

Chicago, illinois 60601-3286

Dear Sir/Madam:

• The American Fisheries Society was founded in 1870 and is the world’s largest and oldest

organization ofprofessional fisheries biologists and aquatic resource scientists. The Illinois

Chapter represents more than 250 fisheries and aquatic scientists within the State ofIllinois. Our

members include a diverse cross section ofprofessionals from regulatory agencies, research

• institutions, universities, and private consültin~firms. The Chapter has the expressed mission

‘~tosupport the conservation and stewardship of the 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 ofIllinois are dependent on.high

quality water supplied by natural hydrologic cycles.

The chapter wishes to express its support for the proposal currently before the Illinois Pollution’•

ControlBoard (IPCB) to impose a 1 mg/I interim monthly average limit on phosphorus from new

or expanded discharges in excess of I mgd. We commend the Illinois Environmental Protection

Agency (IEPA) for their submittal ofthis newstandard. As fisheries professionals, we concur

that it has positive implications for Illinois’ aquatic ecosystems and, in particular, its stream

biota.

As the “limiting factor” for plant growth in most freshwater environments, phosphorus is often a

major determinant ofprimaryproductivity in Illinois’ lakes, rivers and streams. When it occurs

• in excessive amounts (due to anthropogenic so rces such as wastewater or industrial effluent),

this nutrient can trigger significant algal blooms in waterways. Aside from aesthetic impacts,

such growth can lead to wide diurnal oxygen fluctuations (and eventual die-offs) which exert

• considerable stress on aquatic life, leading to massive fish kills in extreme cases. According to

IEPA’ s

2004

Illinois Water Quality Report,

nutrients (including phosphorus) were cited as a

• potential cause of impairment for 2588 miles ofillinois streams out of an assessed total of

15,

069 miles,

•

CLERK’S OFFICE

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For these reasons, the regulation ofphosphorus effluent in our state’s lotic systems is long

•overdue. According to USEPA’s 1986 National Criteria Document, streams should not exceed

0.1 mg/I in order to avoid excessive algal growth. While the proposed effluent standard of 1 M

mg/l would still allow this level to be exceeded in smaller streams with relatively little

assimilative capacity, the magnitude of nutrient enrichment experienced by Illinois’ effluent

receiving waters would be significantly less than what is presently experienced.

From a statutory standpoint, this new standard would help achieve the “fishable, swimmable”

goals ofthe Clean Water Act. It would address the anti-degradation requirements ofstate law

relative to aesthetics, pH and dissolved oxygen (each of which is affected by excessive algae

growth). Moreover, the standard is realistically achievable; it has been in force since the 1970’s

on Great Lakes tributary streams with positive effects on Lake Michigan’s aquatic life.

It is therefore in the best interest of the ecological, recreational and aesthetic values ofIllinois

rivers and streams to enact the proposed standard. The Illinois Chapter of the American Fisheries

Societystrongly urges IPCB to adopt JEPA’s recommendations regarding phosphorus in their

entirety. Thank you for your consideration of these comments on an issue so vital to the health of

our state’s aquatic ecosystems.

Sincerely,

•

(

Bruce L. Lippincott, President

Illinois Chapter

American Fisheries Society.

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CLERK’S OFFICE

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DECO7.201j4

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Fax

• Fax Number: 312-814-3669

TotalNumber ofPages: 3

p ~ 3

Ifyou have questions regarding this transmission, call: Lawler, Matusky & Skelly

Engineers LLP

@

815-334-9511.

Message:

The Illinois chapter of

the American Fisheries Society respectfully requests that its

letter concerning this

matter be added to the case file.