RECEIVED

CLERK’S OFFICE

Re: Proposed

amendments to

dissolvedoxygen

standard

(R(4-25)

JAN

142005

Dorothy Guna, Clerk

Illinois Pollution

Control

Board

STATE

OF ILLINOJS

James

R

ThnpsOnCenter

Pollution Control

Board

100W.

Rafldolph St

Siiit11-500

ChicagoJL

60601

c:,)c’

Dear

Ms.

Gunn,

~

7

In April 2004, the

illinois

Association of Wastewater Agencies (IAWA)

submitted aproposal

to the

illinois

Pollution Control Board

proposing

to lower the

dissolved

oxygen

criteria from

5.0

mg/I

to

3.5

mg/I

during

the months of

July through Febniaiy.

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 dissolvedoxygen follows U.S. Environmental Protection

Agency guidelines

and past scientific

studies

do

not

support a lower

standarct

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 ProtectionAgency.

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

sinallmouth

bass are sensitive

to low

dissolved:o~ygenievels.

Freshwatermussels and

other

aquatic maçminveitebrates

are also negativelyaffectedbylowdissolvcdoxygen.

The~aquatic.fauna

in

the

Fox River is

already

threatened by deteriorating water

quality with

several species becommg

extirpatedfrom

the

watershed

in

recent

decades

Lower

dissolved

oxygen

will’

only

exacerbate the

problems the Fox River faces.

RobertSclianzel made~’

follewing.comrnents

.o~i

hehalf,f

llinis~Cliapter

of.the~-Aie~ican

Fisheries

Society

regarding the proposal:

“The Illinois Chapter ofthe

American

Fisheries

Society

does not

support

relaxing filmois’ existingdissolved

oxygen standards because

insufficient

evidence is available

that

such

action

will

not have serious

and irrevocable

consequences for the state’s

aquaticbieta

-

that

is, the

science

does

I~ot

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 resouives.”

The

condition

of the Fox River is

impacted

by multiple

stressors.

As

these siressors

become intensified the

ecosystem deteriorates.

The

degradation

of the Fox River has

and

will continue to affect the well being of

its

iesidents.~.IaFebruaiy. 201)4,

overJ3.0,000

residentsin

Au

wererecommendedlo.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 deteriorationof water

quality

in

the

Fox River.

The proposed

rule

change by IAWA will not

improve

the

condition of

Ihe

Fox River,

but it has

the potential

to

accelerateitscledlining condition.

Thus,

it

should

be rejected by the illinois Pollution

Control

Board.

Thank you very much for your

time

and consideration.

Sincerely,