Fox
Water Reclamation
Metro
District
682 State Route 31 • Oswego, Illinois 60543-8500
(630) 892-4378
• FAX (630) 892-4394
Illinois Pollution Control Board
Dorothy Gunn, Clerk
James R. Thompson Center
100 Randolph Street, Suite 11-500
Chicago, Illinois 60601
Dear Ms . Gunn :
Thomas F . Muth, Manager
Fox Metro Water Reclamation District
RE: Illinois Pollution Control Boa
Proposed Amendments to Disso ve
35 111 . Adm . Code 302 .206
R.H. Locke, President
J.K. Detzler, Vice President
J.S. Sotir, Secretary & Clerk
M.C . Funkey, Treasurer
A.E. Heriaud, Trustee
T.F
. Muth, District Manager
D.C . Ingemunson, Attorney
G.V. Griffin, Engineer
December
RE
11,
C
2007
EIVED
DEC
2006
ulemakin Water
9 -
STATE OF ILLINOIS
)
Oxygen Standard
Pollution Control Board
The Fox Metro Water Reclamation District (Fox Metro) would like to record its support for the
Illinois Association of Wastewater Agency (IAWA) petition designated as R04-25 .
Fox Metro representatives have been in attendance at the public hearings and have intently
listened to the testimony presented
. Fox Metro feels that the evidence presented supports the
IAWA petition as originally filed
. The petition would establish a dissolved oxygen water quality
standard that protects the state's surface waters and indigenous aquatic life
.
Fox Metro feels that the data presented as part of IAWA's testimony represents good science
which supports the petition and a proposed set of standards which are attainable in minimally
disturbed water systems . The IAWA petition proposes to establish a seasonal dissolved oxygen
standard that is protective of early live stages of fish, aquatic insects and benthic organisms
and establishes a minimum standard that is more stringent than that suggested by USEPA in its
National Criteria Document .
Fox Metro has heard and has examined the testimony of the Illinois Department of Natural
Resources and the Illinois Environmental Protection Agency . Fox Metro does not believe that
these agencies have provided the scientific evidence to support their proposed modifications of
the IAWA petition . Data provided during the hearings suggests that the agencies proposed
modifications would merely be a continuance of a dissolved oxygen water quality standard that
is unattainable, even in minimally disturbed surface water systems .
Fox Metro is strongly opposed to the establishment of river segments that would be subject to
an even more stringent standard without the scientific evidence needed to support such a
designation. Furthermore, Fox Metro believes that the evidence presented during the hearings
showed that river segments, identified in a proposal to modify the IAWA petition, did not need a
special dissolved oxygen standard .
Therefore, in consideration of the above reasons, Fox Metro encourages the Board to adopt the
IAWA petition R04-25 as filed .
Thank You
