AMERICAN BOTTOMS

RE

:

Proposed Amendments to Dissolv ed Oxygen Standard

35 ILL

. ADM .CODE 302.20

Pollution Control Board R e R04-25

Dear Ms. Gunn

:

The American Bottoms Regional Wastewater Treatment Facility would like to record its

support for the Illinois Association of Wastewater Agency (IAWA), petition R04-25

.

American Bottoms has followed the hearings closely and feels that the evidence supports

the position of IAWA as originally filed

. The IAWA petition would establish a dissolved oxygen

water quality standard that is protective of the state's surface waters and biological resources

.

We feel that the petition is founded in good science and is attainable in the least disturbed water

systems

. The IAWA position would establish a seasonal dissolved oxygen standard that is

protective of early live stages of fish, aquatic insects and benthic organisms and establish a

minimum concentration of 3

.5 mg/L, which is more protective than suggested in the USEPA

National Criteria Document

. Furthermore, IAWA has proven its case.

American Bottoms does not agree with the position supported by the Illinois Department

of Natural Resources and the Illinois Environmental Protection Agency

. The agencies have not

proven the case for their proposed oxygen concentrations in surface waters

. The data show that

adoption of the agency proposed dissolved oxygen concentrations would continue a water quality

standard that is unattainable even in the least disturbed surface water systems

. We especially are

opposed to the establishment of river segments held to a different standard without the evidence

to justify such a designation

. An unattainable standard is worse than no standard at all

.

We encourage the Board to adopt the IAWA petition R04-25 as filed

.

George

inge

Execut ve Director

CITY OF EAST ST

. LOUIS

-

VILLAGE OF SAUGET

VILLAGE OF CAHOKIA

COMMONFIELOS OF CAHOKIA PUBLIC WATER DISTRICT

REGIONAL WASTEWATER

1 AMERICAN BOTTOMS

TREATMENT

ROAD

FACILITY

RECEIVED

SAUGET, ILLINOIS 62201-1075

CLERK'S OFFICE

(618) 337-1710

DEC

1 5 2006

FAX (618) 337-8919

STATE

Pollution Control Board

Ms

. Dorothy Gunn, Clerk

JRTC

100 Randolph Street, Suite 11-500

Chicago, Illinois 60601

December 12, 2006

Pollution

CoILLINOIS

ol Bo d

~ c~