UAI

CRAM

SANITARY

CHAMPAIGN

DISTRICT

1100E UNIVERSITY AVENUE • PO BOX 669

December 7, 2006

Pollution Control Board

Dorothy Gunn, Clerk

JRTC

100 Randolph Street, Suite 11-500

Chicago, IL 60601

RE : Proposed Amendments to Dissolved Oxygen Standard

35 ILL. ADM.CODE 302 .206

Pollution Control Board R

Dear Ms. Gunn :

The Urbana & Champaign Sanitary District would like to record its support for the Illinois Association of

Wastewater Agency (IAWA), petition R04-25 .

RECEIVEDCLERK'S

OFFICE

BOARD OF TRUSTEES

ChnstopherAlixDiana

Lenik

DEC 1

5

2006

Jerry Lyke

STATE OF

ILLINOISEXECUTIVE DIRECTOR

Pollutlo'+ Control

Board

Michael Little

URBANA, IL 61803-0669 - Phone (217) 367-3409

. Fax (217) 367-2603

We have followed the hearings closely and feel that the evidence supports the position of the IAWA as

originally filed . The IAWA petition would establish a dissolved oxygen water quality standard that is

protective of the states 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 lives stages fish, aquatic insects and benthic

organisms and establish a minimum concentration of 3

.5 mg/L, that is more protective than suggested in

the USEPA National Criteria Document.

We do 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 with out the evidence to justify such a designation

.

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

Very truly yours,

URBANA & CHAMPAIGN SANITARY DISTRICT

/flcl

R .

>

Michael R Little

Executive Director