Sa

STRAND

ASSOCIATES . INC'

E N G I N E E R S

910 West Wingra Drive

Madison, WI 53715

Phone

: 608-251-4843

Fax 608-251-8655

Office Locations

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www

.strand .com

December 15, 2006

Illinois Pollution Control Board

Dorothy Gunn, Clerk

JRTC

100 Randolph Street, Suite 11-500

Chicago, IL 60601

Re:

Pollution Control Board Rule R04-25

Dear Ms . Gunn :

Strand Associates, Inc

. supports the adoption of petition R04-25 as it was originally

submitted by the Illinois Association of Wastewater Agencies (IAWA) . We are an affiliate

member of IAWA and have been tracking this issue closely

. We believe the original petition

is scientifically justified, attainable, and economically feasible

. The proposed dissolved

oxygen standard provides a long-overdue revision of the original standard that was not

scientifically sound for Illinois

. The IAWA has proposed a standard that implements the

recommendations of the National Criteria Document (NCD), published by the United States

Environmental Protection Agency to provide guidance to individual states when setting

water quality standards to meet the provisions set forth in the Clean Water Act

. The IAWA's

proposal is more protective of aquatic life than the NCD

.

The counter proposal offered by the Illinois Environmental Protection Agency (IEPA) and

the Illinois Department of Natural Resources (IDNR) should not be adopted by the Illinois

Pollution Control Board

. It is not acceptable for several reasons, most notably the seemingly

arbitrary designation of "enhanced" stream segments requiring higher dissolved oxygen

standards

. There is no scientific evidence indicating that the proposed enhanced standards

are attainable in Illinois waterways or necessary for the protection of diverse aquatic life

.

Some of our clients have completed stream dissolved oxygen monitoring with conclusions

that greatly differ from the IEPA and IDNR's assumptions

. The Board now has this data

. We

do not believe the Board should hold certain water segments to a higher standard without the

evidence to support such a designation .

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

.

Sincerely,

STRAND ASSOCIATES, INC .

ORIGINAL

Jane M . Carlson, P .E

.

T y

Stinson, P.E

.

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