December 20, 2006
    Ms. Dorothy Gunn, Clerk
    Illinois Pollution Control Board
    100 West Randolph
    Suite 11-500
    Chicago, IL 60601-3286
    Public Comments by the Illinois Chapter of the American Fisheries Society Regarding
    R 04-025 – Proposed Amendments to Dissolved Oxygen Standards
    Dear Ms. Gunn,
    The American Fisheries Society was founded in 1870 and is the world’s largest and oldest
    organization of professional fisheries biologists and aquatic resource scientists. The Illinois
    Chapter represents more than 250 fisheries and aquatic scientists within the state of Illinois. Our
    members include a diverse cross section of professionals from agencies, research institutions,
    universities, and private consulting firms. The Illinois Chapter has the expressed mission “to
    support the conservation and stewardship of the fisheries and aquatic ecosystems in Illinois by
    promoting professional excellence in fisheries science, management and education.” We
    recognize that the fisheries and overall aquatic diversity of Illinois are dependent on high quality
    water supplied by natural hydrologic cycles.
    The Chapter has reviewed materials relevant to proposed rulemaking to amend Illinois’
    dissolved oxygen General Use standards contained within 35 Ill. Adm. Code 302.206, including
    IPCB hearing transcripts, various sources cited therein (including those provided by Illinois
    Association of Wastewater Agencies (IAWA) and their consultants) and the State’s technical
    support document. We have discussed this matter both informally and in the context of our
    Executive Committee meetings.
    First, we have found no compelling evidence to modify our
    earlier position stated in a June 2004 letter which opposes the adoption of IAWA’s
    recommended standard. Furthermore, it is the overwhelming consensus of the Chapter to
    fully support the joint recommendation of Illinois’ Department of Natural Resources
    (IDNR) and Environmental Protection Agency (IEPA).
    While there is general agreement that the existing standard is in need of revision, we feel that the
    AIWA proposal would inadequately protect aquatic life throughout the range of aquatic habitats
    and environmental conditions present in Illinois. Conversely, the IDNR/IEPA proposal follows
    protocol provided in US Environmental Protection Agency’s (USEPA) 1986 National Criteria
    Document (NCD) for safeguarding organisms known to be sensitive to dissolved oxygen as well
    as early life stages (eggs, embryos, larvae) of
    all
    fish and aquatic invertebrates. Specifically, we
    believe the procedures used by the state agencies to select a protected spawning/post-spawning
    period as well as earmarking “Category I” stream segments are sound and scientifically based.
    In formulating their recommendations, IDNR and IEPA relied heavily upon information gleaned
    by their cooperative basin survey program that has long served as a model for other states. The
    database amassed by their efforts spans over 25 years and includes well over a thousand
    ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, DECEMBER 20, 2006
    * * * * * PC 100 * * * * *
    individual samples from Illinois streams. Each sample includes data on fish, macroinvertebrates,
    habitat, and water and sediment chemistry. Although this body of information forms the
    backbone of the joint agency proposal, it is supplemented by dozens of scientific literature
    sources, a state-of-the-art Geographic Information System (GIS), and, of course, the collective
    experience of the dedicated field biologists within each agency who have collected these data
    over the decades.
    In summary, the Illinois Chapter of the American Fisheries Society fully supports the approach,
    methodology and resulting recommendations crafted by the two agencies with statutory
    responsibility for the protection of Illinois’ fisheries and aquatic resources. The IDNR/IEPA
    proposal recognizes the state’s vast biological diversity and the resultant need to stratify water
    quality protection standards with regard to space and time. The final product is a flexible
    standard which affords full protection of Illinois’ aquatic life without unduly burdening the
    regulated community with a rigid, antiquated standard. We urge the Pollution Control Board to
    adopt the State’s rulemaking proposal in its entirety.
    Sincerely,
    Robert “Bud” Fischer
    President, Illinois Chapter of
    the American Fisheries Society
    ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, DECEMBER 20, 2006
    * * * * * PC 100 * * * * *

    Back to top