environmental

and consultantsengineers

January 2, 2007

Dorothy Gunn, Clerk

Pollution Control Board

JRTC

100 Randolph Street, Suite 11-500

Chicago, Illinois 60601

Re :

Proposed Amendments to Dissolved Oxygen Standard

35 Ill Adm Code 302 .206

Pollution Control Board Rule R04-25

Dear Ms . Gunn :

For the past 35 years I have been active not only in the development of water quality standards in

Illinois, but also stream monitoring throughout much of Illinois

. It has been widely known for

many years that the existing minimum dissolved oxygen (D .O .) water quality standard (5

.0

mg/L) was not being achieved, when proper (early morning) readings were being collected

. This

is not an isolated problem but occurs throughout most, if not all, of the Illinois streams

.

The Illinois Association of Wastewater Agencies (IAWA) petition would establish a 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 that is more protective than

suggested in the U .S . EPA national Criteria Document . Equally important, this minimum D

.O .

standard is attainable in a vast majority of Illinois streams that have had minimal disturbance

.

While the Illinois EPA and IDNR have offered an alternative petition that if adopted, will result

in continued violations on streams with little disturbances, and without any demonstrated benefit

.

To the extent these agencies believe there are unique aquatic ecosystems that require unique

D.O . standards, it would seem each segment should be presented as a unique petition to the

Board with the supporting site specific data to support such petitions

. This is no different than

the requirements on site-specific rule changes currently .

In summary, I would encourage the Board to adopt IAWA's D

.O. petition, and direct the Illinois

EPA and IDNR to bring site specific petitions for each unique waterway

.

REC€EiVEDCLERK'S

OFFICE

ORIGINAL s,.µ'

: 0 `

: 2007 STATE OF ILLINO~SS larger Road, Suite 330

Pollution Control Board

PhoneOak

Brook,

: (630)

IL

684-910060523

Fax : (630) 684-9120

Website : http : / / huffnhuff.com

Res ectfully sub

f~)

James E . H

Vice President

Huff & Huff, Inc .

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