9 January 2007
    Pollution Control Board
    Dorothy Gunn, Clerk
    JRTC
    100 Randolph Street, Suite 11-500
    Chicago Illinois 60601
    RE: Pollution Control Board Rule R2004-025
    Proposed Amendments to Dissolved Oxygen Standard
    Dear Ms. Gunn,
    I have just received a letter written by Mr. Dennis Streicher representing the
    Illinois Association of Wastewater Agencies. In his letter Mr. Streicher makes the claim
    that the position taken by the Illinois Chapter of the American Fisheries Society (ILAFS)
    on the Proposed Amendments to the Dissolved Oxygen Standard was made solely by the
    executive committee and committee chairs of the ILAFS and was biased by the affiliation
    (IDNR and IEPA) of these members. In fact, the decision on the Chapter’s position was
    made in accordance with the ILAFS bylaws, which state that all position papers must be
    approved by the executive committee. At this point the executive committee is composed
    of me, Jim Garvey and Ann Holtrop and since both Jim and Ann recused themselves
    from voting, I (someone with no affiliation with either the IEPA or IDNR) made the final
    decision regarding the Chapter’s position on the Dissolved Oxygen Standard. The
    decision was not made in a vacuum, as has been suggested. Rather I sent an email to as
    many members as possible asking them to review the position the Chapter took at the
    beginning of the DO process (2004), read the transcript from the hearings (provided link)
    and comment on how we should respond to the proposed DO changes as a Chapter.
    After receiving input from the membership, I held a meeting of the executive committee
    and committee chairs to discuss the proposed Dissolved Oxygen Standard. At the end of
    the meeting, after receiving comments from the membership, the committees and having
    read the transcripts myself, I made the decision that the Chapter would continue to
    support its original comments filed with the Pollution Control Board in 2004. I then
    asked Randy Sauer, as the Chair of the Environmental Concerns Committee to revise the
    2004 letter and send it to me for final approval. Once approved the ILAFS position was
    submitted as public comment to the Pollution Control Board.
    The Chapter would also like to address some of the other comments made by Mr.
    Streicher. The ILAFS is not necessarily a "sport minded organization". In fact the
    mission of the ILAFS is to improve the conservation and sustainability of the aquatic
    ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JANUARY 9, 2007
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    resources of the State. This is accomplished by advancing fisheries and aquatic science
    and by promoting the professional development of its membership. That mission is
    carried out by a membership composed of diversely trained professionals from various
    public agencies, institutions and private companies that participate in management,
    research and educational activities, all of which protect, promote, enhance and preserve
    the aquatic resources of Illinois. These professionals hold degrees (the majority have
    advanced degrees) in fisheries and related aquatic sciences. As such they have the ability
    to evaluate data, understand a scientific argument and make objective decisions based on
    the information available. The diversity, education and professionalism of Chapter
    members allow it to function as an independent organization. We understand that the
    IAWA disagrees with our opinions but the claim that our members are unable to be
    objective and that the Chapter has an agenda because some its members work for
    agencies involved in this discussion is incorrect and unfounded. Science moves forward
    through discussion and disagreement of the data presented not on speculation and
    innuendo.
    Although the time for the filing of testimony is expired I am asking the Pollution
    Control Board to allow the ILAFS to respond to the IAWA letter and have our comments
    posted on the web site.
    Sincerely,
    Robert Fischer, PhD
    President, ILAFS
    Professor of Biology
    Associate Chair, Biology
    Eastern Illinois University
    ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JANUARY 9, 2007
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