2419
    East
    Reservoir
    Peoria, IL
    61614-8029
    July
    13,
    2009
    ECVE
    Illinois
    Pollution
    Control
    Board
    CLERK’S OFIOE
    James
    R.
    Thompson
    Center,
    Suite
    11-500
    JUL
    152009
    100
    West
    Randolph
    Street
    Chica
    o
    IL
    60601
    STATE
    OF
    ILLINOIS
    c
    Pollution
    Control
    Board
    Regarding:
    Public
    Comments
    for
    Case
    PCB
    2009-038
    Ameren
    Energy
    Generating
    Company
    v. IEPA
    To
    the
    Members
    of the
    Illinois
    Pollution
    Control
    Board:
    I urge
    you
    to
    deny
    the
    water
    temperature
    changes
    Ameren
    Energy
    Generating
    Company
    is
    requesting
    regarding
    Coffeen
    Lake.
    Ameren
    should
    be
    required
    to
    conduct
    additional
    studies
    of the
    Coffeen
    Lake
    watershed
    and
    area
    water
    resources
    and
    uses
    before
    any
    regulatory
    changes
    are
    made
    for
    this
    cooling
    lake.
    Allowing
    Ameren
    to
    have
    relief
    from
    their
    current
    thermal
    limits
    is
    a
    band-aid
    approach
    on
    something
    that
    indeed
    is
    a much
    greater
    problem. It
    would
    appear
    likely
    that
    if this
    regulatory
    relief
    is approved,
    Coffeen
    Lake
    will
    become
    a
    sacrifice
    zone
    for
    the
    operation
    of the
    Ameren
    Coffeen
    Lake
    Power
    Plant.
    Ameren
    says
    they
    will
    conduct
    a
    study,
    find
    more
    heat
    tolerant
    fish,
    and
    replace
    fish
    if there
    are
    fish
    kills,
    but
    this
    will
    not
    address
    the
    real
    problems
    with
    the
    situation.
    If
    the
    climate
    continues to
    warm,
    it would
    appear
    very
    likely
    that
    Ameren
    could
    be
    back
    for
    additional
    regulatory
    relief
    regarding
    temperature
    issues
    at
    another
    time
    in
    the
    future.
    There
    is a
    valid
    question
    if adequate
    water
    resources
    for
    the
    operation
    of this
    cooling
    plant
    will
    continue to
    be
    available.
    I
    have
    visited
    Hillsboro,
    Illinois,
    on
    many
    occasions
    and
    have
    good
    and
    dear
    friends who
    live
    in
    town
    and
    in
    the
    countryside
    outside
    of
    Hillsboro
    toward
    Coffeen.
    In
    my
    hiking
    interests
    as
    a
    volunteer
    and
    member
    of
    Sierra
    Club,
    I have
    done
    hiking
    and
    bird
    watching
    in the
    Coffeen
    Lake
    Upland
    Management
    Unit
    and
    near
    McDavid
    Branch
    Creek
    and
    have
    been
    at
    the
    Coffeen
    Lake
    IDNR
    site,
    and
    I have
    been
    in
    Coffeen
    on
    several
    occasions.
    At
    the
    June
    23rd
    public
    hearing,
    Ms.
    Arlis
    Bates
    commented
    with
    concerns
    regarding
    proposed
    longwall
    mining in
    the
    watershed
    above
    Coffeen
    Lake.
    I have
    been
    told
    that
    McDavid
    Branch
    Creek
    provides
    a
    significant
    amount
    of
    water
    to
    Coffeen
    Lake.
    A
    section
    of
    the
    creek
    north
    of Route
    185
    above
    Coffeen
    Lake
    will
    be
    dropped
    due
    to
    longwall
    mining
    subsidence.
    The
    mine
    permit
    application
    states
    the
    average
    land
    sinking
    will
    be
    5.7
    feet
    . This
    will
    be
    happen
    over
    more
    than
    4,000
    acres,
    mostly
    north
    of Route
    185
    which
    is
    north
    of
    Coffeen
    Lake
    and
    to
    the
    west.
    The
    mine
    will
    drop
    land
    from
    the
    north
    to the
    south,
    meaning
    water
    levels
    of
    McDavid
    Branch
    Creek could
    be
    affected
    over
    the
    course of
    ten
    or
    more
    years.

    page
    2
    If
    less
    water
    is available
    from
    McDavid
    Branch
    Creek, it
    would
    seem
    the
    lake
    would
    suffer
    further
    problems.
    It
    could
    possibly
    mean
    that
    Ameren’s
    plans
    for
    adequate
    water
    resources for
    their
    cooling
    processes could
    be
    seriously impaired.
    While
    Ameren
    is
    claiming
    economic
    conditions
    and
    the
    cost
    of
    possible
    cooling tower
    improvements
    as
    to
    why
    they
    should
    be
    given
    regulatory
    relief,
    public
    sources
    show
    their
    electric
    division
    revenue
    for
    2008
    was
    $6.37
    billion
    out
    of total
    revenue
    for
    the
    company
    of
    $7.84
    billion.
    I think
    it
    is
    valid
    for
    citizens
    to
    ask,
    and
    for
    agencies
    to
    consider
    why
    such
    large
    companies
    should
    not
    be
    required
    to come
    up
    with
    better
    solutions
    to
    problems that
    what
    Ameren is requesting
    in this
    case.
    The
    temperature
    relief
    allows
    Ameren
    to
    continue
    business
    as
    usual
    and
    the
    lake
    and
    the
    fish
    and
    other
    things affected
    by
    this
    lake
    will
    bear
    the
    burden.
    Yes
    it
    is the
    cooling
    lake
    for the
    power
    plant,
    however,
    the
    water
    they
    are
    utilizing
    comes
    from
    the
    area
    environment
    and
    is
    part
    of
    the
    resources
    of
    this
    state
    and
    should
    be
    a
    consideration.
    I
    thank
    the
    Illinois
    Environmental
    Protection
    Agency
    for
    opposing
    this
    “relief
    from
    current
    thermal
    limits.”
    Thank
    you
    for
    the
    opportunity
    to
    provide
    these
    comments.
    Sincerely,
    Blumenshine

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