RECEIVED

CLERK’S

OFFICE

OCT

2 62000

STATE OF ~WNOIS

Dorothy Gunn, Clerk

Pollution Control Board

Illinois Pollution Control Board

100 W. Randolph, Suite 11-500

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Chicago, Illinois 60601

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Ms. Gunn,

I am writing to comment on the matter of the Natural Gas-

Fired, Peak-Load Electrical Power Generating Facilities, and

Docket Number ROl-lO.

On July

6th,

2000 Governor Ryan

requested the Illinois Pollution Control Board to conduct

inquiry hearings, and provide the Governor the Board’s

findings ofthe Board’s deliberations. I would like to comment,

as an individual citizen, to the Governor’s questions.

Do peaker plants need to be regulated more strictly than

Illinois’ current air quality statutes and regulations

provide?

The simple answer to this question is yes.

It is

myunderstanding that at the present time the State of

Illinois has received applications to approve over 60

differentpeaker plant proposals, a majority ofthose in

the Chicago Metropolitan

area.

As you know the State of

Illinois needs to develop a NOx SIP plan, and the

accumulative impact of these plants needs to be

considered on the air quality ofthe Chicago metropolitan

area, and this can not be accomplished by look at permits

one at a time.

In addition the Chicago area is an ozone

non-attainment area, and this also needs to be considered.

Do peaker plants pose a unique threat, or a greater threat

than other types of State-regulated facilities, with respect

to air pollution, noise pollution, or groundwater or

surface water pollution?

With respect to groundwater I

believe the answer is clearly, yes.

Depending on the type

ofpeaker plant, groundwater can be a major issue.

In my

township, Big Rock, a Peaker Power Plant is proposed

that would use groundwater as its’ source ofwater.

Big

Rock Township does not have any public water supplies

and all residents depend on groundwater.

It seems to me

that in those circumstances extraordinary care should be

made in permitting this use,

and

also extraordinary public

information should be available to residents, and

landowners.

Shouldnew or expanding peaker plants be subject to

siting requirements beyond applicable local zoning

requirements?

In my opinion the simple answer to this

should be yes.

The Peaker Plant proposed for Big Rock

Township would be located right in the middle ofwhat is

now agricultural land, and is inconsistent with the Kane

County

2020

plan.

It seems to me that long range

benefits would accrue to the residents ofthe State of

Illinois if the State had a policy a preferring brownfield

sites for Peaker Plants, over using prime Illinois

agricultural land.

We have many brownfield sites that

would benefit from the location of these plants.

Ifthe Board determines that peaker plants should be

more strictly regulated or restricted, should additional

regulations or restrictions apply to currently permitted

facilities or only to new facilities and expansions?

order to

achieve the best results for all citizens ofIllinois

and continue to improve the State’s air quality, especially

in East St. Louis

and

the Chicago area these regulations

and restrictions should apply to all

facilities, old and new.

How do other states regulate orrestrict peaker plants?

am sure that your work will find that many other states

have more requirements in this regard than does Illinois.

Finally, I would ask the Illinois Pollution Control Board to

place a moratorium on air permits until at least the

accumulative effects ofthese plans on the NOx SIP call is

completed, understanding the ozone implications, and

perhaps most importantly the effect on the State’s

Groundwater resources.

Thank you, for the opportunity to comment

(L~f~to~