RECEIVED
    BEFORE THE ILLiNOIS POLLUTION CONTROLBOARD
    CLERK’S OprrCp
    NOV06 2O0~
    IN THE MATTER
    OF:
    )
    STATE
    OF
    )
    POII~tj0t,Co~t~0
    Board
    NATURAL GAS-FIRED,
    PEAK LOAD
    )
    ROl-lO
    ELECTRICAL POWER GENERATING
    )
    FACILITIES (PEAKER PLANTS)
    )
    COMMENTS OF THE ASSOCIATION OF ILLINOIS ELECTRIC COOPERATIVES
    The Association ofIllinois Electric Cooperatives
    is the statewide service organization for
    Illinois’
    27
    electric
    cooperatives.
    The
    25
    electric
    distribution
    cooperatives
    provide
    electric
    service to more
    than 600,000 Illinoisans,
    located primarily in rural areas of 86 of the
    state’s
    102
    counties.
    Two generation and transmission cooperatives supply wholesale power to the majority
    of the state’s distribution cooperatives.
    Illinois electric
    cooperatives are not-for-profit organizations.
    Each electric cooperative
    is
    governed by a
    board of directors,
    nominated and
    elected
    by the member-consumers who receive
    electric
    service
    from
    that
    cooperative.
    Local
    control
    through
    the
    locally-elected
    boards
    of
    directors ensures all cooperative member-consumers a voice in rates,
    policies, member rights and
    other matters relating to the operation of their electric cooperative.
    First
    organized
    in
    the
    1930’s
    and
    1940’s,
    Illinois
    electric
    cooperatives
    today
    remain
    dedicated to
    providing an adequate
    supply of electric
    power at the most reasonable cost possible
    to ensure the economic prosperity and well-being oftheir member-consumers.
    The
    1997 Illinois
    electric
    deregulation
    law
    recognized
    the
    unique
    nature of electric
    cooperative
    and
    municipal
    electric
    systems
    --
    both
    operate
    on
    a
    not-for-profit
    basis
    and,
    in
    each
    instance,
    the
    systems’
    consumers
    are also the owners of the
    system.
    Article XVII of Illinois’
    deregulation law grants
    co-ops
    and
    municipal
    systems
    “local
    control”
    over
    decisions
    relating
    to
    a
    deregulated
    marketplace.
    Since the enactment ofthat law,
    each electric cooperative board
    has been diligently
    studying how to
    best serve their member-consumers in the new marketplace.
    Prompted
    in part
    by price volatility during the summers of
    1998
    and
    1999,
    a number of cooperatives
    have taken
    steps to secure
    additional generation
    capacity.
    Two
    Illinois
    cooperatives
    have
    recently
    announced
    plans
    to
    increase
    coal-fired
    generation, using advanced “clean
    coal” technologies.
    Several other
    cooperatives
    have decided
    to utilize natural-gas-fired peaker plants.
    Electric cooperatives
    --
    local organizations in the truest
    sense
    --
    are committed to being good
    neighbors.
    Where peaker plants have been utilized,
    it has
    been in
    response to the needs
    of the
    co-op’s
    retail
    member-consumers.
    In
    each
    case,
    planned
    peaker plants
    have been located in
    sparsely-populated and remote rural downstate areas, without
    objection from local residents, and with the support of local government.
    The Illinois Environmental Protection Agency’s public position has been that evaluations
    of new peaker plants for which it
    has received permit applications have indicated that the plants
    will
    not
    have
    a
    measurable
    impact
    on
    air
    quality;
    further,
    that
    if
    a
    source
    does
    not
    have
    measurable impact on
    air quality, there should not
    be an
    adverse health impact.
    We believe that
    the
    1PCB
    hearings have not produced strong
    evidence to
    the contrary.
    In fact,
    a great deal
    of
    testimony
    indicates
    that
    peaker
    plants
    are
    among
    the
    “cleanest”
    answers
    to
    the
    need
    for
    additional generation capacity.
    Sufficient
    generation
    capacity
    is
    absolutely
    essential
    to
    fulfilling
    the
    responsibility of
    providing
    adequate,
    reliable energy at
    an affordable price.
    The
    electric
    cooperatives of Illinois
    respectfully
    suggest
    that to
    impose
    new
    and
    burdensome
    regulations
    regarding
    installation of
    new
    gas-fired
    peaker
    plants,
    especially in
    light
    of California’s
    recent
    experiences,
    would
    be
    unwise,
    Respectfl.illy submitted,
    By:____
    Earl W. Struck
    President/CEO
    Date:
    November 3, 2000
    Earl W.
    Struck
    President, Association of Illinois
    Electric Cooperatives
    P.O.
    Box 3787
    Springfield, IL 62708
    (217)
    529-5561

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