RECEIVED
    ~ ~‘RicsOFFICF
    BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
    ~
    06 2000
    STATE
    OF IWHO
    Is
    P0/lU
    ft
    on Qn~
    IN THE MATTER OF:
    )
    ro, ~
    )
    NATURAL GAS-FIRED, PEAK-LOAD
    )
    ROl-lO
    ELECTRICAL POWER GENERATING
    )
    ~
    FACILITIES (PEAKER PLANTS)
    )
    t
    ‘~
    COMMENTS OF THE ILLINOIS MUNICIPAL ELECTRIC AGENCY
    The Illinois Municipal Electric Agency (“IMEA”) is anot-for-profit unit of
    municipal govermnent made up of 39 of the State’s 42 municipally-operated electric
    systems. The municipal systems of Illinois are relatively evenly distributed through the
    control areas of Commonwealth Edison, Illinois Power and AmerenCIPS. These
    municipal systems serve approximately 475,000 Illinois citizens.
    The IMEA’s primary function is to provide wholesale electricity to its members.
    The individual municipally-operated electric systems then resell that electricity to their
    retail customers. IMEA’s power comes from a variety of sources. IMEA owns some
    generating facilities and also contracts for additional power with other power providers.
    This can and does include the purchase of power on the daily market in peakperiods.
    Not only does IMEA arrange for a sufficient quantity of electricity, it also schedules the
    delivery ofthat power to each community over the State’s transmission grid on a real
    time basis.
    At this time, IMEA has contracts with 28 Of the State’s 42 municipal systems to
    provide all, or most, of their wholesale electricity. While our peak load is not large when
    compared to the biggest utilities, our members’ peak has grown significantly in recent
    years. It is up 33 over the past decade, from 300 MW to 400 MW.
    Since municipal systems are essentially islands and few have sufficient generation
    to satisfy their own needs, avibrant wholesale power market is vital for the health and
    well-being of our members’ citizens. It is instructive to remember that electricityis the
    only product that must be produced atthe exact moment it is consumed. Because ofthis
    fact, areliable electric market requires generation sources in comfortable excess of
    projected peak demand. Without sufficient resources, prices will increase and reliability
    will suffer. California in the summer of2000 is the best example ofthe truth ofthat
    statement.
    In addition, generation sources should be located in relatively close proximity to
    the load they serve. Today’s transmission grid is not the interstate highway to which
    some have compared
    it.
    Rather,
    it
    is acrosshatching oftwo lane roads with many areas
    of heavy traffic and troublesome congestion on the busiest days. Those high volume,
    peak load days create transmission bottlenecks that have threatened parts of the State
    with mandatory curtailments as recently as this summer.
    As a result of our day to day experience in the power market, we respectfully
    request that the State do nothing to create power shortages in Illinois through new and
    restrictive regulation of natural gas-fired, gas turbine peaking plants. They are, by almost
    anymeasure, the cleanest source of power generation available today that can satisfy
    peak load needs.
    Of course, it would be ideal if even greener sources of power, such as wind, solar,
    or hydro, could satisfy the State’s growing needs. But such sources of power are not
    2
    available on demand and often, in peak times, are not available at all. ~lherefore,we are
    left with natural gas-fired peaking facilities as the best alternative.
    Without sufficient power generation, higher costs and diminished reliability
    (perhaps severely diminishedreliability) will result. Natural gas-fired peaking plants are
    a vital component in the State’s power portfolio and their construction and operation
    should not be discouraged by unnecessary and burdensome new regulations.
    The IMEA appreciates the opportunity to comment in these proceedings.
    Respectfully submitted,
    By~~
    General Manager & CEO
    Dated: October 31, 2000
    Mr. Ronald D. Earl
    General Manager & CEO
    Illinois Municipal Electric Agency
    919 South Spring Street
    Springfield, Illinois 62704
    (217) 789-4632
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