BEFORE THE POLLUTION CONTROL BOARD
    OF THE STATE OF ILLINOIS
    IN THE MATTER OF:
    )
    )
    NATURAL GAS FIRED, PEAK LOAD
    )
    R01-10
    ELECTRICAL POWER GENERATING
    )
    FACILITIES (PEAKER PLANTS)
    )
    WRITTEN SUBMITTAL
    TO:
    Ms. Dorothy M. Gunn
    Ms. Amy L. Jackson, Esq.
    Clerk of the Board
    Hearing Officer
    Illinois Pollution Control Board
    Illinois Pollution Control Board
    James R. Thompson Center
    600 South Second Street
    100 West Randolph Street
    Suite 402
    Suite 11-500
    Springfield, IL 62704
    Chicago, IL 60601
    Please find enclosed a submittal from Jim LaBelle, Chairman, and Sandy Cole and
    Bonnie Thomson Carter, Members, of the County Board, Lake County, Illinois for the above
    referenced matter.
    Respectfully submitted,
    Jim LaBelle, Chairman
    Lake County Board
    Lake County, Illinois
    November 6, 2000
    Ms. Dorothy M. Gunn
    Clerk of the Board
    Illinois Pollution Control Board
    James R. Thompson Center
    100 West Randolph Street
    Suite 11-500
    Chicago, Illinois 60601
    Ms. Amy L. Jackson, Esq.
    Hearing Officer
    Illinois Pollution Control Board
    600 South Second Street
    Suite 402
    Springfield, Illinois 62704
    Dear Ms. Gunn and Ms. Jackson:
    We would first like to thank the Illinois Pollution Control Board for the opportunity to
    participate in the Public Hearings on Peaker Power Plants, and further to commend the
    Board and the staff on the professional manner in which the hearings were conducted.
    A great deal of highly technical information, as well as emotionally charged testimony,
    was presented to the Board, and through it all, the Board and staff conducted
    themselves in a fair and impartial manner.
    At the conclusion of the Lake County testimony provided at the Public Hearing in
    Grayslake on September 21, 2000, the IPCB provided the County the opportunity to
    submit recommendations for siting requirements. Per your request, the following are
    Lake County’s suggestions for further consideration by the Illinois Pollution Control
    Board (IPCB).
    •
     
    Lake County continues to request that a moratorium be placed on all pending peaker
    plant air quality permits until such time as all outstanding peaker (merchant) power
    plant permitting issues are resolved.
    •
     
    Lake County requests that as current IEPA permits expire, un-built peaker power
    plants shall not be grandfathered. We request that a new permitting process be
    required under the new regulations.
    •
     
    Lake County requests that the NOx waiver be lifted relative to generating facilities
    from the six-county non-attainment area, which includes the severe non-attainment
    area of Lake County.
    •
     
    Lake County supports changing 40CFR52.21 to include peakers and we ask that it
    be modified to include non-steam electrical (peakers). Modifying 40CFR52.21 will
    achieve BACT/LAER (Best Available Control Technology/Lowest Achievable
    Emission Rate), public hearings and comment periods and appeal processes.
    •
     
    Lake County requests that start-up and shutdown emissions be accounted for in the
    request for IEPA permitting, as equipment startups and shutdowns will account for a
    greater proportion of emissions than traditional plants. Although we believe this to be
    required by the USEPA, there may not be consistency in implementation by the IEPA
    due to application requirements.
    •
     
    Lake County requests that emissions generated during equipment startup and
    shutdown shall be regulated by a separate set of limitations to optimize emission
    control. Permit conditions should limit the amount of daily startups and shutdowns.
    •
     
    Lake County requests that the IEPA require an ambient air quality impact analysis of
    the petitioner as part of the emissions permit.
    •
     
    This impact analysis should not allow pollution outputs to be considered over a
    twelve-month period but rather the three-month period peaker plants are likely to
    operate.
    •
     
    Further the impact analysis should consider that peaker plants are likely to operate
    on days when the ozone is high and the air quality is poor.
    •
     
    Lake County requests that the use of optimum control technology be required even if
    regulations can be met using lesser technology. As technology advances,
    permitting regulations should be tightened.
    •
     
    Lake County sees a need for a regional siting process, governed by the IPCB (or
    other appropriate agency). We feel this siting process should maintain local control of
    zoning, but provide for a forum, and the necessary technical expertise to review all
    air, water supply and quality, stormwater runoff, waste water discharge and noise
    issues. Following individual air and water (etc) permits and local zoning approvals,
    this review would result in the issuance of a siting permit.
    •
     
    A regional siting process must include enough data on water supply, air quality,
    etc. are readily available from the State. Currently, local governments do not
    have the data or resources needed to make informed decisions.
    •
     
    Lake County requests that IEPA consider forming regions based on attainment
    zones. These zones would then be a factor in issuing peaker power plant
    permits.
    •
     
    Provisions should be made to have experts on the issues involved review
    applications together when applicable. Many of the criteria involved in the review
    are interrelated.
    •
     
    The impact of multiple peaker plants must be a crucial consideration of the
    regional review board. Additionally, the impact of and to neighboring regions
    must be mitigated.
    •
     
    Lake County requests that permitting regulations be more stringent if the power
    generated by peaker plants is to be sold outside of Illinois. Moreover, that the entity
    seeking the permit must demonstrate to the appropriate agency where the power will
    be sold. Such demonstration should be through power purchase agreement and/or
    letters of intent with affidavits confirming that the power purchased and sold will be
    used to meet end use consumption.
    •
     
    Lake County would like the IPCB to formally recognize that water supply issues are a
    major concern and need to be addressed in the permitting process.
    •
     
    Lake County requests that the IPCB require the approved siting agency to work with
    the Midwest Independent System Operator ("ISO") on locating generation, taking into
    account alternatives such as other sites throughout the state and alternatives such
    as constructing new transmission lines and rate incentives for end users.
    •
     
    Lake County requests that the IPCB and appropriate state agencies participate in a
    statewide planning process for electric infrastructure growth, and that such planning
    is done in concert with the requests above. Such a planning process will allow a
    statewide agency to have a broader perspective and to fairly evaluate the benefits of
    such electric infrastructure growth and the intended benefits.
    Again, we appreciate the opportunity to offer our input and also appreciate the receptive
    manner with which our public testimony has thus far been received.
    Sincerely,
    Jim LaBelle
    Sandy Cole
    Bonnie Thomson Carter
    Chairman
      
    Member
      
    Member
    Lake County Board
    Lake County Board
    Lake County Board

    Back to top