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November 6, 2000

Please accept these comments on behalf of the Sierra Club, Illinois

Chapter, representing over 23,000 members in Illinois.

From our perspective, the current proliferation of natural gas-powered

electric plants raises serious concern for air quality, water quality, and

water quantity.

Regarding water quantity; the relatively sudden proposals for new power

plants that consume large amounts of water have exposed a gaping hole in

the State's efforts to protect our water resources. While it has been

established that the State has the authority and the legal obligation to

protect natural conditions in Illinois waterways, this authority has not

been utilized. In particular, no approval by the State is currently

required by the Office of Water Resources for most new withdrawals of

ground or surface water. With strong competition for existing water

sources, an active state role in managing water use is essential.

Specifically, state approval should be required for any new withdrawal

from surface or groundwater sources exceeding 10,000 gallons per day.

The primary water quality concerns from these facilities result from the

potential for substantial discharge of process water. These discharges, no

matter how clean, could significantly degrade the habitat of a smaller

stream by changing the flow regime. The discharge of heated water can also

degrade habitat for aquatic life. Fortunately, the State does have the

National Pollutant Discharge Elimination System in place to provide some

framework for regulating these threats, but improvements are needed. In

particular, strong antidegradation rules (currently the subject of another

Board proceeding) should be adopted to protect streams against these new

discharges.

While generating electricity from natural gas is much cleaner than

generating power from coal combustion, there are air quality

considerations in this debate as well. In particular, clearly the time has

come for the State to reconsider the current exemption of new pollution

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sources in the Chicago nonattainment area from Reasonably Available

Control Technology (RACT) requirements. As a result of this exemption,

neighbors of these newer power plants get significantly less protection

than they would if they lived near the same plant in another nonattainment

area. We also recommend consideration and adoption of more protective

emissions standards for these facilities, as are currently required in

California, for example.

We believe that natural gas-fired power plants have a role in Illinois'

near-term energy production mix. However, the current list of proposed new

plants would produce many times more power than Illinois is projected to

demand, and we do not have adequate safeguards in place to protect our air

and water from this phenomenon. We support calls for an immediate

moratorium on the permitting and construction of new facilities so that we

can examine the policies of the state that are making our communities

magnets for these facilities.