ILLINOIS POLLUTION CONTROL BOARD
    October
    5,
    1982
    It~
    THE MATTER OF:
    )
    RACT II RULES,
    )
    R80-5
    CUAPTER 2:
    AIR POLLUTION
    CONCURRING OPINION
    (by J.D.
    Dumelle and
    N.E.
    Werner):
    Our reasons for concurring are
    the possible serious eco—
    nomic effects of these regulations upon Illinois industry and
    the recent evidence that Illinois may not need further hydro-
    carbon reductions.
    Illinois industry is
    in
    a recession.
    The Rockford,
    Decatur,
    and Peoria areas are on the national list of
    10 urban areas of
    highest unemployment.
    And for Illinois itself, unemployment
    now exceeds 12
    -—
    an exceedingly
    high
    Eigure.
    These additional hydrocarbon controls or process or pro-
    duct changes will cost money.
    Industry,
    in a recession,
    must
    husband its financial resources to pay fixed costs which con-
    tinue even as sales and output
    fall.
    And businessmen considering relocation to
    the
    Sun Belt
    or elsewhere may easily interpret these additional costs im-
    posed by the State as indicative
    of an unfeeling attitude toward
    their extreme situation.
    Are these additional regulations really needed?
    No violations
    of the national
    (identical with Illinois) ambient ait quality
    standard
    for ozone were recorded anywhere in the State
    in 1982.
    Why then are further controls necessary when IEPA,
    the proponent,
    admits that earlier theoretical models used in the 1978—79
    RACT—I proceeding “overcontroiled”?
    The only arguments advanced
    are those of decreased industrial output and reduced car usage
    because of the recession and possible favorable meteorological
    conditions.
    Another reason for controls is often not voiced.
    It
    is that
    the Federal government “expects”
    Illinois to enact these new
    rules and may promulgate them
    if
    the State does not.
    But
    how
    can the case be made for promulgation if no violations exist?
    We would have preferred not to enact regulations statewide
    so as to spare Rockford,
    Decatur,
    and Peoria possible further
    burdens.
    But there
    is no easy way to hold the regulations
    in
    abeyance while enacting those
    in non—attainment areas only.
    This order is
    a compromise.
    It immediately enacts
    the new
    controls in non—attainment and immediately adjacent counties.
    It puts the beginning of the control programs off to 1987
    49-65
    2
    for the remainder of the State including
    the
    Rockford,
    Decatur,
    and Peoria areas.
    It
    is our hope that 1983 and 1984 ~iillalso show no ozone
    violations.
    If that in fact happens,
    then industry should
    promptly ask the Board
    to repeal
    those pending controls which
    trigger in 1986.
    Finally,
    in any further scientific studies on ozone re-
    duction, the possibility of controlling oxides of nitrogen
    ought
    to be explored.
    There are few further sources of hydro-
    carbons that can be controlled without great expense.
    1-
    ~.
    I, Christan
    L.
    Moffett, Clerk of the Illinois Pollution
    Control Board,
    hereby certify that th?~above Concurring Opinion
    was filed on the
    ~~day
    of~j~i~~___
    ___,
    1982.
    Christan L.
    Moff t~.rclerk
    Illinois Pollution control Board
    Chairman
    C
    •1
    /
    49-66

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