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ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, DECEMBER 15, 2005
BEFORE TILE ILLINOIS POLLUTION CONTROL BOARD
DYNEGY MIDWEST GENERATION, INC .
(VERMILION POWER PLANT),
Petitioner,
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY,
Respondent
.
To
:
Pollution Control Board_ Attn : Clerk
James R. 1 hompson Center
100 W. Randolph. Suite 11-500
Chicago, Illinois 60601
Bradley Halloran
Hearing Officer
Pollution Control Board
James R. Thompson Center
100 W. Randolph, Suite 11-500
Chicago, Illinois 60601
PLEASE TAKE NOTICE that I have today filed with the Office of the Clerk of the
Pollution control Board Petitioner's Response to the Agency's Motion for Extension of Time
to File Record, a copy of which is herewith served upon each of you .
Kathleen C Bassi
NOTICE OF FILING
Robb Layman
Sally Carter
Division of Legal Counsel
Illinois Environmental Protection Agency
1021 North Grand Avenue, East
P.O. Box 19276
Springfield, Illinois 62794-9376
PCB 06-073
(Permit Appeal - Air)
 
ELECTRONIC FILING. RECEIVED, CLERK'S OFFICE, DECEMBER 15, 2005
Dared
:
Dcccmhcr I5. _'005
Shcldon A. Label
Kathleen C. 13assi
Stephen J. Bonebrake
Joshua R. More
Kavita M . Patel
SCI tIFF I IARDIN,
1.[.P
6600 Sears Toner
233 South VVackcr Drive
Chicago, Illinois 60606
312-258-5500
lax: 3 12-258-5600
 
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, DECEMBER 15, 2005
BEFORE TFIE ILLINOIS
POLLI!7'ION
CONTROL BOARD
DYNEGY MIDWEST GENERATION, INC .
)
(VERMILION I'OWER PLANT),
)
Petitioner,
)
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
Respondent
.
)
PCB 06-073
(Permit Appeal - Air)
RESPONSE TO AGENCY'S MOTION
FOR EX'T'ENSION OF TIME TO FILE RECORD
NON-' COMES Petitioner, Dynegy Midwest Generation, Inc ., by and through its
attorneys, Schiff Ilardin, LLP, and responds to the Illinois Environmental Protection Agency's
("Agency'') Motion for Extension of Time to File Record in the above-captioned matter, stating
as follows
:
The Agency represents in its Motion that the record in this matter is voluminous
and that, having insufficient staffing of its own to perform the copying, it has had difficulties in
finding a copy service willing to perform the task necessary here . The Agency observes in its
Motion that while many permit appeals are protective in nature and so do not necessarily require
the tiling of a record, the complexities in this appeal make it more likely that the record will be
necessary. Finally, the Agency requests an indefinite extension of time in which to file the
record .
Petitioner agrees that while some issues in this matter may he addressed through
discussion and agreement between the parties, it is premature to determine whether that is true
-3-
 
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, DECEMBER 15, 2005
for anv, much less all. of the issues raised in the appeal . 'I 'hereIore, it is neeessarv and
appropriate that the Agency tile the record in this appeal
.
Petitioner also understands the Agency's problem in preparing the record for
filing and does not object to the Board's granting the Agency an extension of time to file the
record. I lowever. Petitioner requests that the Board grant such extension of time until January
26, 2006, with leave to seek a further extension if the Agency has been unable to prepare and file
the record by that time
.
4
.
Finally. Petitioner understands that the Agency may seek to reduce its copying
burdens relative to the record through filing fewer than the number of copies mandated by the
Board's rules. The Agency has discussed this with Petitioner, and Petitioner has no objection to
the Board granting the Agency reasonable relief from that requirement .
Respectfully submitted
.
DYNEGY MIDWES L GENERATION, INC
.
(VERMILION POWER PLANT)
Dated :
December 15, 2005
Sheldon A. Label
Kathleen C. Bassi
Stephen J . Bonebrake
Joshua R. More
Kavita M. Patel
SCHIFF HARDIN, LLP
6600 Sears Tower
233 South Wacker Drive
Chicago. Illinois 60606
312-258-5500
Fax: 312-258-5600
-4-
One of Its Attorneys
 
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, DECEMBER 15, 2005
BEFORE TIlE ILLINOIS POLLUTION CONTROL BOARD
DYNEGY MIDWEST GENERATION, INC
.
(VERMILION POWER PLANT),
Petitioner,
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY,
Respondent.
by electronic deli 'er_e upon the following
person :
Pollution Control Board. Attn: Clerk
James R. l'hompson Center
100 W. Randolph. Suite 11-500
Chicago. Illinois 60601
CERTIFICATE OF SERVICE
I, the undersigned, certify that I have served the attached Appeal of CAAPP Permit of'
Dy negy Mirhvest Generation, Inc., (Vermilion Power Plant),
- 5-
PCB 06-073
(Permit Appeal - Air)
and by electronic and first class mail upon
the following person
:
Rohb Layman
Sally Carter
Division of Legal Counsel
Illinois Environmental Protection Agency
1021 North Grand Avenue. Past
P.O. Box 19276
Springfield, Illinois 62794-9276
rc hh
Iaymai
Cu
epastate.iI
.u_s
sat t
v,carter%a%ena.
state . il.us
Bradley 1-lalloran, Hearing Officer
Pollution Control Board
James R. Thompson Center
100 W. Randolph, Suite, 11-500
Chicago, Illinois 60601
hal l orah(a) ipcb. state . i I . us
 
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, DECEMBER 15, 2005
Dated :
December I . . 2005
Sheldon A . Zahel
Kathleen C. Bassi
Stephen J . l3onehrake
Joshua R . More
Kacita M. Patel
S('[ [I[ :[-- I IARDIN. LLP
6600 Scars Tower
2's', South NVacker Drive
Chicago, Illinois 60606
312-2 58-5500
1 ax: 312 258-5600
(
.111,134'S62I

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