To :
Mr. Robb Layman
Ms. Sally Carter
Illinois Environmental
Protection Agency
Division of Legal Counsel
1021
North Grand Avenue
Post Office Box
19276
Springfield,
IL 62794-9276
James T . Harrington
David L . Rieser
McGuireWoods LLP
77 West Wacker, Suite 4100
Chicago, IL 60601
Telephone: 312/849-8100
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
AMEREN ENERGY
)
GENERATING COMPANY,
)
COFFEEN POWER STATION,
)
Petitioner,
)
v .
)
PCB 06-64
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
Respondent .
)
NOTICE OF FILING
Ms. Dorothy Gunn, Clerk
Bradley P. Halloran, Hearing Officer
Illinois Pollution Control Board Illinois Pollution Control Board
James R. Thompson Center
James R. Thompson Center
1000 West Randolph Street
1000 West Randolph St., Suite 11-500
Suite 11-500
Chicago,
IL 60601
Chicago, IL
60601
Please take notice that on December 19, 2005, the undersigned caused to be filed with the Clerk of
the Illinois Pollution Control Board a Response to Agency Motion for an Extension of Time to File the
Record, a copy of which is herewith served upon you
.
i
James T .
ington
One of the Attorneys to P
tioner
C
HITS OFFICE
D
L
IC
P
LU
STATE OF ILLIPCIS
Pv:,u. ion Cotntio Cc rc!
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
AMEREN ENERGY
)
CL
a;1 ;':' OFFijE
GENERATING COMPANY,
)
COFFEEN POWER STATION,
)
Petitioner,
)
v .
)
PCB 06-64
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
Respondent
.
)
RESPONSE TO AGENCY MOTION FOR AN EXTENSION OF TIME
TO FILE THE RECORD
NOW COMES the Petitioner, by its Attorneys, James T. Harrington, David R. Rieser and
McGuireWoods LLP and for its response to the Motion for Extension of Time to File the Record, states as
follows .
I
.
The Illinois Environmental Protection Agency (the "Agency") has indicated that some
issues raised by Petitioner may be resolved and therefore an indefinite delay in filing the record is
appropriate . Petitioner agrees that while some matters may be resolved, others are likely to proceed and
the record should be filed .
2
.
Petitioner, however, understands that the Agency has completed compilation of the record
but is having difficulty arranging for the copying of the record .
3
.
Petitioner, therefore, does not object to the Board granting a reasonable extension of time
within which the record will be filed to a date certain and does not object to the Agency filing one copy of
the record with the Board .
4 .
Petitioner suggests an extension to January 26, 2006 without prejudice to the right of the
Agency to seek an additional extension should it prove necessary
.
r,- r .
I- ,
11
1
'05
STATE OF ILLIP(118
Pcl,ut rm Control jord
Dated
:
McGuireWoods LLP
77 West Wacker, Suite 4100
Chicago, IL 60601
Telephone: 312/849-8100
CERTIFICATE OF SERVICE
I, James T. Harrington, one of the attorneys for Petitioner, hereby certify that I served a copy of
Response to Agency Motion for an Extension of Time to File the Record upon those listed on the attached
Notice of Filing on December 19, 2005 via First Class Mail, postage prepaid
.
\\REA\292056 .
1
Respectfully submitted,
s
. Harrington
e of the Attorneys for Petitioner
McGuireWoods LLP
77 West Wacker, Suite 4100
Chicago, Illinois 60601
Telephone: 312/849-8100