AMERENENERGY RESOURCES

GENERATING COMPANY,

EDWARDS POWER STATION,

V .

Petitioner,

ILLINOIS ENVIRONMENTAL

PROTECTION AGENCY,

Respondent .

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

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

.

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

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

'

,

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I i j\ w,

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B

ames T. Harrington

One of the Attorneys for Pe

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CLEF,'t :'; OFFICE

DEC 1

" 2005

STATE OF

ILLINOIS

Pollution Control Board

1

---

V

.

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

AMERENENERGY RESOURCES

)

GENERATING COMPANY,

)

EDWARDS POWER STATION,

)

Petitioner,

)

PCB 06-67

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 .

1

.

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 .

CLERF; S OFFICE

CrC 1

2005

STATE OF

ILLINOIS

I'oflutinr Control board

---

Dated : 10 i~

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I t

c

McGuireWoods LLP

77 West Wacker, Suite 4100

Chicago, IL 60601

Telephone: 312/849-8100

\\REA\292319 . 1

Respectfully submitted,

1

74

es T. Harrington

avid L. Rieser

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

.

,

/ I I

//1 /i

es T. Harrington

the of the Attorneys for Petitione

McGuireWoods LLP

77 West Wacker, Suite 4100

Chicago, Illinois 60601

Telephone: 312/849-8100