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2025 Windsor Drive

Oak Brook, DIInois 60523

Telephone 630.372.9393

September 18, 2006

Office of the Clerk

Illinois Pollution Control Board

100 W. Randolph St.

Chicago, IL 60601

No . 5813

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RECEIVEDOFFICE

SEP 2 0 2006

pn1STATE

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ILLINOIS

Re: Proposed New 35 ILL . ADM. CODE 225, Control of Emissions fro trrz argerCom sttonard

Sources (Mercury) ; R06-25

Dear Honorable Members of the Board:

I am writing to express Advocate Health Care's support for the Illinois Environmental Protection

Agency's proposed rule to reduce mercury pollution, as amended to include the recent

agreements with Ameren and Dynegy . This rule is absolutely critical to protect the health of all

Illinoisans - especially women of childbearing age, children and the unborn - and is

technologically feasible and cost effective.

As you know, mercury is a neurotoxin that can pass through the placenta and poison fetal brain

development. Every day, thousands of developing fetuses, newborns and young children are

exposed to mercury when pregnant and nursing women eat contaminated fish, or children eat

fish themselves . Nationally, 6 to 10 percent of women of childbearing age are estimated to have

mercury levels high enough to put their developing children at increased risk for developmental

problems. Here in Illinois, that translates to more than 100,000 women of childbearing age

whose blood mercury levels may exceed the federal recommended limit .

Coal plants produce 71 percent of the mercury pollution emitted in Illinois and 60 percent in the

Great Lakes state as a whole . The southern Great

Lakes region has among the highest mercury

deposition rates in the U .S. In Illinois, mercury pollution has created severe mercury "hot

spots," areas where the threat to public health is elevated

. In fact, Illinois ranks fourth in the

U.S. for most severe mercury pollution hot spots

.

What's the result of all this mercury pollution? Fish in Lake Michigan and all Illinois waterways

are contaminated with mercury. The problem is so bad that the Illinois Department of Public

Health wars everyone - particularly pregnant women, women of childbearing age and children

- to limit their consumption of fish from every lake, river and stream in Illinois .

Much of mercury pollution comes from local and regional sources

. So by reducing mercury

pollution at its largest sources - coal-fired power plants - we can reduce mercury concentrations

in fish and lower the harmful effects of mercury exposure

. In one study, for instance, reductions

in mercury emissions led to an 80 percent decline in mercury contamination levels in nearby fish.

Ilinois must take action on mercury pollution because a new federal mercury rule scheduled to

take effect later this fall is simply too little, too late

. The federal rule will perpetuate mercury hot

spots like those in Illinois by allowing coal plants to continue using older technology and

wnadvoamhealth.com

Related to the Evangelical Lutheran Church in America and the United Church of Christ

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purchase the right to continue polluting at high levels rather than installing equipment to clean up

their plants and protect our health and environment .

Illinois is not alone

. Wisconsin, Mas

aanhusetts,

Michigan, Minnesota, Ohio, and Pennsylvania,

among others, have initiated mercury reduction proposals similar to the Illinois rule, showing the

rule is reasonable and based on achievable mercury reduction goals .

Affordable, readily

available technology already has been shown to reduce mercury pollution from coal plants by as

much as 95 percent. We don't need additional studies or research.

We need to move forward

now to protect the health of our children and future Illinoisans

.

A large, diverse coalition of doctors, hospitals, public health officials, children's advocates,

health associations and environmental groups throughout Illinois support the proposed rule

before the IPCB

. But what really speaks volumes about this issue is the fact that Ameren and

Dynegy have already agreed to cut mercury pollution from their power plants by 90 percent in

the coming years . It's time to codify their agreements in law, and to require companies like

Midwest Generation that haven't accepted their corporate responsibility to do the same.

Ely Forko

D'

r, Strategic Planning