fs
W NV. Wtuhinl too Blvd
.
.1'icrgo, IL 606(1-1875
'line
: (312) 24? 2000
I'm: (312) 243-3 154
raro lungchicag org
.7oug.as
A . Grab m, Esq .
Hoard Chair
Juao I)
. Boomem ,
NIP, MBA
Chai,El"I
Lewis J, Smith, h 0
:'ice Chair
Stevcu L . victor
'rYearurer
ireid B. Yel in, E
q .
Secretary
!'tamicl PA . Clau lio, MD
Fast hoard Chair
'Ow( J . AOick
`e44.nt and Chi •l
ACC, IivC Officer
r
''1 La
ping Chkagc
cl-
Breathe
w
F,inded
Easi^rror101
in 1906, I
Years
to
American Lung Aa
wcietion
ol'Metropoliwn CI icago
rms Chicago an,
:'ook County with
>ducation,racarcl and
:tvcca-y program .
Vemher of cfo mt nity Health
CJwrirlas-AJeare enemher
die AL,l AfC in you will.
September 20, 2006
Office of the Clerk
Illinois Pollution Control Board
100 West Randolph
Chicago, IL 60601
ReEmissions
: Comments
from Large
on Proposed
Combustion
New
Sources
35 ILL(Mercury)
. ADM
. CODE
; R06-25225,
Control of
Dear Honorable Members of the Board ;
The American Lung Association of Metropolitan Chicago supports the
proposed rule filed with the Illinois Pollution Control Board by the Illinois
Environmental Protection Agency, as amended and including the Ameren and
Dynegy proposals ("the rule"). This rule is necessary to protect the health of the
citizens of Illinois and is both technologically feasible and cost effective,
The Illinois rule as drafted (including amendments and Ameren's and
Dynegy's proposals), is sound and will be effective. States such as Georgia,
Maryland, Massachusetts, Michigan, Minnesota, New Jersey and Pennsylvania,
among others, have initiated proposals with mercury reductions from power
plants similar to those in the Illinois proposed rule, demonstrating that this rule is
reasonable and the bases for the rule are sound
. The IEPA and proponents also
made the necessary showing at the hearings'and in filings that the rule is both
technically feasible and economically reasonable
. In particular, where 90% is not
achievable with activated carbon injection (ACI) alone, other pollution control
options can be used to achieve 90%, including controls for other pollutants that
provide additional mercury reductions
.
Finally, there is sufficient flexibility in the rule for
operators to choose a
compliance pathway that is appropriate for them in terms of both means and
timing of achieving the necessary mercury reductions . We are especially
supportive of Ameren and Dynegy's proposed multi-pollutant standard, as in
addition to mercury reductions, significant reductions will also be achieved in
sulfur dioxide and nitrogen oxide(s) emissions which contribute to
fine particulate
and ozone problems within Illinois. Reducing such emissions will improve the
health of Illinois residents with lung disease
.
to
t
AMERICAN
LUNG
ASSOCIATION®
of Metropolitan
Chicago
Re
CLERK'S
c
VIED
SEP 2 0 2006
Pollution
STATE OF
Control
ILLINOIS
Board
Nearly two thirds of Illinois residents live within areas that fail to meet
current federal minimal health standards for ozone and fine particulate matter .
Furthermore, there is ample scientific evidence, as indicated by USEPA staff and
the Clean Air Scientific Advisory Committee, that current federal standards for
ozone and fine particulate matter are not sufficient to protect vulnerable
populations with an adequate margin of safety as required by the Clean Air Act
.
We do not see these additional non-mercury pollutant reductions as a
substitute in any way for a strong Illinois rple that will shortly be required in order
for the state to comply with the federal Clean Air Interstate Rule, but appreciate
the additional health benefits these emission reductions will bring in addition to
the health and welfare benefits of significantly reducing mercury emissions if
sources chose the mufti-pollutant option for compliance with the Illinois mercury
rule.
Ameren and Dynegy's support for the rule demonstrates that facilities
within the State of Illinois can achieve the required reductions contained in the
proposed rule in a cost-effective manner .
For these reasons, American Lung Association of Metropolitan Chicago
supports the proposed rule and encourages the Board to vote in favor of the rule
.
Brian P.
rbaszew
Director of Envi
ental Health Programs
