Offilsers, and Demeanors,

Chaimren

James T. Frenkenbach

Preskenf/Chiei Executive Officer

Rush NOM Shore Medical Center

Chairmen-Elect

Bruce C . Campbell

President

Advocate Lutheran General Hospital

Peat Chairmen

Dean M . Harrison

President/Chief Executive Officer

NoMwestem Memorial Hospital

Treasurer

Dennis A. Reilly

Presient/Chlel Executive Officer

Lithe Company of Mary Hospital and

Health Cere Centers

PresidentChlef Executive Officer

Kevin Scanlan

Alan H

. Charming

Preakent/Chlef Executive Officer

Sinai Health System

Barry C. Finn

President/Chiel Executive Officer

Rush-Caplet' Medical Center

Richard B. Floyd, FACHE

President/Chlef Executve Officer

Shaman Heal h Systems

William T. Foley

Presldent/Chlef Executive Officer

Provena Heath

Colleen Kannaday

President

St. France Hospital & Health Center

(Blue Island)

Brian Lemon

Chief Executive Officer

Holy Chase; Hospital

Pa nick M

. Magoon

PresidentChlef Executive Officer

Children's Memorial Hospital

Lake McGuinness

Presidenvchlef Executive Officer

Central DuPage Health

Peter J . Murphy

Prasientchief Executive Officer

St. James Hospital

s Heats Cement

Jesus M . Ong

President Chief Executive Officer

Souf, Shore Hospital

Paul Pamrlak

PresldentiChlef Executive Officer

Sih/er Cross Hospital

James H . skogsbergh

Preeident/Chiei Executive Officer

Advocate Health Care

Sister Donna Mane Wolowlcki, OR

Group Vice President & Execulve

Vice PreskenNChlef Executive Officer

Resurrection Medical Career

September 20, 2006

Office of the Clerk

Illinois Pollution Control Board

100 W

. Randolph St .

Chicago, IL 60601

Re

: Proposed New 35 ILL

. ADM . CODE 225, Control of Emissions from

Large Combustion Sources (Mercury)

; R06-25

Dear Honorable Members of the Board

:

I am writing to express the Metropolitan Chicago Healthcare Council'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 tamong

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 warns everyone

-

particularly pregnant women, women of childbearing age and children

-

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

Illinois .

MCHC

222 South Riverside Plaza

Metropolitan Chicago

Chicago, Illinois 60606-6010

Healthcare Council

Telephone (312) 906-6000

Facsimile (312) 993-0779

http :/www .mcho.org

RECEIVED

CLERKS

SEP 2 0 2006

Pollution

STATE OF

ConILLINOIS

d

---

9/20/06

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

.

Illinois 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

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, Massachusetts, 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

.

Sincerely,

Lawrence U . Haspel, D .O

.

Senior Vice President

Mercury PCB comment letter.doc

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