28 East Jackson Blvd

. _

sure 700

Chicago, IL 60604

GtarcA Maaeats

Mary Lou biglnd. RN, MS

Kane County

Huhh Dapertmeu

Secrearydrrmura

Stephen Martin, Ph.D., MPH

Cook County Depeunen

of Public HWdr

Terry Muon MO. FACS

Chi

Public Mulchago-of

Maunei McHugh

or,Pep Couey

Haft Daparaunt

Dale W. Gaasoe, MA, MS

Lake County

Health Deparomnt

Pauirk McNulty

MtMenrr County

Health Department

James E Zelko. RS

Will County

Health Depam enc

J. M*hl, Bacon MPH, R5

Whnebago Cwnty

Health Depa ant

Arnan McMeacc

Kay Lym Shounaler, RN . BSN

Gnndy eoanq

Hmkh Depwomric

Bonds Schaafarn

. RN. BSM MBA

Kankaka Count'

Health Dpnnemc

Cheryl LJohnscn, BA

Kndal County

Health Daparmtit

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September 19, 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 Northern Illinois Public Health Consortium's

(NIPHC) 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. We understand this rule to be

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. The NIPHC, in an effort to protect the health of

all northern Illinois residents and visitors, supports and endorses the

reduction of all sources

of environmental mercury pollution in northern

Illinois and beyond.

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 withh mercury

. The problem is so

bad that the Illinois Department of Public Health warns everyone

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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

.

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 merct!ry, 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 Illinoiesps, ,

A large, diverse coalition ofdoctors, 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 .

.r,

Steve uratti, MPA, LEHP

Chair, Environmental Health Committee

Northern Illinois Public Health Consortium

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