OIL-Z0/2000 13 :44

FAX 3129222173

OUNCE

FU\D-PPE\

'E\TIO\OF

September 18 2006

Office of the Clerk

Illinois Pollut on Control Board

100 W . Rando lph St.

Chicago, IL 6)601

i

Re: Proposed New 35 ILL. ADM

. CODE 225; Control of Emissions from Large Combustion

Sources (Men ;ury) ; R06-25

Dear Honoral le Members of the Board :

i

I am writing t U

express The Ounce of Prevention Fund's support for the Illinois Environmental

Protection Ag ency'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 - e specially women of childbearing age, children and the unborn -

and is

technological y feasible and cost effective .

1

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 themselv ;s. Nationally, 6 to 10 percent ofwomen of childbearing age are estimated to have

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

problems

. He re in Illinois, that translates to more than 100,000 women of childbearing age

whose blood ncrcury 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 vhere 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 re suit of all this mercury poliutionl

t Fish in Lake Michigan and all Illinois waterways

are

contaminated

with mercury

. The problemiis 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 .

Much of men :ury

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 lover the harmful effects of mercury exposure

. In one study, for instance, reductions

in mercury er tissions led to an 80 percent decline in mercury contamination levels in nearby fish

.

OUNCE OF PREVENTION

R

CLERK'S

ECEIVE[)

OFFICE

Z001

SEP 2 0 POppyc

e Skoog

STATE OF ILLI~

ha'r

Pollution Control

i Meyer

Q

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---

09/20/2008 13 :44 FAX 3129222173

OUNCE

FUNDPRO/E\TONOF

Illinois must t ike action on mercury pollution because a new federal mercury rule scheduled to

take effect lad

:r this fall is simply too little, too late

. The federal rule will perpetuate mercury hot

spots like tho,

e 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 done_ Wisconsin, Massachusetts, Michigan, Minnesota, Ohio, and Pennsylvania,

among others

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

rule is reasom .ble and based on achievable mercury reduction goals

. Affordable, readily

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

much as 95 pt rcent. We don't need additional studies or research . We need to move forward

now to protec : 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 Ilk B

. 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 ye ars . It's time to codify their agreements in law, and to require companies like

Midwest Gen

:ration that haven't accepted their corporate responsibility to do the same .

Sincerely,

Nancy Shier

KidsPEPP Di •ector

Ounce of Pre+"entron Fund

OUNCE OF PREVENTION

2002

Joyce

Chair

Skoog

Harriet Meyer

President