BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF:
)
)
NOX EMISSIONS FROM STATIONARY
)
R07-19
RECIPROCATING INTERNAL COMBUSTION
)
(Rulemaking
-
Air)
ENGINES AND TURBINES:
)
AMENDMENTS TO 35 1LL.ADM.CODE
)
SECTION201.146ANDPARTS211AND217.
)
NOTICE OF FILING
To:
John T. Therriault, Assistant Clerk
Illinois Pollution Control Board
James R. Thompson Center
Suite 1 1-500
100 West Randolph
Chicago, Illinois 6060 1
Persons included on the
ATTACHED SERVICE LIST
PLEASE TAKE NOTICE that we have today filed with the Office of the Clerk of the
Pollution Control Board the
PIPELINE CONSORTIUM'S MOTION FOR PRODUCTION
OF INFORMATION.
Dated: June 29,2007
Renee Cipriano
Kathleen C. Bassi
Stephen J. Bonebrake
Joshua R. More
SCHIFF
HARDIN, LLP
6600 Sears Tower
233 South Wacker Drive
Chicago, Illinois 60606
3
12-258-5500
Fax:
3
12-258-5600
Electronic Filing, Received, Clerk's Office, June 29, 2007
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF:
1
)
NOX EMISSIONS FROM STATIONARY
)
R07-19
RECIPROCATING INTERNAL COMBUSTION
)
(Rulemaking
-
Air)
ENGINES AND TURBINES:
1
AMENDMENTS TO 35 1LL.ADM.CODE
1
$ECTION201.146ANDPARTS211AND217.
)
PIPELINE CONSORTIUM'S MOTION FOR
PRODUCTION OF INFORMATION
NOW COME ANR PIPELINE COMPANY, NATURAL GAS PIPELINE COMPANY,
TRUNKLINE GAS COMPANY, and PANHANDLE EASTERN PIPELINE COMPANY
(collectively "the Pipeline Consortium"), by and through their attorneys, SCHIFF
HARDIN
LLP, and, pursuant to 35 111.Adm.Code
$5
102.402 and 101.614, move the Hearing Officer to
order the Illinois Environmental Protection Agency ("Agency") to produce any and all
documents related to the
BaseK OSATIPSAT simulations summarized in the Powerpoint
presentation that accompanied Michael Koerber's pre-filed testimony, submitted by the Agency
on May 11, 2007, including specifically the following data, in the manner set forth later in this
Request:
1. CAMx Run scripts for simulation
K20 12R4S 1 a-APCA-nopig
2. OSAT Source region maps for simulation 20 12R4S 1 a-APCA-nopig
3. CAMx emissions files for simulation K20 12R4S 1 a-APCA-nopig
4. CAMx model outputs for simulation K20 12R4S 1 a-APCA-nopig
5. CAMx Run scripts for the PSAT simulations of K2012R4S 1 a
6. PSAT Source region maps for simulations of K20 12R4S 1 a
7. CAMx emissions files for PSAT simulations of K20
12R4S 1 a
8. CAMx model outputs for simulation K20 1 2R4S 1 a
The Pipeline Consortium requires this data to develop its
affirmative case in opposition to
the Agency's proposed rule. The Agency has informed the Pipeline Consortium's attorneys that
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1
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Electronic Filing, Received, Clerk's Office, June 29, 2007
it is processing the data and will provide it within 10-1 4 days, which would be July 10, 2007, at
the latest. The Pipeline Consortium requests that the Hearing Officer establish July 10, 2007, as
the latest date by which the Agency should provide the information with the admonition that it
should be provided sooner if possible.
Because the data requested is modeling data and is highly technical in nature, possibly
even written in a format that normal word processing-type computers are not able to read, the
Pipeline Consortium requests that the data be transferred directly from LADCO, where Mr.
Koerber is the Executive Director and which is the developer and keeper of the data requested, to
the Pipeline Consortium's consultant, Alpine Geophysics, LLC. If the data is to be conveyed on
a computer disk, it should be sent to the following address in the most expedient manner:
Alpine Geophysics, LLC
Attention: Mr. Dennis McNally
7341 Poppy Way
Arvada, Colorado 80007
If the data can be conveyed electronically and if electronic conveyance is the method typically
used for conveying this modeling data,' it should be sent to Mr. McNally as follows:
Electronic conveyance is our preferred method for having the data transferred.
*
We note that LADCO is, under normal circumstances, very open in sharing its modeling
data with its fellow modelers.
Electronic Filing, Received, Clerk's Office, June 29, 2007
Respectfully submitted,
ANR PIPELINE COMPANY, NATURAL GAS
PIPELINE COMPANY, TRUNKLINE GAS
COMPANY, and PANHANDLE EASTERN PIPELINE
COMPANY
by:
Dated: June 29,2007
Renee Cipriano
Kathleen C. Bassi
Stephen
J. Bonebrake
Joshua R. More
SCHIFF
HARDIN, LLP
6600 Sears Tower
233 South Wacker Drive
Chicago, Illinois 60606
3 12-258-5500
Fax: 3 12-258-5600
Electronic Filing, Received, Clerk's Office, June 29, 2007
CERTIFICATE OF SERVICE
I, the undersigned, certify that on this 29th day of June, 2007, I have served electronically
the attached
PIPELINE CONSORTIUM'S MOTION FOR PRODUCTION OF
INFORMATION
upon the following persons:
John T. Therriault, Assistant Clerk
Persons included on the
Illinois Pollution Control Board
ATTACHED SERVICE LIST
James R. Thompson Center
Suite 1 1-500
100 West Randolph
Chicago, Illinois 6060 1
Renee
Cipriano
Kathleen C. Bassi
Stephen J. Bonebrake
Joshua R. More
SCHIFF
HARDIN, LLP
6600 Sears Tower
233 South Wacker Drive
Chicago, Illinois 60606
312-258-5500
Fax:
3 12-258-5600
Electronic Filing, Received, Clerk's Office, June 29, 2007
SERVICE LIST
(RO7-19)
Timothy Fox
Hearing Officer
ILLINOIS POLLUTION CONTROL BOARD
100 West Randolph, Suite 1 1-500
Chicago, Illinois 6060 1
foxt@,ipcb.state.il.us
Katherine D. Hodge
N.
LaDonna Driver
Gale W. Newton
HODGE DWYER ZEMAN
3
1 5 0 Roland Avenue
P.O. Box 5776
Springfield, Illinois 62705-5776
khodge@,hdzlaw. com
nldriver@,hdzlaw. com
gnewton@,hdzlaw.com
John Kim
Rachel Doctors
Robb H. Layman
Division of Legal Counsel
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY
102
1 North Grand Avenue, East
P.O. Box 19276
Springfield, Illinois 62794-9276
j oh.
i
.kim@,illinois .wv
rachel.doctors~illinois.gov
robb.layman@illinois.gov
William Richardson, Chief Legal Counsel
Virginia I Yang, Deputy Counsel
ILLINOIS DEPARTMENT OF NATURAL
RESOURCES
One Natural Resources Way
Springfield, Illinois 67202- 127 1
bill.richardson@,i11inois.~ov
virginia. yang@,illinois.gov
Electronic Filing, Received, Clerk's Office, June 29, 2007