BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
    IN THE MATTER OF:
    )
    )
    PETITION OF MIDWEST GENERATION, LLC, )
    AS 07-04
    WILL COUNTY GENERATING STATION
    )
    (Adjusted Standard- Air)
    FOR AN ADJUSTED STANDARD FROM
    )
    35 ILL.ADM.CODE 225.230
    )
    )
    NOTICE OF FILING
    To:
    Dorothy Gunn, Clerk
    Persons included on the
    Illinois Pollution Control Board
    ATTACHED SERVICE LIST
    James R. Thompson Center
    Suite 11-500
    100 West Randolp
    Chicago, IL 60601
    PLEASE TAKE NOTICE
    that we have today filed with the Office of the Clerk of the
    Pollution Control Board
    MOTION TO INTERVENE OF ENVIRONMENTAL LAW &
    POLICY CENTER
    , copies of which are herewith served upon you.
    Respectfully Submitted,
    Faith E. Bugel
    Environmental Law & Policy Center
    35 E. Wacker Dr. Suite 1300
    Chicago, IL 60601
    DATED: December 6, 2007
    Electronic Filing: Received, Clerk's Office, December 6, 2007
    BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
    IN THE MATTER OF:
    )
    )
    PETITION OF MIDWEST GENERATION, LLC, )
    AS 07-04
    WILL COUNTY GENERATING STATION
    )
    (Adjusted Standard- Air)
    FOR AN ADJUSTED STANDARD FROM
    )
    35 ILL.ADM.CODE 225.230
    )
    MOTION FOR LEAVE TO INTERVENE
    I, FAITH E. BUGEL, hereby file a MOTION TO INTERVENE in this matter on behalf
    of ENVIRONMENTAL LAW & POLICY CENTER. In support of this Petition, ELPC states the
    following:
    1.
    ELPC is an Illinois-based not-for-profit organization that was previously party to
    the CAIR (R06-025) and Mercury (R06-026) Rulemakings before the Illinois Pollution Control
    Board and is similarly affected by the current Adjusted Standard proceeding.
    2.
    Due to our interest and involvement in R06-025 and R06-026, ELPC and all
    ELPC members have an interest in proceedings that decide and affect the applicability of the
    Illinois Mercury Rules.
    3.
    ELPC and its members will be directly and materially affected by the outcome of
    this proceeding. ELPC’s mission includes advocating for the protection of air quality and water
    quality, and protection of public health directed related to air and water quality. ELPC’s
    members would be directly affected by an adjusted standard at the Will County facility that
    affects the manner in which the Illinois Mercury Rule is applied and the consequent mercury
    emissions from that facility.
    Respectfully Submitted,
    Electronic Filing: Received, Clerk's Office, December 6, 2007
    Faith E. Bugel
    Environmental Law & Policy Center
    35 E. Wacker Dr. Suite 1300
    Chicago, IL 60601
    DATED: December 6, 2007
    Electronic Filing: Received, Clerk's Office, December 6, 2007
    CERTIFICATE OF SERVICE
    I, the undersigned, certify that on this 6th day of December, 2007, I have served
    electronically the attached
    MOTION FOR LEAVE TO INTERVENE OF ELPC
    upon the
    following persons:
    Dorothy Gunn, Clerk
    Illinois Pollution Control Board
    James R. Thompson Center
    Suite 11-500
    100 West Randolph
    Chicago, Illinois 60601
    and electronically and by first class-mail with postage thereon fully prepaid and affixed to the
    persons listed on the
    ATTACHED SERVICE LIST.
    Faith E. Bugel
    Environmental Law & Policy Center
    35 E. Wacker Dr. Suite 1300
    Chicago, IL 60601
    DATED: December 6, 2007
    Electronic Filing: Received, Clerk's Office, December 6, 2007
    SERVICE LIST
    (AS 07-04)
    Alec Messina, General Counsel
    John. J. Kim, Managing Attorney
    Air Regulatory Unit
    Division of Legal Counsel
    Illinois Environmental Protection Agency
    1021 North Grand Avenue East
    P.O. Box 19276 Springfield
    IL 62794-9276
    Sheldon A. Zabel
    Stephen J. Bonebrake
    Kathleen C. Bassi
    Schiff Hardin, LLP
    6600 Sears Tower
    233 South Wacker Drive Chicago
    IL 60606-6473
    Sheldon A. Zabel
    Stephen J. Bonebrake
    Kathleen C. Bassi
    Electronic Filing: Received, Clerk's Office, December 6, 2007

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