ILLOIS
POLLUTION
CONTROL
BOA
November
7,
2008
Jack
Lavin,
Director
Department
of Commerce
and
Economic
Opportunity
620
East
Adams
Street,
S-6
Springfield,
Illinois
62704
Re:
Request
for Economic
Impact
Study
for: Amendments
to
35
III.
Adm.
Code
225: Control
of Emissions
from
Large
Combustion
Sources
(iViercury
Monitorin2),
(R09-1O)
•
SPRINGFJEIDOFF1CE
1021
oGrandAEast
P.O.
Box
19274
Springfie1cJb
6794-92I4’
217-524;85Q0,
FAX
217-5248O8
CHICAGO
OFFICE
JaniesR.
Thorpson
Center
100West4tido1ph
H
1i-500
IL
60601:
4-3620
I
Dear Director
Lavin:
On
November
5,
2008,
the Board
accepted
a proposal
for
hearing
in
Amendments
to
35 Ill.
Adm.
Code
225,
Control
of
Emissions
from
Large
Combustion
Sources
(Mercury
Monitoring),
R09-
10.
This
rulemaking
was
filed
with the
Board
by the
Illinois
Environmental
Protection
Agency
(Agency).
Generally,
the
Agency
proposes
to
amend
Part 225
of
the
Board’s
air
pollution
regulations
(35 Ill.
Adm.
Code 225)
to
recreate
certain
monitoring
provisions
of the
federal
Clean
Air
Mercury
Rule
(CAiMR),
which
was recently
vacated
by
a federal
court,
and
add those
provisions
to Illinois’
mercury
rule.
I write
to request
that
your
Department
conduct
an
economic
impact
study
concerning
this proposal.
Since
1998, Section
27(b) of
the
Enviromitental
Protection
Act
has
required
the
Board
to:
1)
request
that
the Department
of Commerce
and
Economic
Opportunity
(formerly
the
Department
of
Commerce
and
Community
Affairs)
conduct
a
study
of the
economic
impact
of
the
proposed
rules.
The Department
may
within
30
to 45
days
of such
request
produce
a
study
of the
economic
impact
of the
proposed
rules.
At
a
minimum,
the
economic
impact
study
shall
address
a)
economic,
environmental,
and
public
health
benefits
that may
be
achieved
through
compliance
with
the proposed
rules,
b)
the effects
of
the
proposed
rules
on
employment
levels,
commercial
productivity, the economic
growth
of
small
businesses
with
100 or
less employees,
and
the State’s
overall
economy,
and
c) the cost
per
unit of
pollution
reduced
and
the
variability
of
company
revenues
expected
to be used
to implement
the
proposed
rules;
and
(2)
conduct
at
least
one
public
hearing
on the
economic
impact
of
those
rules.
At
least
20
days
before
the
hearing,
the
Board shall
notify
the
public
of
the
hearing
and
make
the
economic
impact
study,
or
the Department
of
GOVERNOR
Rod
R.
Blagôjevich
CHAIRMAN
G.
Tanner
Girard,
Ph.D.
S
‘LLIN
ILLINOIS
POLLUTION
CONTROL
BOARD
GOVERNOR
Commerce
and
Economic
Opportunity’s
explanation
for
not
producing
an
Rod
R.
Blagojevich
economic
impact
study,
available
to
the
public.
Such
public
hearing
may
be
held
simultaneously
or
as
a
part
of
any
Board hearing
considering
such
new
+
rules.
415
ILCS 5/27(b)
(2006).
CHAIRMAN
.
G.TannerGirard,
Ph.D.
The
Board
is
in
the
process
of
schedulmg
initial
hearings
in
this
rulemaking.
Although
there
is
no
decision
deadline
in
this
rulemaking,
the
Board
intends
to
proceed
expeditiously
with
this
rulemaking,
and
asks
that
you
respond
to
this
request
as
soon
as
you
conveniently
can.
If I,
or
my
staff,
can
provide
you
with
any
additional
information,
please
let
me
know.
Thank
you
in
advance
for
your
prompt
response.
Sincerely,
G.
Tanner
Girard
SPRINGFIELD
OFFICE
Acting
Chairman
1021
North
Grand
Ave.
East
Pollution
Control
Board
P.O.
Box
19274
S
4
fie
9
1dIL
cc:
Warren
Ribley,
DCEO
-
217-524-8500
John
T.
Therriault,
Assistant
Clerk
of
the
Board
.
FAX
217-524-8508
CHICAGO
OFFICE
James
R.
Thompson
Center
100
WesRdoIph
Suite
11-500
Chicagç,
IL
60601
:-
312814-3620
FAX
3
12-814-3669
TYY3J2-8
14-6032
WEB
SITE
www.ipcb.state.il.us