Page
    lofi
    John
    Therriault
    - IL AFL-CIO
    Public
    Comment
    - Ameren’s
    Petition
    for
    Variance
    From:
    “Beth
    Spencer”
    <BethS@ilafl-cio
    .org>
    To:
    <therriajipcb.state.il.us>
    Date:
    12/22/2008
    11:00 AM
    L.’I
    222008
    Subject:
    IL AFL-CIO
    Public
    Comment
    -
    Ameren’s Petition
    for
    Variance
    STATS
    OF,
    CC:
    “Michael
    Carrigan”
    <MichaelCi1afl-cio.org>
    ‘O1IUtion
    CorJ1OIS
    Oar
    John:
    Per our phone
    conversation,
    please find
    attached
    Public Comment
    from
    the Illinois
    AFL-CIO,
    the
    IBEW and
    the
    UMWA
    in support
    of Ameren’s
    Petition for
    Variance.
    Any
    questions
    please
    feel tree
    to contact me
    or
    Michael
    T.
    Carrigan,
    president,
    IL
    AFL-CIO
    at
    217.544.4014.
    Thank
    you,
    Beth
    Spencer
    Communications
    Director
    L AFL-CIO
    Ph. 217.544.4014
    Fx.
    217.544.0225
    bethsilafI-cio.org
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    BEFORE
    THE
    ILLINOIS
    POLLUTION
    CONTROL
    BOARD
    AMEREN
    ENERGY
    GENERATING
    )
    COMPANY,
    AMERENENERGY
    )
    DEC
    22
    2gg
    RESOURCES
    GENERATING
    COMPANY
    )
    AND
    ELECTRIC
    ENERGY,
    INC.,
    )
    Pj
    7
    COflfroI
    Board
    Petitioners,
    )
    PCB
    —
    09-21
    )
    (Variance
    —
    Air)
    v.
    )
    )
    )
    ILLINOIS
    ENVIRONMENTAL
    )
    PROTECTION
    AGENCY,
    )
    )
    Respondent.
    )
    TO:
    John
    Therriault,
    Assistant
    Clerk
    Illinois
    Pollution
    Control
    Board
    James
    R.
    Thompson
    Center
    100
    W.
    Randolph,
    Ste.
    1
    1-500
    Chicago,
    IL
    60601-3218
    Kathleen
    Bassi
    Renee
    Cipriano
    Amy
    Antoniolli
    SchiffHardin,
    LLP
    6600
    Sears
    Tower
    233
    South
    Wacker
    Drive
    Chicago,
    IL
    60606
    John
    Kim
    Kent
    Mohr
    Division
    of
    Legal
    Counsel
    ILEPA
    1021
    N.
    Grand
    Ave.
    East
    P.
    0.
    Box
    19276
    Springfield,
    IL
    62794-9276
    Bradley
    Halloran
    Hearing
    Officer
    Illinois
    Pollution
    Control
    Board
    100W.
    Randolph,
    Ste.1
    1-500
    Chicago,
    IL
    60601-3218
    PLEASE TAKE NOTICE
    that
    the Illinois AFL-CIO,
    International Brotherhood
    of Electrical
    Workers (IBEW)
    and the United Mine Workers
    of America
    (UMWA) File Public Comment
    (as follows)
    Public Comment
    of Michael T. Carrigan, president,
    Illinois
    AFL-CIO
    In response to Ameren’s Petition
    for Variance filed with
    the Illinois Pollution Control Board,
    we
    wish to express our
    support for approval of this variance.
    It is our understanding
    that the relief
    Ameren requests
    is very narrow and does not seek
    to undo its environmental
    commitments as
    suggested by the public comments recently filed
    by
    certain environmental
    groups.
    The facts
    are
    that Ameren was the first
    company to come forward
    to reach an agreement with the
    state to
    reduce mercury emissions.
    Ameren was actually one
    of the chief architects of Illinois’
    multi-
    emission environmental
    compliance strategy, working
    closely with State officials.
    In
    addition,
    the company’s strong
    record of significant emissions reductions
    indicates Ameren
    is
    as
    committed
    as ever to further reducing emissions
    from its power plants.
    This fall,
    Ameren sought to move the timeframe for
    installing new controls for two
    reasons: (1)
    regulatory uncertainty created
    by the federal courts’ overturning
    key federal regulations
    and
    (2)
    the financial crisis gripping our nation.
    Almost every industry
    sector has been affected
    by
    this
    crisis--the auto and banking industries
    are only the most public examples.
    Financial publications
    have also pointed
    to
    the
    serious problems utility companies face
    because of their reliance
    on
    short-term financing
    to
    manage
    their daily operations. Ameren has
    stated in news releases,
    financial documents and in its discussions
    with the financial community
    that the company has
    had
    great difficultly accessing capital markets
    to support its operations
    and refinance debt.
    If granted, this variance would
    allow Ameren to defer -- not
    cancel --approximately
    $500
    million of
    environmental capital expenditures,
    giving the corporation breathing
    room to manage through
    this
    crisis.
    It is vital that members of the Board remember
    that Ameren companies for more
    than a century
    have provided good jobs and stable employment
    to thousands of Illinoisans.
    Taxes paid by these
    companies are critical to the support of schools,
    emergency response organizations
    and city
    governments of dozens
    of communities across the
    state.
    It
    would be irresponsible for
    the Board
    to
    ignore the realities of what is
    occurring in the economy
    and to push this stable company
    into
    financial distress.
    Ameren has stated that it is not reneging
    on its emissions reduction
    agreement and, in fact, has
    agreed to more stringent emission requirements
    than the original regulation.
    Over the next
    decade, Ameren intends
    to
    install
    seven to eight scrubbers
    at its Illinois
    plants---these
    projects
    will provide hundreds of
    permanent and
    contract
    jobs
    to unionized workers.
    These are good
    paying
    jobs our state desperately
    needs in
    these
    economically
    trying times.

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