FEB

03

2009

Attn

John Terriault,

Asst. Clerkof

the Board

Illinois

Pollution

Control Board

100 W. Randolph St.,

Suite 11-500

Chicago,

Illinois

60601

The

purpose

of this

letter is to provide

comments

on

the Illinois Environmental

Protection

Agency’s

(IEPA’s) proposed

rulemaking

involving

case number

R2008-019,

‘

Nitrogen

Oxides Emissions

From Various

Source Categories,

Amendments

to 35 Ill.

Adm.

Code Parts 211

and 217, pertaining

to Reasonably

Available

Control

Technology

(RACT)

scheduled for public

hearing February

3, 2009.

The Missouri

Department of

Natural

Resources’

Air

Program has completed

a similar

RACT

development

process

for

the

control of Nitrogen Oxide

(NOx)

emissions

which

contribute to ozone

and particulate

matter 2.5

micrometers

in diameter (PM2.5)

formation

in

the St. Louis

nonattainment

area. The

department’s comments

are intended

to provide

support for IEPA’s

proposed

rulemaking

for Nitrogen Oxides

Emissions

From Various

Source Categories.

The

St. Louis

nonattainment area

for

ozone

and PM2.5 includes

counties in

both

Missouri and

Illinois.

A primary

goal of the St.

Louis

ozone

and PM2.5

modeling

studies

is to

develop

photochemical modeling

databases

and allied analysis

tools necessary

to

reliably simulate

the processes responsible

for ozone

and PM2.5

exceedances

in the

region.

This is

done to assist in

the development

of realistic emissions

reduction

strategies. The

St. Louis modeling

study includes

episodic

emissions,

meteorological,

ozone and PM2.5

simulations

covering

the central

U.S. and centered

on St. Louis.

NO

RACT is a required

element

of the ozone and

PM2.5SIP planning

process,

and must

be

completed

for the St. Louis nonattainment

area

before the

U.S. Environmental

Protection Agency

(EPA) can

take action on these

plans for Missouri

and Illinois.

Missouri appreciates

IEPA action

to finalize

this

rule, as it will

allow

the EPA

to approve

Missouri’s ozone

plan

submittal.

In addition, the

proposed rulemaking

will help

lower

ozone and PM2.5

levels in the St.

Louis nonattainment

area.

The emission

reductions

expected from this

proposed rulemaking

will

assist in bringing the

St. Louis

nonattainment

area into attainment

for

both the

ozone and PM2.5

standards.

As a result

Missouri applauds

IEPA’s

efforts

and

are in support

of

the proposed

rulemaking.

---

Mr. John Terriault

Page Two

The department’s Air

Pollution Control Program

appreciates the opportunity

to comment

on this proposed rulemaking.

If you have any questions,

please contact David Lamb

with

the

department’s

Air Pollution Control Program,

at P.O. Box 176, Jefferson

City, MO

65102 or

by

phone at

(573) 751-4817.

Sincerely,

James

L. Kavanaugh

Director

Air Pollution Control

Program

Missouri Department of Natural Resources

cc: Timothy J. Fox, Hearing Officer