08/11/0908:03

FAX

708

551

2510

Regulatory

Affairs

l002

CornPmducts

INTERNATIONAL

Corn

Products

International,

Inc.

S

Westbrook

Corporate

Center

Westchester;

IL

60154

?Oog

August

11

2009

‘on

C

0

44t4/

0

/

8

Mr.

Timothy

Fox,

Hearing

Officer

illinois

Pollution

Control

Board

James

R.

Thompson

Center

100

W.

Randolph

Suite

11-500

Chicago,

Illinois

60601

RE:

Rulemaking

R2006-22,

In

the Matter

of:

NOx Trading

Program:

Amendments

to

35

Ill.

Adm.

Code

Part 217;

Response

to

Motions

by

the

Illinois

Environmental

Regulatory

Group

Mr. Fox;

I

sin

writing

on

behalf

of

Corn

Products

International,

Inc.,

Argo

Plant

in

response

to

the

illinois

Pollution

Control

Board’s

(“Board”)

August

6,

2009

Order

requesting

responses

to

the

Illinois

Environmental

Regulatory

Group’s

(“IERO”)

Motion

for Emergency

Rule

and

Motion

for

Expedited

Action

on

IERO’s

Alternative

Proposal

(collectively

“Motions”).

We

would

like

to

offer

our

support

for

the

Motions,

and

urge the

Board

to

consider

the

following

in

ruling

on

the Motions;

1.

We

are

an

owner/operator

of

budget

unit(s)

subject

to

the

current

Subpart

U.

35

Ill.

Admin.

Code

Part

21

7.Subpart

U.

2.

We

have

not

received

allocations

of

NOx

allowances

for

the

2009

ozone

season,

nor for

any

subsequent

years.

3.

We

understand

that

the

cuitent

version

of

Subpart

U

is

a

valid

and

enforceable

regulation

in

illinois

that

reqaires

subject

sources

to

hold

NOx

allowances

for

each ton

of

NOx

emitted

during

the ozone

season

by

November

30

of

the

applicable

yeat

4

We

understand

that

the

USEPA

is

no

longer

issuing

allowances

for the

NOx

Budget

Trading

Program,

as

would

be

required

to

satisfy

the

above

described

requirement.

Phone;

706-551-2600

---

08/11/09

08:03 FAX

708 551 2510

Regulatory

Affairs

L003

5.

We understand

that NOx

allowances could

potentially

be

obtained through

the

purchase

of Clean

Air

Interstate Rule

(“CAIR”) NOx

allowances,

although we are

uncertain

whether

those allowances

would be

legally sufficient

to satisfy the

Subpart

U

requirement

to

hold NOx SIP Call

allowances-

Nor

even if sufficient,

could

we

demonstrate

compliance with the

requirement,

due

to

our inability

to

obtain

CAR

compliance

accounts from

the USEPA Clean

Air

Markets Division

(“CAMD”),

abscnt a

federally

approved

trading

program in

Illinois.

Therefore, we believe

it is

in

the

best

interest

of business in

Illinois

to adopt rules,

such

as

the emergency rule and

alternative

proposal

described

in the

Motions,

that require NOx

allowances to be

distributed

for

the 2009 ozone season,

as

well as subsequent

control

periods.

Corn

Products International,

Inc., Argo

Plant

appreciates

the

opportunity

to

provide

this

response.

In

light

of

the above,

we

request that

the

Board

grant 1ERO’s

Motion

for

Emergency

Rule in

order to

require

that

2009

NOx

allowances

be

distributed

to

impacted

sources,

and

grant

BERG’s

Motion for

Expedited

Action

on

IERG’s

Alternative

Proposal

in order to

bring NOx SIP

Call budget units

into

the CAR NOx

Ozone Season

Trading

Program for the 2010

control

period

and beyond.

Sincerely,

Corn

Products

International,

Inc,

Argo

Plant

By:

/

Alan

iij ‘

Vice

President,

Regulatory

Affairs

Alan

Jirik

Vice

President, Regulatory

Affairs

Corn Products International,

Inc.

5

Westbrook Corporate

Center

Westchester,

IL

60154

(708)

551-2512

Alan.iitik(&cornproducts.corn