Conservation Groups Comments Logo

 

March 21, 2024

Sarah Brubaker
Office of Community Relations
Illinois Environmental Protection Agency
1021 North Grand Ave. East,
P.O. Box 19276
Springfield, IL 62794-9506

Electronic Filing via Email Sa************@il******.gov

Re: Comments on Illinois’ Regional Haze State Implementation Plan for the Second Implementation Period

The National Parks Conservation Association, Sierra Club, the Coalition to Protect America’s National Parks, Illinois Environmental Council, Environmental Law and Policy Center, and the Respiratory Health Association (collectively, the Conservation Groups) submit the following comments on the Illinois Environmental Protection Agency’s (Illinois EPA) draft Regional Haze State Implementation for the Second Implementation Period (Draft SIP Revision).

In its Draft SIP Revision, Illinois EPA proposes to select just five sources for Four-Factor Analyses—Prairie State Energy Campus (PSEC), Archer Daniels Midland Co. (ADM), Rain CII Carbon LLC, Holcim U.S. Inc., and Southern Illinois Power Cooperative Marion Power Plant (SIPCO Marion)—but does not propose to require any of these facilities to adopt new control measures to reduce emissions in the second planning period.1Illinois Env’t Prot. Agency, Illinois Regional Haze State Implementation Plan for the Second Implementation Period (Jan. 2024) [hereinafter “Draft SIP Revision”]. As discussed in these comments and in the attached expert report from Vicki Stamper (Stamper Report),2Vicki R. Stamper, Review and Comments on Reasonable Progress Controls for the Illinois Regional Haze Plan for the Second Implementation Period (March 14, 2024) [hereinafter “Stamper Report”] (attached as Ex. 1). which is incorporated in its entirety into these comments, the Conservation Groups have serious concerns about Illinois’ Draft SIP Revision:

  • Illinois EPA relies on an unduly high emissions over distance (Q/d) source selection threshold of 10, and so, fails to select significant sources of haze-forming pollution for Four-Factor Analyses. The Agency should use a Q/d of 5 or less to select sources for further analysis.
  • Illinois EPA fails to set a cost-effectiveness threshold for evaluating emission control measures and improperly proposes to reject cost-effective controls. It should identify a cost-effectiveness threshold of $10,000/ton of pollution reduced, in line with thresholds adopted by other states for the second planning period.
  • Illinois EPA improperly proposes to reject otherwise available, feasible, and cost-effective controls as achieving too little visibility benefit.
  • Illinois EPA relies on highly flawed Four-Factor Analyses and fails to require cost-effective pollution controls and enforceable SIP emission limits for the short list of sources identified by the Conservation Groups and NPS. The Agency must correct the errors in its source-specific analyses and conduct new Four-Factor Analyses that comply with the requirements of the Regional Haze Program.
  • Illinois EPA fails to incorporate into the SIP Revision (1) federally enforceable retirement dates for Dynegy Midwest Generation’s Baldwin plant (Baldwin) and Illinois Power Generating Co.’s Newton plant (Newton), (2) federally enforceable retirement dates for the power plants listed in the Draft SIP Revision’s long-term strategy as already shutdown, and (2) emission limits and other measures for the existing measures listed as necessary to make reasonable progress in the long-term strategy. The Agency must incorporate into the regulatory portion of the SIP these source retirement dates and emission limits and other requirements for the existing measures it lists in the long-term strategy.
  • Illinois EPA fails to meaningfully consider and advance environmental justice and civil rights through its SIP Revision. It should use readily available information and tools to consider the environmental justice and civil rights impacts of its SIP Revision. To satisfy the Clean Air Act and Regional Haze Rule (RHR), Illinois EPA must correct the flaws identified in these comments and in the attached Stamper Report before submitting its SIP Revision to the U.S. Environmental Protection Agency (EPA).

To satisfy the Clean Air Act and Regional Haze Rule (RHR), Illinois EPA must correct the flaws identified in these comments and in the attached Stamper Report before submitting its SIP Revision to the U.S. Environmental Protection Agency (EPA).

Click here to read the full letter and attachments.

  • 1
    Illinois Env’t Prot. Agency, Illinois Regional Haze State Implementation Plan for the Second Implementation Period (Jan. 2024) [hereinafter “Draft SIP Revision”].
  • 2
    Vicki R. Stamper, Review and Comments on Reasonable Progress Controls for the Illinois Regional Haze Plan for the Second Implementation Period (March 14, 2024) [hereinafter “Stamper Report”] (attached as Ex. 1).