Ms. Mary A. Gade 

Regional Administrator R-19J USEPA, Region 5 

77 West Jackson Blvd. 

Chicago, lllinois 60604 Re: lllinois Infrastructure SIP 

Dear Ms. Gade: 

I am writing to confirm that the State of lllinois continues to retain the resources 

necessary to evaluate ambient air quality, develop plans to attain new and existing 

ambient air quality standards, meet the applicable requirements of the new source 

review program, and effectively enforce all applicable requirements. Specifically, the 

lllinois Environmental Protection Agency ("lllinois EPA") has the authority and resources 

to implement and satisfactorily complete the requirements listed below as set forth in 

Section 110 of the Clean Air Act ("CAA) for the current National Ambient Air Quality 

Standards ("NAAQS"). Specifically, the lllinois EPA meets the current applicable 

requirements of Section 110 of the CAA for 8-hour ozone, PM 2.5, and PMlo. 

The State Implementation Plan ("SIP") elements listed below are required under 

Section 110(a)(l) and (2). Section 11 O(a)(l) provides the procedural and timing 

requirements for SIPS. Section 11 0(a)(2) lists the basic or "infrastructure" elements that 

all SIPS must contain. Following each element is a discussion of the lllinois EPA's ability to fulfill the requirement. 

Emission limits and other control measures: Section 11 0(a)(2)(A) requires 

SIPS to include enforceable emission limits and other control measures, means or 

techniques, schedules for compliance and other related matters. USEPA notes that the 

specific nonattainment area plan requirements of Section 11 O(a)(2)(1) are subject to the 

timing requirement of Section 172, not the timing requirement of Section 110(a)(l), and 

also that SIPS to meet this section are not covered by the March 10, 2005, consent 

decree between USEPA and Earth Justice. 

ROCKFORD - 4302 North Main Street, Rockford, IL 61 103 - (81 5) 987-7760 DES PLAINES - 951 1 W. Harrison St., Des Plaines, IL 6001 6 - (847) 294-4000 

ELGIN - 595 South State, Elgin, IL 601 23 - (847) 608-31 31 PEORIA - 541 5 N. University St., Peoria, IL 61 614 - (309) 693-5463 

BUREAU OF LAND - PEORIA - 7620 N. University St., Peoria, IL 61 614 - (309) 693-5462 CHAMPAIGN - 21 25 South First Street, Champaign, IL 61 820 - (21 7) 278-5800 

SPRINGFIELD - 4500 S. Sixth Street Rd., Springfield, IL 62706 - (21 7) 786-6892 COLLINSVILLE - 2009 Mall Street, Collinsville, IL 62234 - (61 8) 346-51 20 

MARION - 2309 W. Main St., Suite 11 6, Marion, IL 62959 - (61 8) 993-7200 
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attain the national ambient air quality standards, or that are necessary to comply 

with the requirements of the federal Clean Air Act ("CAA"). 415 ILCS 5110. 

Ambient air quality monitoring data system: Section 11 0(a)(2)(B) requires 

SIPS to include provisions to provide for establishment and operation of ambient 

air quality monitors, collecting and analyzing ambient air quality data, and making 

this data available to USEPA upon request. 

In accordance with its SIP, lllinois EPA continues to operate an extensive 

monitoring network incorporating more than 300 monitors that track the 

measurements of a variety of pollutants and air toxic compounds throughout the 

State. lllinois EPA publishes an annual report, most recently the lllinois Annual 

Air Quality Report 2005, that describes the monitoring network and summarizes 

the measurements for the year. Illinois EPA also prepares and publishes for 

public comment its plans for the coming year. The 2008 Illinois Air Monitoring 

Network Plan is available on lllinois EPA's website. USEPA provides approval of 

the plan in advance of each calendar year. All reports and data are routinely 

shared with the USEPA or readily available to the USEPA upon request. 

Program for enforcement of control measures: Section 1 IO(a)(2)(C) requires 

States to include a program providing for enforcement of all SIP measures and the 

regulation of construction of new or modified stationary sources to meet 

prevention of significant deterioration ("PSD") and nonattainment New Source Review 

("NSR1') requirements. 

Illinois EPA continues to staff and implement a vigorous enforcement program 

that includes the Compliance Section and Division of Legal of Counsel. Section 4 

of the Act provides the Director with the authority to implement and administer 

this program. 415 ILCS 514. In Illinois, enforcement actions are brought by the 

Office of the lllinois Attorney General or local States' Attorney offices, with whom 

Illinois EPA consults. lllinois enforces all terms of our PSD and nonattainment NSR construction and operating permits. 

Interstate transport: Section 110(a)(2)(D) requires SIPS to include provisions 

prohibiting any source or other type of emissions activity in one state from 

contributing significantly to nonattainment, or interfering with maintenance, of the 

National Ambient Air Quality Standard ("NAAQS") in another state, or from interfering 

with measures required to prevent significant deterioration of air quality or to protect 
CAlR annual and seasonal NOx trading programs, CAlR SO2 trading program, and 

sets forth provisions pertaining to the control of mercury emissions from coalfired electric generating units ("lllinois Mercury Rule"). 35 111. Adm. Code 

Part 225. In particular, the lllinois Mercury Rule contains a multi-pollutant 

standard to reduce NOx and SO2 emissions from coal-fired electric generating 

units. Similarly, the Illinois CAlR trading programs contain combined pollutant 

standards to reduce NOx and SO2 emissions from coal-fired electric generating 

units. These provisions, which will result in reductions of SO2, NOx and Hg 

beyond Federal requirements, will significantly reduce the interstate transport of pollutants from sources in Illinois. Moreover, lllinois has entered into agreements 

and working relationships with the States of Missouri, Indiana and Wisconsin as 

part of the continuing effort to achieve compliance in Illinois' multi-state nonattainment areas. Together, these regulations and cooperative agreements amply 

address Congressional and USEPA concerns over the interstate transport of 

emissions of regulated pollutants. 

Adequate resources: Section 11 0(a)(2)(E) requires states to provide for 

adequate personnel, funding, and legal authority under state law to carry out its 

SIP, and related issues. 

Public Act 95-0348, Article 215 

(http:llwww.ilga.govllegislationlpublicactsl95lPDFlO95-O348.pdf) provides $60.3 million of Appropriations for the lllinois EPA Bureau of Air 

programs and 317 Full Time equivalent staffing positions. The Act provides the 

Director, in conjunction with the Board, with the authority to develop rules and regulations necessary to meet ambient air quality standards and respond to any 

EPA findings of inadequacy with the lllinois SIP program. 415 ILCS 514 and 10. 

The Board may also enact regulations that are required by law, that are otherwise 

part of the State's attainment plan and are necessary to attain the national 

ambient air quality standards, or that are necessary to comply with the 

requirements of the federal CAA. 415 ILCS 5110. 

Stationary source monitoring system: Section 1 10(a)(2)(F) requires states to 

establish a system to monitor emissions from stationary sources and to submit 

periodic emissions reports. 

lllinois EPA requires regulated sources to submit various reports, dependant on 

applicable requirements and the type of permit issued to the source, to the 
Section 34 of the Act allows the lllinois EPA to declare alerts upon a finding that 

episode or emergency conditions exist. 415 ILCS 5134. Further, Section 43(a) of 

the Act authorizes the Illinois EPA to request a State's Attorney of the Office of 

lllinois Attorney General to seek immediate injunctive relief in circumstances of 

substantial danger to the environment or to the public health of persons. 415 

ILCS 5/43(a). Thus, lllinois EPA has the necessary authority to address activities 

causing imminent and substantial endangerment to public health, as required by 

Section 110(a)(2)(G). The lllinois EPA will revise the particulate matter SIP when 

USEPA promulgates Emergency Episodes which address priority classifications 

and significant harm levels for PM2.5. 

Future SIP revisions: Section 11 0(a)(2)(H) requires states to have the authority 

to revise their SIPS in response to changes in the NAAQS, availability of 

improved methods for attaining the NAAQS, or in response to a USEPA finding 

that the SIP is substantially inadequate. 

The Act provides the Director, in conjunction with the Board, with the authority to 

develop rules and regulations necessary to meet ambient air quality standards 

and respond to any EPA findings of inadequacy with the lllinois SIP program. 415 

ILCS 514 and 10. 

Consultation with government officials: Section 1 10(a)(2)(J) requires states to 

provide a process for consultation with local governments and Federal Land Managers carrying out NAAQS implementation requirements pursuant to Section 121 

relating to consultation. 

The lllinois EPA is required to give notice to the Office of the Attorney General 

and the Illinois Department of Natural Resources during the rulemaking process. The lllinois EPA provides notice to both entities during every rulemaking and 

includes each as a stakeholder during outreach. The lllinois EPA further provides 

notice to reasonably anticipated stakeholders and interested parties. The lllinois 

EPA also gives notice to the Federal Land Manager ("FLM") if the rulemaking 

applies to Federal land which the FLM has authority over. Finally, the lllinois 

EPA consults with the States of Indiana, Wisconsin, Michigan, and Ohio through 

its membership in the Lake Michigan Air Directors' Consortium ("LADCO") and 

participates in the Regional Haze Planning Process through its membership in 

the Midwest Regional Planning Organization. 
to the media. In addition Illinois EPA provides the AQI to local stakeholder 

groups, Partners for Clean Air in Chicago and the Clean Air Partnership in St. 

Louis, who post the information on-line. Through these collaborative efforts, 

lllinois EPA and the Cook County Department of Environmental Control provides 

information to the public on measures that can be taken to prevent exceedances 

and this information is also posted on lllinois EPA's website. 

PSD and visibility protection: Section 1 10(a)(2)(J) also requires States to meet 

applicable requirements of Part C related to prevention of significant deterioration and 

visibility protection. 

lllinois EPA is addressing both the long term requirements to meet natural 

visibility levels by 2064 and the ongoing review of new major sources and major 

modifications under Illinois' approved PSD new source review program. lllinois 

EPA will be submitting the regional haze SIP, including provisions to implement 

Best Available Retrofit Technology ("BART"), in the near future. 

Air quality modeling data: Section 110(a)(2)(K) requires that SIPS provide for 

performing air quality modeling for predicting effects on air quality of emissions 

from any NAAQS pollutant and submission of such data to USEPA upon request. 

lllinois EPA maintains a capability to perform modeling of the air quality impacts 

of emissions of all criteria pollutants, including the capability to use complex 

photochemical grid models. lllinois EPA performs modeling in support of the SIP 

for all nonattainment areas in the State. lllinois EPA also requires air quality 

modeling in support of permitting the construction of major and some minor new 

sources under the PSD program. These modeling studies are thoroughly 

documented and are available to the USEPA and the public upon request. 

Furthermore, the lllinois EPA participates in multi-state regional modeling efforts, 

including participation and providing funding for the LADCO. LADCO conducts 

regional modeling that is utilized for statewide planning purposes. The lllinois 

EPA is also contracting out for more refined modeling in the Metro-East 

nonattainment area. 

Permitting fees: Section 110(a)(2)(L) requires SIPS to require each major 

stationary source to pay permitting fees to cover the cost of reviewing, approving, 

implementing and enforcing a permit. 
requires States to provide for consultation and participation in SIP development 

by local political subdivisions affected by the SIP. 

lllinois EPA follows approved procedures for allowing public participation, 

consistent with 35 111. Adm. Code Part 164, Procedures for Informational and 

Quasi-Legislative Public Hearings, and 35 111. Adm. Code Part 252, Public 

Participation in the Air Pollution Control Permit Program. Part 252 is an 

approved portion of Illinois' SIP. Note that the Illinois EPA recently conducted 

public meetings in both nonattainment areas regarding its recommendations for 

proposed PM2.5 boundaries pursuant to the new 24-hour PM2.5standard, although 

no such requirements for such meetings exist. 

Based on the information provided in these discussions, I believe that Illinois EPA 

meets or exceeds all of the necessary CAA Section 11 0 infrastructure needs, enabling us to continue to satisfy those requirements of the CAA. If you have any questions, 

please feel free to contact Laurel Kroack, Chief of the Bureau of Air, (217) 785-4140. 

Very truly yours, 

~ou~lag P. Scott 

Director 

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