Comment submitted by Laurel L. Kroack, Chief, Bureau of Air, Illinois Environmental Protection Agency (Illinois EPA)

The Illinois Environmental Protection Agency (Illinois EPA) appreciates the opportunity to comment on the subject rulemaking. We are particularly concerned that in the Final Rule to Implement the 8-Hour Ozone National Ambient Air Quality Standard ? Phase 2 (November 29, 2005), U.S. EPA determined that electric generating units (EGUs) complying with the requirements of the CAIR would be considered as meeting the NOx RACT requirement. This determination will hinder Illinois? ability to achieve NOx emissions reductions from EGUs that impact our ozone nonattainment areas, which may in turn cause delays in attaining the ozone NAAQS in a timely manner. We are pleased that U.S. EPA is revisiting this issue and we hope it will reconsider its position. The complete set of Agency comments are contained in the attached document.