People v. PSI Energy, Inc.

CourtAppellate Court of Illinois
DecidedMarch 23, 2006
Docket5-04-0602 Rel
StatusPublished

This text of People v. PSI Energy, Inc. (People v. PSI Energy, Inc.) is published on Counsel Stack Legal Research, covering Appellate Court of Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
People v. PSI Energy, Inc., (Ill. Ct. App. 2006).

Opinion

Rule 23 order filed NO. 5-04-0602 February 3, 2006; Motion to publish granted IN THE March 28, 2006. APPELLATE COURT OF ILLINOIS FIFTH DISTRICT ________________________________________________________________________ THE PEOPLE ex rel. LISA MADIGAN, ) Appeal from the Attorney General of the State of Illinois, and ) Circuit Court of ex rel. TERRY KAID, Wabash County State's ) Wabash County. Attorney, ) ) Plaintiffs-Appellees, ) ) v. ) No. 04-CH-20 ) PSI ENERGY, INC., ) ) Defendant-Appellant, ) ) and ) ) CINERGY POWER GENERATION ) SERVICES, LLC, ) Honorable ) David K. Frankland, Defendant. ) Judge, presiding. ________________________________________________________________________

JUSTICE DONOVAN delivered the opinion of the court:

Defendant PSI Energy, Inc. (PSI), appeals from the preliminary injunction entered by the circuit court of Wabash County enjoining PSI from operating certain pollution-control

equipment at its Gibson Power Generating Station (Gibson Station) in Owensville, Indiana,

except in accordance with the terms of the injunction. PSI also appeals the denial of its motion to dismiss for lack of subject matter jurisdiction. We vacate the preliminary injunction and remand this cause with directions for dismissal on the grounds of federal

preemption. PSI owns and operates Gibson Station in Owensville, Indiana, which is approximately

three miles from Mt. Carmel, Illinois. Gibson Station is a 3,150-megawatt, coal-fired,

1 electric-power-generating facility that supplies electricity to customers in Indiana. Defendant

Cinergy Power Generation Services, LLC (CPGS), was not a party to the motion to dismiss, nor was CPGS enjoined by the preliminary injunction. CPGS, while connected to PSI, does not operate or exercise control over Gibson Station.

The federal Clean Air Act (42 U.S.C. '7401 et seq. (2000)) and United States Environmental Protection Agency (USEPA) regulations are designed to address environmental emissions and pollution-control systems at coal-fired, electric-power-

generating stations such as Gibson Station. USEPA has required certain states, including Indiana, to lower nitrogen oxide emissions from such stations as well as from other large

combustion sources. One means of reducing the emissions from electric-power-generating

units is to use selective-catalytic-reduction equipment (SCR). SCRs use chemical processes

to reduce nitrogen oxide emissions by channeling heated gas over catalytic reactants. As a result of these processes, small levels of sulfur dioxide oxidize to form sulfur trioxide. Coal-

fired, electric-power-generating stations, in order to comply with acid rain regulations, must

also "scrub" their emissions to reduce content. The water from the emission scrubbers, when

combined with sulfur trioxide, can yield sulfuric acid. Trace amounts of both sulfuric acid and sulfur trioxide dissipate upward as a part of the plant's plume. Depending on certain variables, including weather, humidity, and wind, a plume can invert and sink to ground level

for brief periods of time. In early June of 2004, a plume inversion headed in the direction of Mt. Carmel. PSI responded by switching the type of coal used and started testing additives to counter the

impact of the SCR devices on the plume. It also met with residents and city officials from Mt. Carmel and informed them of the situation and possible solutions.

A second plume inversion occurred over Mt. Carmel on the morning of July 21, 2004. In response, PSI started testing a series of different additives and instituted a "Protocol for

2 Operation of SCR Reactors" (hereinafter Protocol) to proactively and immediately "minimize

the possibility of any potential [sulfur dioxide], [sulfur trioxide], or acid aerosol impacts in populated areas." The Protocol created a full-time, plume-watching position and called for a shutdown of the SCRs under circumstances where the plume, whether inverted or not, might

head toward Mt. Carmel. As a result, there have been no plume inversions, and no plant- related haze has drifted over or near Mt. Carmel since the July incident. The Illinois Attorney General filed a complaint and a motion to enjoin defendants

from operating the SCR devices at Gibson Station except as defined in the Protocol, claiming that "emergency relief is required given that releases of sulfur trioxide have resulted in a

serious hazard to the environment and to public health and welfare." Shortly after the July 21

plume reached Mt. Carmel, numerous residents complained of burning eyes, scratchy throats,

and coughing caused by the thick haze covering their town. PSI filed a motion to dismiss alleging that regulation of its pollution-control devices was preempted by the federal Clean

Air Act. The circuit court denied PSI's motion and entered a preliminary injunction on the

grounds that "the failure to have the Court's involvement to maintain the status quo could

result in irreparable harm and damage." PSI argues on appeal that the court erred in finding subject matter jurisdiction based on the application of Illinois state law to an interstate air-emission issue controlled

exclusively by federal law. PSI also asserts the court abused its discretion in finding a violation of the Illinois Environmental Protection Act (415 ILCS 5/1 et seq. (West 2004)) and in finding a "substantial danger" warranting an immediate injunction in the absence of actual

or potential harm. PSI further finds fault with the injunction itself in that it is vague and overly broad. We agree with PSI that the preliminary injunction must be vacated and that

plaintiffs' complaint must be dismissed because the Clean Air Act preempts Illinois's claims under the Illinois Environmental Protection Act. As noted in International Paper Co. v.

3 Ouellette, 479 U.S. 481, 93 L. Ed. 2d 883, 107 S. Ct. 805 (1987), preemption in interstate

pollution disputes serves the valuable purpose of minimizing regulatory chaos, unpredictability, and innumerable interstate conflicts that are created when one state asserts jurisdiction over an out-of-state source.

Beginning some 30 years ago, a series of cases established that federal law governs interstate pollution disputes with respect to the Federal Water Pollution Control Act Amendments of 1972 (Clean Water Act) (33 U.S.C. '1251 et seq. (2000)) and that state law

may not be applied by one state to regulate an emissions source in another state. See Illinois v. City of Milwaukee, Wisconsin, 406 U.S. 91, 31 L. Ed. 2d 712, 92 S. Ct. 1385 (1972); City

of Milwaukee v. Illinois & Michigan, 451 U.S. 304, 68 L. Ed. 2d 114, 101 S. Ct. 1784 (1981);

Illinois v. City of Milwaukee, 731 F.2d 403 (7th Cir. 1984). These cases were further

clarified by the Supreme Court in International Paper Co. v. Ouellette, 479 U.S. 481, 93 L. Ed. 2d 883, 107 S. Ct. 805 (1987), in which the parties argued whether, notwithstanding the

federal Clean Water Act, Vermont common law could be applied to a New York source for

damages that allegedly occurred in Vermont. The Court concluded that preemption, which

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Related

Illinois v. City of Milwaukee
406 U.S. 91 (Supreme Court, 1972)
City of Milwaukee v. Illinois
451 U.S. 304 (Supreme Court, 1981)
International Paper Co. v. Ouellette
479 U.S. 481 (Supreme Court, 1987)
United States v. Kin-Buc, Inc.
532 F. Supp. 699 (D. New Jersey, 1982)
Clean Air Markets Group v. Pataki
338 F.3d 82 (Second Circuit, 2003)
Illinois v. City of Milwaukee
731 F.2d 403 (Seventh Circuit, 1984)

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