RECEIVED
BEFORE THE ILLINOIS POLLUTION CONTROL BOAI~iY~OFFICE
MAR
31
2003
THE CITY OF KANKAKEE, an Illinois
)
Municipal Corporation
)
STATE OF
(LLINOIS
)
Pollution
control
Board
Petitioner
)
v.
)
No.
PCB 03-125
)
COUNTY OF KANKAKEE, a body politic and
)
(Third-Party Pollution
Control Facility
Corporate; KANKAKEE COUNTY BOARD;
)
Siting Appeal)
And WASTE MANAGEMENT OF ILLINOIS,
)
INC.,
)
Respondent
)
)
MERLIN KARLOCK,
)
Petitioner
)
)
v.
)
No. PCB 03-133
COUNTY OF KANKAKEE, a body politic and
)
(Third-Party Pollution Control Facility
Corporate; KANKAKEE
COUNTY BOARD;
)
Siting Appeal)
And WASTE MANAGEMENT OF ILLINOIS,
)
INC.,
)
Respondent
)
)
MICHAEL WATSON,
)
Petitioner
)
)
v.
)
No. PCB 03-134
COUNTY OF KANKAKIEE, a body politic and
)
(Third-Party Pollution Control Facility
Corporate; KANKAKEE COUNTY BOARD;
)
Siting Appeal)
And WASTE MANAGEMENT OF ILLINOIS,
)
INC.,
)
Respondent
)
KEITH RUNYON,
)
Petitioner
)
)
v.
)
No. PCB 03-135
COUNTY OF KANKAKEE, a body politic and
)
(Third-Party Pollution
Control Facility
Corporate; KANKAKEE COUNTY BOARD;
)
Siting Appeal)
And WASTE MANAGEMENT OF ILLINOIS,
)
INC.,
)
Respondent
)
)
CLERK’S
OFFICE
WASTE MANAGEMENT
OF ILLINOIS
)
MAR
312003
INC.,
Petitioner
)
STATE OF IWNOIS
)
Pollution
Control Board
v.
)
No. PCB 03-144
)
(Pollution Control Facility
COUNTY OF
KANKAKEE,
)
Siting Appeal Consolidated)
)
Respondent
)
NOTICE
OF FILING
To:
See Attached Service List
PLEASE TAKE NOTICE that on March 27, 2003
there caused to be filed via U.S. Mail
with the Illinois Pollution Control Board an original and 9 copies ofthe following document, a
copyofwhich is
attached hereto:
Response to Motion to
Dismiss Petition for Review Filed by The City ofKankakee
Respectfully submitted,
The City ofKankakee
By:
____________
Attorneyf r City ofKa
~tkee
Prepared by:
L. Patrick Power #22443
57
Corporate Counsel
956 North Fifth Ave.
Kankakee, IL
60901
(815) 937-6937
2
AFFIDAVIT
OF SERVICE
The undersigned, pursuant to the provisions ofSection
1-109 of the Illinois
Code
ofCivil Procedure, hereby under penalty ofperjury under the laws ofthe United States of
America,
certifies that on March 27,
2003,
a copy of the foregoing
Response
to
Motion
to Dismiss Petition for Review Filed by the City ofKankakeewas served upon:
Dorothy M. Gunn,
Clerk
Illinois Pollution Control Board
James Thompson Center
100 W.
Randolph St., Suite 11-500
Chicago,
IL
60601-3218
Charles F. Heisten
Attorney atLaw
P.O. Box 1389
Rockford, IL 61105-1389
Attorney for Kankakee County Board
Kenneth Leshen
One
Dearborn Square, Suite
550
Kankakee, IL
60901
(815) 933-3385
(815)
933-3397Fax
George Mueller
Attorney atLaw
501 State Street
Ottawa,
IL 61350
(815)
261-2149
(815)
433-4913 Fax
Keith Runyon
1165 Plum Creek Dr. #D
Bourbonnais, IL 60914
(815)
937-9838
(815)
937-9164 Fax
Donald J.
Moran
Attorney atLaw
161N. Clark, Suite 3100
Chicago,
IL 60601
(312) 261-2149
(312) 261-1149 Fax
Elizabeth Harvey, Esq.
One IBM
Plaza, Suite 2900
330 N.
Wabash
Chicago,IL 60611
(312) 321-9100
(312) 321-0990 Fax
Jennifer J. SackeftPohlenz,
Attorney atLaw
175 W. Jackson Blvd., Suite 1600
Chicago,IL 60604
(312) 540-7540
(312) 540-0578Fax
Kenneth A. Bleyer
Attorney at Law
923
W. Gordon Ter. #3
Chicago, IL 60613-2013
Patricia O’Dell
1242 Arrowhead Dr.
Bourbonnais, IL 60914
Brad Halloran, Hearing
Officer
Illinois Pollution Control Board
100 W. Randolph St., Suite
11-500
Chicago,IL 60601-3218
By
depositing a copy thereof,
enclosed in
an envelope
in
the United States Mail at Kankakee,
Illinois, proper postage
prepaid,
before
the
hour
of 5:00
p.m.,
on
27th
day
of
March 2003,
addressed as above.
ofMarch 2003.
Prepared by:
L. Patrick Power
Assistant City Attorney
956
N. Fifth Avenue
Kankakee, IL
60901
(815)
937-6937
Kenneth A.
Leshen
Assistant City Attorney
One Dearborn Square, Suite
550
Kankakee,IL
60901
(815)
933-3385
R
BEFORE THE ILLINOIS POLLUTION CONTROL BOAI~R
312003
THE CITY OF
KANKAKEE,
an Illinois
)
STATE OF IWNOIS
Municipal Corporation
)
Pollution
Control Board
)
Petitioner
)
v.
)
No.
PCB 03-125
)
COUNTY OF
KANKAKEE,
a body politic and
)
(Third-Party Pollution Control Facility
Corporate;
KANKAKEE
COUNTY BOARD;
)
Siting Appeal)
And WASTE MANAGEMENT OF ILLINOIS,
)
INC.,
Respondent
)
)
MERLIN KARLOCK,
)
Petitioner
)
)
v.
)
No. PCB 03-133
COUNTY OF
KANKAKEE,
a body politic and
)
(Third-Party Pollution Control Facility
Corporate;
KANKAKEE
COUNTY BOARD;
)
Siting Appeal)
And WASTE MANAGEMENT OF ILLINOIS,
)
INC.,
Respondent
)
)
MICHAEL WATSON,
)
Petitioner
)
)
v.
)
No. PCB 03-134
COUNTY OF
KANKAKEE,
a body politic and
)
(Third-Party Pollution Control Facility
Corporate;
KANKAKEE
COUNTY BOARD;
)
Siting Appeal)
And WASTE MANAGEMENT OF ILLINOIS,
)
INC.,
Respondent
)
KEITH RUNYON,
)
Petitioner
)
)
v.
)
No.
PCB 03-135
COUNTY OF
KANKAKEE,
a body politic and
)
(Third-Party Pollution Control Facility
Corporate;
KANKAKEE
COUNTY BOARD;
)
Siting Appeal)
And WASTE
MANAGEMENT OF ILLINOIS,
)
INC.,
)
Respondent
)
IRE CE
~V E ~
CLERK’S
OFFICE
WASTE MANAGEMENT OF ILLINOIS
)
MAR
312003
INC.,
)
STA~EOF ILLINOIS
Petitioner
)
Pollution
Control Board
)
v.
)
No. PCB 03-144
)
(Pollution Control Facility
COUNTY OF
KANKAKEE,
)
Siting
Appeal Consolidated)
)
Respondent
)
RESPONSE TO MOTION TO DISMISS
PETITION FOR REVIEW FILED BY THE CITY
OF
KANKAKEE
Now
comes
City of Kankakee,
a
Municipal
Corporation,
(“City”),
by
and
through
its
attorneys,
L.
Patrick
Power
and
Kenneth
A.
Leshen,
Assistant
City Attorneys,
and
files
this
response
to
the Motion to
Dismiss Petition
for Review
filed by the
City of Kankakee,
and
in
support thereof, states as follows:
I.
THE ABOVE
REFERRED
TO MOTION WAS
NOT FILED
IN A
TIMELY
MANNER
IN
ACCORDANCE
WITH
THE
PROVISIONS
OF
THE
ILLINOIS
POLLUTION CONTROL BOARD RULE
101.506.
A.
Rule
101.506
requires
that
all
Motions
such
as the
one
filed by
the
County of
Kankakee must be
filed within 30 days after service ofthe challenged document,
unless the Board determines that material prejudice would result.
B.
In this case, notice was served upon Movant on February 20, 2003.
The motion in
question was
filed more
than
30
days
after service of the
City
of Kankakee’s
Petition for Review.
(See Exhibit
1
attached)
II.
THE
POLLUTION
CONTROL
BOARD
HAS
ALREADY
DETERMINED
THAT
THE
CITY
OF
KANKAKEE
IS
A
PROPER
PARTY
TO
THIS
PROCEEDING
AND
HAS ACCEPTED
ITS PETITION IN
THE ORDER OF MARCH 6, 2003.
A.
The Order
states in pertinent part as follows:
2
“For the reasons set
forth
below, the Board
accepts
the petitions
for
hearing
and
consolidates
the
proceedings
on
the
Board’s
own
motion.”
B.
In accepting the Petition, the Board has found that the Petitioner satisfies
all
of
the
requirements
of
415
ILCS
5/40.1(b)
and
is
therefore
not
“duplicitous or frivolous”.
C.
Said
Order further
finds
that the Petition of the
City of Kankakee meets
the content required of 35
Ill.
Adm.
Code
107.28,
including the
fact that
the Petitioner is so located as to be affected by the proposed facility.
III.
THE
CITY
OF
KANKAKEE
HAS
STANDING
TO
APPEAL
THE
DECISION
OF
THE
COUNTY OF
KANKAKEE
APPROVING
THE
SITING
IN THIS
CAUSE TO THE
POLLUTION
CONTROL BOARD, IS WITHOUT
MERIT, BECAUSE
IT MEETS THE REQUIREMENTS OF 415 ILCS 5/40.1(b).
A.
In this case, the City ofKankakee filed as an objector and fully participated in the
siting hearings held in this
cause pursuant
to
the rules
established by the County
Board of Kankakee County
and
in
accordance with
the provisions of 415
ILCS
5/39.2.
No party, including Kankakee County,
objected to the City ofKankakee
participating as an objector.
B.
After
fully participating
in
said
siting hearings,
without
objection,
the
City
of
Kankakee filed its Petition to
Review the County Board’s decision approving the
siting with the Illinois
Pollution Control Board pursuant to
the provisions of 415
ILCS
5/40.1(b).
C.
Said section
5/40.1(b)
reads in pertinent part as follows:
A
third
party
other
than
the
applicant
who
participated
in
the
public
hearing conducted
by the
county board or governing
body
ofthe municipality may, within 35
days after the date on which the
local siting authority granted siting approval, petition the Board for
a
hearing
to
contest
the
approval
of
the
county
board
or
the
governing body of the municipality.
Unless the Board
determines
3
that such petition is duplicative or frivolous, or that the petitioner is
so located as to
not be
affected by the proposed facility, the Board
shall hear the petition in accordance with
the terms of subsection
(a)
of
this
Section
and
its
procedural
rules
governing
denial
appeals, such hearing to be based
exclusively on the record before
county board orthe governing body ofthe municipality.
D.
The County of Kankakee’s Motion
does not
argue that
the City
of Kankakee’s
Petition is “duplicative” or
“frivolous”.
The Pollution Control Board’s Order of
March 6, 2003, makes this specific finding.
E.
The
City of Elgin
case
cited
by
Movant
is
inapplicable
to
this
case.
That
case
involved to a contest ofa zoning amendment passed by an
agency called the Solid
Waste
Agency
of
Northern
Cook
County
(SWANCC),
which
was
a
zoning
approval for a construction of a landfill.
Rather than appeal that
decision to
the
Illinois
Pollution
Control Board,
the
objectors
chose
to
file
suit
in
the
Circuit
Court of Cook
County.
The County Court
dismissed this
action with
prejudice.
In support of its position, the Plaintiff-Appellant argued that
Barrington
Hills
v.
Village
of Hoffman
Estates,
81
Ill.
2d
392
and
Hickory
Hills
v.
Village
of
Bridgview,
67
Ill.
2d
399,
allowed them
to
appeal such decisions to
the Circuit
Court.
The Elgin Court distinguished these cases
by
indicating
that they were
zoning decisions that
did not involve
the siting of a solid
waste
disposal facility
and
did
not
otherwise implicate the Illinois
Environmental
Protection
Act
(Page
65
of said decision).
The Courts then indicated that
“.
.
.
the
1981
amendments
provided
that
the
local
government
decisions
approving
the
siting
of pollution
control
facilities
are
appeallable
to
the
Pollution
Control
Board.
(415
ILCS
5/40.1(b))”.
Only the decision ofthe Pollution Control
Board is
appealable to the
Court.
F.
In this case, the City of Kankakee has appealed to the Pollution control Board,
as
called for in
City ofElgin
v.
County of Cook.
4
G.
Further,
City
of Elgin
v.
County
of
Cook
relates
to
Section
39.2
(c)
of
the
Environmental Protection
Act.
(Page
70
of said
case)
This
case
at
bar,
is
an
appeal
from
a
decision under
39.2
of the Environmental
Protection
Act.
The
latterprovides
for broad public input; the former does not.
H.
Since the City
of Kankakee
was allowed to
participate by
the
County
in
these
hearings
as an
objector,
and
since the
issue of lack of standing was
not
raised
prior
to
the
hearing by the County,
that
issue if it has any merit
whatever,
was
waived, except for the grounds contained in Section 5/40.1(b).
IV.
THE
CITY
OF
KANKAKEE
IS
SO LOCATED
AS
TO BE
SIGNFIANTLY
AFFECTED BY THE
PROPOSED FACILITY.
A.
Movant
cites
Ogle County Board v. Pollution Control Board,
272 Ill.
App.
184 in
support ofthe proposition City ofKankakee
is
so located as to not be
affected by
the proposed facility. In the
Ogle
County
case, the Court
found that
an
objector
named Carmichael, who lived
10 miles
from the proposed facility and who was a
director
and
shareholder
in
a
bank
located
approximately
4
miles
from
the
proposed facility and who was a director at a grain elevator located
2.5
miles from
the landfill was ~
a person “so
located as
to
not
be
affected
by
the proposed
facility.” (page
190 ofsaid decision)
B.
In the
case at
bar, the
City of
Kankakee’s
interest
are dramatically affected:
(i) the City’s boundary lines run approximately one mile from the proposed site in
this
case;
(ii) property values,
traffic
congestion
and
safety hazards
caused by
improper design
or operation
of any
facility
on
the proposed
site could
clearly
affect the interest of the City ofKankakee whose boundaries
lie
so close to
said
proposed
cite;
(iii)
the
City
of
Kankakee
takes
it
drinking
water
from
the
Kankakee River, which receives water from the proposed site.
Any run-offfrom
the proposed facility and the run-off from
the existing
facility or pollution of the
aquifer underlying the site and the
entire
County of Kankakee as a
result of the
5
unsafe design or operation ofthe facility would
directly affect the health,
safety
and welfare of the City ofKankakee’s citizens; (iv)
the proposed site is within the
mile and one-halfzoning jurisdiction ofthe City ofKankakee.
WHEREFORE, the
City of Kankakee prays
that the Motion
to
Dismiss
filed herein by
the County ofKankakee be either dismissed or denied.
Respectfully submitted,
The City ofKankakee
By
__________________________
Prepared by:
L. Patrick Power #2244357
Corporate Counsel
956
North Fifth Ave.
Kankakee,
IL
60901
(815)
937-6937
6
THE CITY OF
KANKAKEE,
an Illinois
Municipal Corporation
VS.
)
)
)
)
No.
PCB’
(Pollution
Control Facility
Siting Appeal)
RE
CE ~V ED
CLERK’S
OFFICE
FEB
2
0
2003
BEFORE
THE
ILLINOIS POLLUTION CONTROL BOARD
STATE OF ILLINOIS
Pollution
Control Board
)
)
Plaintiff
)
)
)
COUNTY OF
KANKAKEE,
.a body politic and
Corporate;
KANKAKEE
COUNTY BOARD;
And
WASTE MANAGEMENT OF ILLINOIS,
INC.,
Defendants
)
NOTICE OF
FILING
To:
See Attached Service List
PLEASE
TAKE NOTICE
that on February
20, 2003
there has caused to be filed via U.S.
Mail
with the Illinois
Pollution Control
Board,
an original of the following documents, a copy of which
are
attached hereto:
PETITION FOR
HEARING
TO
CONTEST SITE
LOCATION
AJ’PROVAL
By:
__________
Attorney
ua.
.u.
STATE OF ILLINOIS
)
)ss
)
The
undersigned, being
first
duly sworn, state that I served a true
and
correct copy of the aforegoing Notice, together with a copy
of each
document refçrredjo therein,
upon the person(s) indicated
at their address(es) in
~cated
by mailing in Kankakee, Illinois,
before
6:OOP.M.onthe
q’OlJ.~
day
of February 2003.
a?
SUBSCRIBEDAND SWORN TO before me this
COUNTY
OF KANAKKEE
Prepared by:
L. PATRICK
POWER #2244357
ATTORNEY
AT LAW
956
NORTH FIFTH AVENUE
KANKAKEE~
ILLINOIS
60901
(815)
937-693‘7
Proof of Service
‘~.
/
SERVICE
LIST
Karl
Kruse, Charman
Kankakee
County Board
189 E.
Court
St.
Kankakee, IL
60901
CharlesF.
Heisten
Attorneyat
Law
P.O. Box 1389
ItockfordL
61105-1389
Attorney
for
Kankakee
County
Board
Fax;
(815)
963-9989
Edward Smith
450
East Court
St.
!Cankakee,JL
60901
Ynn1c~i1ceeCounty
State’s
Attorney
Fax: (815)
937-3932
L. Patrick
Power
Attorney
at
Law
956
North
Fifth
Avenue
Kankakee, IL
60901
Leland
Milk
6903
S.. R.oute
45-52
Chebanse, IL
60922
KeithRunyon
1165 PlumCreek
Dr.
Bo~irbonnais,IL
60914
Donald J. Moran
Attorney
at
Law
161
N.
Clark,
Suite 3100
Chicago, IL
60601
Attorneyfor
Waste
Management offllinois
Fax: (312)261-1149
Bruce Clark
Kankakee
County
Clerk
189 E.
Court
St.
Kankakee,
IL
60901
Fax:
(815)
939-8831
Jennifer
J.
Sackett
Poblenz
Attorney
at
Law
275 W. JacksonBlvd.., Suite
1600
Chicago.
IL
60604
Attorney
for Mike Watson
Fax
(312)
540-0578
Kenneth A.
Bleyer
Attorney at
Law
923
W. Gordon Ter. #3
Chicago, IL
60613-2013
Patricia
O’Dell
1242
ArrowheadDr.
Bourbonnais,
IL
60914
George Mueller
Attorney at Law
501 State Street
Ottawa,
IL
61350
/
TOTflL
P.02
-
.
•
CLERK’S OFFICE
~
2
0
2003
STATE OF
ILLINOIS
Pollution
Control Board
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
THE CITY OF KANKAKEE,
an Illinois
)
MunicipalCorporation
)
)
Plaintiff
)
VS.
)
No.
PCB ~
)
COUNTY OF KANKAKEE,
a body politic
and
)
(Pollution Control Facility
Corporate;
KANKAKEE COUNTY BOARD;
)
Siting Appeal)
And
WASTE
MANAGEMENT
OFILLINOIS,
)
INC.,
)
Defendants
)
PETITIONFORHEARING
TO CONTEST SITE LOCATION APPROVAL
Now
comes
Petitioner City of
Kankakee,
a
Municipal
Corporation,
(“City”),
by
and
through
its
attorneys, L.
Patrick Power
and
Kenneth
A.
Leshen,
Assistant
City Attorneys,
and
respectfully requests a hearing to contest the decision of the Kankakee
County
Board (“County
Board”)
granting
site location approval for a new regional
pollution control facility.
In support
of
this
Petition, the City states as follows:
1.
This
petition
is
filed
pursuant
to
Section
40.1
of the
Illinois
Environmental
Protection Act, (the “Act”)
(415
TLCS
5/40.1).
2.
On August
16,
2002,
Waste
Management of Illinois,
Inc.
(“WMII”)
filed
an
application
with the
County
Board for a new
regional
pollution
control
facility immediately
adjacent to its
existing landfill.
3.
On
January
31,
2003,
following
service
and
publication
of notice
and
public
hearings
conducted before
the County
Board,
the
County
Board
formally approved
the siting
request.
A
true
and
correct
copy of the decision of the County
Board
is
attached hereto
and
incorporated herein as Exhibit A.
4.
The City appeared and participated in the hearings held before the County Board.
I
•
1
5.
The City contests
and
objects to the County
Board’s siting approval because the
siting
process
and
procedures
used
by
the
County
Board
in
reaching
its
decision
were
fundamental
unfair for the following reasons:
(a)
Members ofthe County Board prejudged the
siting
application;
(b)
The County Board did not make available to the public required documents;
(c)
Procedural irregularities renderedthe hearings fundamentally unfair; and,
(d)
The
application
was
not
complete
and
neither
the
County
Board
nor
WMII
followed the local siting ordinance requirements;
6.
The
City
further
contests
and
objects
to
the
County
Board’s
siting
approval
because the County Board
lacked jurisdiction
to conduct the siting hearing and because ofthe
failure ofWMII to give statutory notice to each ofthe required parties.
7.
The
City
further contests
and
objects
to
the
County
Board”s
siting
approval
because the evidence presented by WMII failed to establish that WMII met the following criteria
as established in §39.2 ofthe Act, to
wit:
(A)
That
the facility is so designed, located and proposed to be operated
that the
public
health, safety and welfare will be protected.
Specifically, the evidence
submitted
by WMII and considered by the County Board
fell
short in one or more ofthe following particulars:
(i)
WMII has mischaracterized the permeability, thickness and regularity ofthe in
situ materials relied upon to protect the public safety;
(ii)
The groundwater impact assessment is based
on incorrect input parameters and
is thus ofno value;
(iii)
The inward hydraulic gradient is not sufficiently established or understood; and,
2
(iv)
The regional
bedrock aquifer underneath the existing
adjacent facility has been
contaminated
and
impacted by
the existing
facility and
the safety of leachate recirculation and
the proposedtie-in ofthe new facilityto the old facility have not been established.
(v)
No
statistics
or
testimony
were
presented
by
WMII
to
show
the
effects
of
recirculation of leachate upon the safe operation ofthe facility.
(vi)
WMII
failed
to
submit
any
plans
whatever for
monitoring the
site
during
its
operation forradioactive waste.
(vii)
WMII failed to do a
piezometric surface map ofthe clay beneath the liner in the
proposed plan.
(viii)
WI’vffl failed
to provide data that would
establish that the proposed ground water
monitoring system would be effective.
(B)
That
the facility is
located so as to so as to
minimize
incompatibility with the
character
of
the
surrounding
area
and
to
minimize
the
effect
on
the
value
of
the
surrounding properties.
Specifically,
the
evidence
submitted
by
WIvilI
and
considered
by
the
County
Board fell short in one or more ofthe following particulars:
(i)
WMII’s
expert
witness,
J.
Christopher
Lannert
failed
to
testify
as
to
the
plan
“minimizing incompatibility” and therefore did not speak to this criterion at
all.
(ii)
WMII’s expert witness,
Patricia Garr, misrepresented
her credentials as an expert
and
further, her
analysis of the estimated effect ofthe proposed facility on the value of farmland
and residential land in the area is unpersuasive.
(C)
That
the
plan
of
operation
for
the
facility
is
designed
the
minimize
the
dangers to the surrounding area from fire, spills, or other operational accidents.
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3
7
(D)
That the traffic patterns to or from the facility is so designed as to minimize
the impact ofthe existing traffic flow.
8.
The City
further contests
and
objects to the County Board’s siting
approval
because
the proposed
facility is
not
consistent
with
the
County
Solid
Waste Plan
in
that
it
prohibits location of a new regional pollution
control facility above a major aquifer
and
because
no Property value
Guarantee
program was independently prepared and approved by the County
Board.
WHEREFORE,
the Cityprays that the Board enterits order as follows:
A.
Setting for hearing
this
contest ofthe County Board Siting Decision;
B.
Reversing the County Board’s siting decision; and
C.
Providing
for
such
other
and
further
relief
as
this
Board
deems
to
be
just,
necessary and proper.
Respectfully submitted,
The City ofK
cc
By:
_____________________________
Attorneyfor Cityof
Kankakee
Prepared by:
L. Patrick Power #2244357
Corporate Counsel
956
North Fifth Ave.
Kankakee, IL
60901
(815)
937-6937
4
