BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF:
)
)
PROPOSED AMENDMENTS TO:
)
R04-022
REGULATION OF PETROLEUM
)
(UST Rulemaking)
LEAKING UNDERGROUND STORAGE )
TANKS (35 ILL.ADM.CODE 732)
)
)
IN THE MATTER OF:
)
)
PROPOSED AMENDMENTS TO:
)
R04-023
REGULATION OF PETROLEUM
)
(UST Rulemaking)
LEAKING UNDERGROUND STORAGE )
Consolidated
TANKS (35 ILL.ADM.CODE 734)
)
TESTIMONY OF UNITED SCIENCE INDUSTRIES, INC. TO ALTER THE ILLINOIS
ENVIRONMENTAL PROECTION AGENCY’S PROPOSAL TO AMEND 35 ILL.
ADM. CODE 732 AND 35 ILL. ADM. CODE 734
My name is Becky Canty. I am the Superintendent of Elverado Unit
#196 Schools in Elkville, IL. Our school district in Elkville is a
single incident PRP and therefore an interested party in the above
rulemaking and I would like to offer the following testimony as it
pertains to these rulemakings and the upcoming hearing on July 27,
2005.
Elverado Unit #196 School district is currently involved in a
single incident clean up and the following are my observations,
comments and testimony regarding our experience with the LUST Fund and
the IEPA.
1. Trying to make all kinds of specifications from
generalizations is never a good process. As educators we know that
children are not the same either academically, physically, emotionally,
and we don't or shouldn't educate them that way. That's why No Child
Left Behind doesn't work; one size doesn't fit all. This analogy can
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JULY 8, 2005
also be applied to the proposed rulemakings and their apparent number
of conceptual flaws in the rules as currently presented in the First
Opinion and Order.
2. The money from this LUST fund tremendously assists those of
us who are already forced to function within stretched and strained
budgets. The loser in an inflexible and flawed system will be the
individual tank owners who’s liability will be jeopardized.
3. This process (LUST) is an incredibly complicated issue for
those who own individual tanks. The assistance of expert
consultant/contractors who take over this responsibility is critical to
the effectiveness and success of a proper clean-up. Changing this
system could result in chaos and ignoring of the problem until our
valuable water and eco-systems are destroyed.
4. Because there are public dollars involved, and all owners and
operators of underground storage tanks are taxed-- Underground storage
tank owners and the companies that clean-up should not be held hostage
to an inflexible system.
Thank you for allowing me the opportunity to voice my opinions
and observations. I trust that the Pollution Control Board will be
vigilant in hearing, listening and understanding the needs of the small
owner/operator in protecting our future and our environment.
Sincerley,
Elverado Unit #196 Schools
Becky Canty
Superintendent
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JULY 8, 2005