Illinois

Manufacturers’

Association

September

17,

2008

CLERK’S

OFFICE

‘N—

SEP

262008

Ms.

Dorothy

0mm

STATE

OF

ILLINOIS

Illinois

Pollution

Control

Board

Pollution

Control

Board

James

R.

Thompson

Center

100 W.

Randolph

Street;

Suite

11-500

Chicago

IL

60601

RE:

Rule

2006-20.

Proposed

amendments

to the

Board’s

Specii

Wziste

Regulations

concerning

Used

Oil,

35

Iii.

Adm.

Code

808,

809

Dear

Ms.

Gunn:

On behalf

of

the Illinois

Manufacturers’

Association

(IMA)

and

our

thousands

of

member

companies

across

the

state,

I

would

like

to

join

the

National

Oil Recyclers

Association

(NORA)

and respectfully

express

our

support

of the

proposed

rule

governing

used

oil.

As with

many

regulations,

the IMA

believes

that

our

member

cornpanie.s

would

benefit

from

an

Illinois

regulation

that

mirrors

current

federal

regulations

and

the

United

States

Environmental

Protection

Agency.

The uniformity

will make

it easier

for

manufacturing

companies

to

comprehend

and

follow

the regulations

leading

to

efficiencies

and

increased

compliance.

We

support

NORA’s proposal

to exclude from

the

Illinois

Special

Waste

regulations

all

materials

subject

to federal

regulation.

This

component

will

simplify

the paperwork

system

without

jeopardizing

either

human

health

or

the environment.

Illinois

would

also

join

all

of our

neighboring

states

who

have

replaced

complex

and burdensome

regulations

and

manifests

with

the new

system.

Quiet

simply,

Illinois’

current

Oil

Manifesting

Program

is antiquated

and

lacks

efficiencies

that

increases

the

cost

for

Illinois

businesses

and

imposes

unfair

requirements

that

make

it

more

difficult

for our

companies

to operate.

In

closing,

I again

ask for

your

support

of

these

common-sense

reforms

that

will

protect

the

environment

and

help

Illinois-based

companies.

Regards,

Mark

Denzl

Vice

President — Government Affairs

220

East

Adams

Street

.

Springfield,

Illinois

62701

Telephone:

(217)

522-1240

• Fax:

(217)

522-2367

1211 West

22nd

Street,

Ste.

620

•

Oak Brook,

Illinois

60523

• Telephone:

(630)

368-5300

• Fax:

(630)

218-7467

Web

Site:

www.ima-net.org

E-mail:

ima@ima-net.org