July 26,2004

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illinois Pollution Control Board

JUL.

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Illinois

James R. Thompson Center

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Rec”clinn

100 W. Randolph St., Suite 11-500

POWJT?OPJ CCJNT~OL

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Chicago, IL 60601

Association

P.O.

Box3717

Oak Park, IL 60303-3717

Voice: 708.358.0050

FAX:

708.358.0051

Dear Sir or Madam:

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illinoisrecycles. org

www.illinoisrecycles.org

The Illinois Recycling Association respectfully submits this letter in support

of Falcon Waste & Recycling Inc.’s petition for an adjusted standard ruling

regarding their shingle recycling process. In our view, this process should be

consideted a legitimate recycling process, not waste handling or waste

disposal, and therefore the petitioners should not be required to obtain waste

handling permits. Falcon’s process involves obtaining post manufacturing

shingle material and through a clean grinding process, creates a recycled

content commodity in the form of alternative driveway paving. This new

product made from recycled material is a perfect example of the statutory

definition of recycling

“. . .

any process by which materials thatwould

otherwise be disposed of or discarded are collected, separated or

processed and returned to the economic mainstream in the form of raw

materials or products.”

Falcon’s process prevents

the

shingle scraps from

being

sent to

the

landfill for disposal by making a new product out of them.

The market for this product is not based on speculation. There is a

demonstrated market in terms of standing orders for this product.

•

This

product has been tested in use and proven effective for its stated application.

The Illinois Recycling Association believes it is very important for the IEPA

and the IPCB to approve the development of this type of creative and

innovative market development that increases the recycling industry’s ability

to serve as a significant economic driver inIllinois. Innovative processes

such as Falcon Waste and Recycling Inc.’s, should be embraced and

applauded for finding ways to keep otherwise hard to recycle materials out of

landfills and into the productive economy in an environmentally friendly

way. Thank you for your consideration in this matter.

Respectfully,

Michael Mitche

Executive Director

Cc:John Kim

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