BEFORE
    THE
    ILLINOIS
    POLLUTION
    CONTROL
    BOARD
    ELMHURST MEMORIAL
    HEALTHCARE
    and
    ELMHURST MEMORIAL
    HOSPITAL,
    Complainants,
    vs.
    RECEVED
    CLERK’S
    OFFICE
    JUN
    2
    62009
    )
    STATE
    OF
    ILLINOIS
    )
    Pollution
    Control
    Board
    )
    )
    No.
    PCB 2009-066
    )
    (Citizen’s Suit
    )
    Enforcement
    Action)
    )
    )
    )
    NOTICE
    OF FILING
    To:
    Carey
    S.
    Rosemarin
    Andrew
    J.
    Marks
    Law Offices
    of Carey
    S.
    Rosemarin,
    P.C.
    500
    Skokie
    Boulevard,
    Suite 510
    Northbrook, Illinois
    60062
    PLEASE
    TAKE
    NOTICE
    that
    on
    June
    26, 2009, we filed
    with the
    clerk
    of the
    Illinois
    Pollution
    Control
    Board
    an original
    and nine copies of
    Response
    of
    Chevron
    U.S.A.
    Inc. to
    Motion
    to
    Strike
    Affirmative Defenses,
    a copy of
    which is attached
    hereto
    and
    herewith
    served upon you.
    Dated:
    June
    26, 2009
    Joseph
    A.
    Girardi
    Robert
    B. Christie
    Henderson
    &
    Lyman
    Attorneys
    for
    Chevron U.S.A.
    Inc.
    175
    W.
    Jackson Blvd.,
    Suite 240
    Chicago,
    Illinois
    60604
    (312)
    986-6960
    CHEVRON
    U.S.A.
    INC.
    By:
    )
    )
    )
    CHEVRON
    U.S.A.,
    INC.
    Respondent.
    attorneys

    BEFORE
    THE
    ILLINOIS POLLUTION
    CONTROL
    BOARD
    ELMHURST MEMORIAL
    HEALTHCARE
    )
    ECEVED
    CLEq<’
    OFFIQE
    and
    ELMHURST
    MEMORIAL
    HOSPITAL,
    )
    2621109
    )
    STATE
    OF
    ILLINOIS
    Complainants,
    )
    No.
    PCB
    2Th1n
    Control
    Boa
    )
    (Citizen’s
    Suit
    vs.
    )
    Enforcement
    Action)
    )
    CHEVRON
    U.S.A., INC.
    )
    )
    Respondent.
    )
    RESPONSE OF
    CHEVRON U.S.A.
    INC.
    TO
    MOTION
    TO STRIKE
    AFFIRMATIVE
    DEFENSES
    Respondent,
    Chevron
    U.S.A.
    Inc.,
    incorrectly
    named
    as
    Chevron
    U.S.A.,
    Inc.
    (“Respondent”),
    by its attorneys
    Henderson &
    Lyman, and
    for its
    response to
    the motion
    of
    Complainants,
    Elmhurst Memorial
    Healthcare and
    Elrnhurst
    Memorial Hospital
    (“Complainants”),
    to
    strike
    affirmative
    defenses,
    states
    as follows:
    Law Applicable
    to
    the
    Complainants’
    Motion
    With
    respect
    to
    affirmative
    defenses, the procedural
    rules of the
    Illinois
    Pollution
    Control
    Board (“Board”) provide
    only that “any
    facts constituting
    an
    affirmative
    defense must
    be
    plainly set forth before
    hearing in the
    answer or
    in
    a
    supplemental
    answer,
    unless the
    affirmative
    defense could
    not
    have
    been
    known
    before
    hearing.”
    (Emphasis
    supplied)
    35
    Ill. Adm.
    Code
    103.204(d).
    As the Board
    procedural
    rules
    do
    not
    specifically
    define,
    state or
    enumerate specific
    affirmative defenses,
    the
    Board has
    defined
    affirmative
    defenses
    in many of its decisions.
    For
    example,
    in People
    of the
    State of
    Illinois
    v.
    Stein
    Steel Mills Services,
    Inc.,
    PCB
    No.
    02-1 (April 18, 2002),
    the
    Board
    initially
    defined an affirmative
    defense
    as
    “new
    facts or
    arguments that, if
    true,
    1

    will
    defeat. .
    .
    the
    government’s claim even
    if all allegations in the complaint
    are true.”
    Citing: People
    v.
    Community
    Landfill
    Co.,
    PCB 97-193, slip
    op. at 3
    (Aug.
    6,
    1998). In
    addition, the Board (pursuant
    to
    the authority granted under
    35
    Iii. Adm. Code
    101.100(b)), then enlarged that definition
    to
    also include the definition of
    an affirmative
    defense
    found in the Illinois Code of Civil Procedure, specifically:
    (d)
    The facts constituting any affirmative defense, such
    as
    payment,
    release, satisfaction, discharge, license, fraud, duress, estoppel, laches,
    statute of frauds, illegality, that the negligence of a complaining
    party
    contributed in
    whole
    or
    in
    part to the injury of which he
    complains, that
    an instrument or transaction is either void or voidable in
    point of law, or
    cannot
    be
    recovered upon
    by
    reason
    of any
    statute
    or
    by
    reason
    of
    nondelivery,
    want or failure
    of
    consideration in whole or in part, and
    any
    defense
    which by
    other affirmative matter
    seeks to
    avoid the legal effect of
    or defeat the cause
    of action
    set
    forth in the complaint, counterclaim, or
    third-party complaint, in whole or in part, and any ground or
    defense,
    whether
    affirmative or not, which, if
    not
    expressly
    stated
    in the pleading,
    would
    be
    likely
    to take
    the opposite party
    by
    surprise, must be plainly set
    forth in the answer or reply. 735 ILCS 5/2-613(d)
    (Emphasis supplied)
    Further, the Board
    has
    held that pleading of defenses should be
    liberally allowed in
    order
    to
    inform the parties
    of
    the
    legal theories
    to be
    presented, prevent
    confusion
    as to
    whether
    a
    defense
    has been timely raised, and avoid taking the
    other party
    by surprise.
    People
    v. Geon Company,
    PCB
    No.
    97-62 (October 2,
    1997);
    Citing, People v. Midwest
    Grain
    Products,
    PCB
    No.
    97-179 (August 21, 1997).
    It is,
    therefore, clear that any set of facts or any provisions
    of law, including those
    which constitute
    defenses specifically set
    forth in 5/2-613(d) above, that
    could or
    might
    avoid or
    defeat
    a
    cause of
    action,
    whether
    in whole or
    in part,
    or that could or might
    take the
    opposing
    party
    by
    surprise, must
    be
    pled or they are waived. Thus, at
    the
    pleading stage
    of
    a
    proceeding,
    as
    here, a
    respondent must
    be
    accorded all appropriate
    opportunity
    to
    present any set of facts
    or any provisions of law that presently
    are an
    2

    affirmative
    defense,
    or
    which may,
    through
    discovery
    and preparation
    for hearing,
    ripen
    into an
    affirmative
    defense.
    In
    People
    v. Stein Steel,
    supra,
    the
    Board
    further
    held that
    a
    motion
    to
    strike
    an
    affirmative
    defense
    admits
    all
    well-pleaded
    facts
    constituting
    the
    defense,
    and
    attacks
    only the
    legal
    sufficiency
    of those
    facts. The
    Board found
    that
    “where
    the
    well-pleaded
    facts
    of an affirmative
    defense
    raise the
    possibility
    that
    the
    party
    asserting
    them
    will
    prevail,
    the
    defense
    should
    not
    be
    stricken.”
    Citing,
    International
    Insurance
    Co.
    v.
    Sargent
    and
    Lundy,
    242 Ill.
    App.
    3d 614,
    630-31, 609
    N.E.2d
    842,
    853-54
    (1st Dist.
    1993),
    Citing,
    Raprager
    v.
    Allstate
    Insurance
    Co.,
    183
    Ill.
    App.
    3d
    847,
    854, 539
    N.E.2d
    787,
    791
    (2nd
    Dist.
    1989)
    (Emphasis
    supplied).
    And
    there is
    no
    requirement
    to
    raise
    any new
    facts in
    an
    affirmative
    defense,
    as the
    Board
    has
    held that
    a respondent
    may rely
    on
    the
    facts
    pled
    by a
    complainant.
    See
    International
    Union,
    etc., et al.
    v Caterpillar
    Inc., PCB
    No.
    94-20
    (holding that
    a
    fully
    developed
    record
    may
    show
    that a
    violation
    of the Act
    did not
    occur
    or
    that the relief
    requested
    by
    the
    complainant
    is
    improper).
    For the
    reasons
    set forth
    below, application
    of
    the foregoing
    principles
    to the
    affirmative
    defenses
    alleged
    by
    Respondent
    finds that
    the Complainants’
    motion
    to
    strike
    should be
    denied.
    Argument
    Affirmative
    Defense
    No. I
    - No
    Assumption
    of
    Texaco Inc.’s
    Liabilities
    Complainants
    did
    not move
    to
    strike
    this
    defense;
    therefore,
    no
    response
    is
    made.
    3

    Affirmative Defense
    No.
    II
    - Discharge in Bankruptcy
    Complainants allege that
    Respondent is responsible for the liabilities of Texaco
    Inc. in this
    matter, which Respondent has denied. In this affirmative defense,
    Respondent
    has asserted that, irrespective of this responsibility issue, the claims alleged
    in the Complaint were discharged in
    the Texaco Inc. bankruptcy (“Texaco
    Bankruptcy”)
    that took place in the late 1980s. Thus, Complainants cannot have any claims against
    Texaco
    Inc. for
    which they can allege
    Respondent
    could
    be responsible.
    In their motion to strike this defense, Complainants, in summary,
    argue that
    their
    claims
    against
    Texaco Inc. were not discharged
    by
    the Texaco bankruptcy
    because
    the
    Complainants did
    not
    know,
    and could not
    have
    known, of their claims at
    the
    time of
    the Texaco
    Bankruptcy. Complainants reason, therefore, that
    they
    could not have filed,
    and were not required to
    file,
    a
    claim
    in the Texaco bankruptcy to
    preserve their claims.
    Complainants do not dispute
    the
    following:
    1. On April 12, 1987, Texaco Inc. instituted
    a
    proceeding under
    Chapter 11
    of the United
    States
    Bankruptcy Code, entitled In re Texaco
    Inc.,
    et
    at., 87
    B 20142, United States
    Bankruptcy for the Southern District of New York
    (hereinafter the
    “Texaco Bankruptcy”).
    2. On January 26, 1988, the Court
    in the Texaco Bankruptcy entered an
    order that fixed the date
    of March 15, 1988 as the last date
    for creditors to
    file proofs of
    claim.
    3.
    On
    March 23, 1988, the Court in the Texaco Bankruptcy entered
    an
    order
    approving confirmation of the plan of reorganization
    (“Plan”) of
    Texaco Inc. (Exhibit
    1)
    4.
    The Plan provides that any claims not filed and approved by
    the Court
    in the Texaco
    Bankruptcy are discharged and forever barred.
    5.
    No
    claims arising
    out
    or relating to
    any
    acts, omissions
    or liabilities
    of
    Texaco Inc.
    arising
    out
    of or relating to the Property,
    including
    but
    not
    limited
    to
    the
    claims
    alleged
    in the Complaint, were filed in the
    Texaco
    4

    Bankruptcy
    by
    Complainants
    or
    any other
    person or
    entity.
    While
    Complainants
    rely on
    several
    cases
    in support
    of
    their position
    that deal
    with
    other bankruptcies,
    they do
    not refer
    to
    or discuss
    any
    cases
    that
    have been
    decided
    on this
    very
    issue
    by
    the bankruptcy
    court
    as a
    part of the
    Texaco
    Bankruptcy.
    These
    Texaco Bankruptcy
    decisions
    demonstrate
    that
    Complainants’
    claims
    have
    been
    discharged.
    Texaco
    Inc.
    v.
    Fred Saunders,
    et
    al. (In
    re
    Texaco
    Inc.), 182
    B.R. 937
    (1995) arose
    out
    of
    an
    action
    brought
    by
    Texaco Inc.
    to
    reopen the
    Texaco
    Bankruptcy
    for
    the
    purpose
    of
    enforcing
    the discharge
    provisions
    of the
    order
    confirming
    the plan
    of
    reorganization
    (“Order
    of Confirmation”)
    against
    Mr.
    Saunders
    and
    approximately
    20
    other
    persons (collectively
    “Saunders”).
    Saunders
    was
    pursuing
    various
    environmental
    claims
    against
    Texaco
    Inc. in
    a state
    court
    proceeding
    in Louisiana
    in
    1995.
    None of
    the
    Saunders
    had
    filed claims
    in the Texaco
    Bankruptcy.
    The
    Saunders
    state court
    action
    was
    initiated well
    after
    the conclusion
    of
    the
    Texaco
    Bankruptcy
    and
    sought
    damages
    from
    Texaco Inc.
    for
    remediation
    of the
    environmental
    impacts to
    the
    Saunders
    real
    property.
    Saunders
    alleged
    the
    impacts
    occurred
    as
    the
    result
    of the
    migration
    of contaminants
    generated
    by Texaco
    Inc.
    on
    adjoining
    property
    (that had
    previously
    been operated
    by
    Texaco
    Inc.)
    to
    the
    Saunders
    property.
    All
    of
    Texaco
    Inc.’s actions
    at
    the
    adjoining
    property
    were
    concluded
    years
    before
    the
    Texaco
    Bankruptcy
    was initiated.
    Texaco
    Inc.
    filed
    an
    affirmative
    defense
    in
    the
    state
    court
    action
    alleging the
    Saunders
    claims
    were discharged
    in
    the
    Texaco
    Bankruptcy.
    Saunders
    moved
    to strike
    the
    defense,
    but the
    state
    court judge
    denied
    their
    motion,
    stating:
    5

    Well,
    I
    do
    [have
    jurisdiction to decide
    the
    motion
    to
    strike],
    I don’t
    have
    any
    doubt
    about
    it,
    but I’m not [going
    to]
    knock out
    something
    that is
    not
    [going
    to]
    impede my law
    suit, it’s not [going
    to] stop
    anything
    at
    this
    basis. I
    understand what you’re
    saying.
    I believe
    you.
    And believe
    me I
    understand
    what you’re saying.
    I
    don’t
    think
    I can strike a
    defense
    like
    that. Saunders,
    182 B.R.
    at
    943 (1995)
    At the same time
    Texaco Inc. also filed
    a motion
    in the bankruptcy
    court in New
    York (initiating this
    1995
    proceeding)
    to
    reopen the
    Texaco
    Bankruptcy
    to
    enforce
    against Saunders
    the injunction
    contained
    in the Order of
    Confirmation
    that prohibits
    any
    person from
    pursuing a
    claim
    that
    has been
    discharged.
    In response
    Saunders
    alleged
    (as
    do
    Complainants
    here)
    that their claims
    had not manifested
    themselves
    and
    could
    not have been known
    by the respondents
    at the
    time
    of the
    Texaco
    Bankruptcy.
    The bankruptcy
    court denied
    these
    defenses
    and
    enforced
    the discharge
    against
    Saunders.
    In reaching its decision,
    the bankruptcy
    court
    first restated
    the
    law
    that the
    confirmation of
    a
    plan under
    Chapter
    11 discharges
    the debtor
    from any debt
    that
    arose
    prior
    to
    the
    date
    of such confirmation,
    whether or not
    a
    proof
    of claim
    on that
    debt
    is
    filed or
    allowed,
    citing
    11
    U.S.C.
    1141(d)(1).
    Thus,
    all
    debts
    are
    discharged
    and the only
    right that
    a
    holder
    of a
    discharged
    debt may
    have is
    through
    the
    proof-of-claim
    process.
    The
    bankruptcy
    court
    next restated
    the law
    regarding the effect
    of the
    discharge as
    being a
    permanent injunction
    against
    the commencement
    or continuation
    of any action
    to
    recover discharged
    claims,
    citing 11 U.S.C.
    524(a)(2).
    The
    bankruptcy
    court then
    found
    that the Order
    of Confirmation
    of the
    Texaco Inc.
    plan of
    reorganization
    mirrors
    these
    provisions
    and is binding
    on all
    persons
    holding
    claims
    against
    Texaco
    Inc.
    The
    bankruptcy
    court
    next reviewed
    the meaning
    of
    “debt”,
    in the
    context of
    6

    what
    the
    Order of
    Confirmation
    discharges.
    The court
    found
    that “debt”
    means
    “liability
    on
    a
    claim”,
    citing
    11
    U.S.C.
    101(12).
    The court
    then
    found
    that
    “claim”
    means:
    (A) right
    to payment,
    whether
    or not such
    right
    is reduced
    to judgment,
    liquidated,
    unliquidated,
    fixed,
    contingent,
    matured,
    unmatured,
    disputed,
    undisputed,
    legal, equitable,
    secured
    or
    unsecured;
    or
    (B) right
    to
    an
    equitable
    remedy
    for
    breach of
    performance
    if
    such breach
    gives
    rise to
    a
    right
    to
    payment,
    whether or
    not
    such right
    to an
    equitable
    remedy
    is reduced
    to
    judgment,
    fixed,
    contingent,
    matured,
    unmatured,
    disputed,
    undisputed,
    secured
    or unsecured.
    The court
    reviewed
    the decisions
    interpreting
    the nature
    and
    breath
    of
    “claim”,
    quoting
    from
    In re Chateaugay
    Corp.,
    944
    F.2d 997
    (2nd
    Cir. 1991),
    as follows:
    Congress
    unquestionably
    expected
    this
    definition
    to
    have
    wide
    scope.
    ‘By
    this
    broadest
    possible
    definition
    .... the bill
    contemplates
    that
    all
    legal
    obligations
    of
    the
    debtor,
    no matter
    how remote
    or contingent,
    will
    be
    able
    to be
    dealt
    with
    in the
    bankruptcy
    case.’
    H.R.Rep
    No.
    595,95th
    Cong.,
    2d
    Sess.
    309
    (1978), reprinted
    in
    1978 U.S.Code
    Cong.
    &
    Admin.
    News
    5787,
    5963,
    6266.
    See also
    Tohnson
    v. Home
    State
    Bank, 501
    U.S.
    78,
    83,
    111
    S.Ct.
    2150,
    2154, 115
    L.Ed2d
    66
    (1991);
    Pennsylvania
    Dep’t
    of
    Public Welfare
    v.
    Davenport,
    495
    U.S.
    552,
    557,
    1105.
    Ct. 2126,
    2130,
    109
    L.Ed.2d
    588
    (1990).
    The bankruptcy
    court
    then
    applied
    this law
    to the Saunders
    claims and
    determined
    that all
    of Texaco
    Inc.’s operations
    at
    the adjoining
    property
    ceased
    years
    before
    the
    Texaco
    Bankruptcy.
    As
    a
    result
    the
    court
    found
    that
    “All
    of the
    physical
    events
    required
    to
    establish
    causation
    and
    damage for
    such
    claims occurred
    prior
    to
    the
    confirmation.”
    Texaco
    v Saunders,
    182 B.R.
    at
    951 The
    court thus
    ruled
    that
    all
    claims
    resulting
    from
    Texaco
    Inc.’s operations
    at
    the
    adjoining
    property
    arose
    prior
    to
    the
    Texaco
    Bankruptcy
    and that
    the
    Saunders
    claims
    were
    discharged
    in
    the
    Texaco
    Bankruptcy.
    The
    same
    is true
    of the
    claims
    of Complainants
    here. The
    Complaint
    alleges
    that
    Texaco
    Inc.
    did not
    own
    or operate
    the
    USTs or
    the Property
    after
    1977,
    well before
    the
    7

    Texaco
    Bankruptcy. Thus, any action of Texaco Inc. that could
    have given rise to the
    claims
    alleged
    by
    Complainants were completed prior
    to
    the Texaco
    Bankruptcy. These
    claims were, therefore,
    debts
    of Texaco Inc.
    at
    the
    time
    of the Texaco
    Bankruptcy and
    were
    discharged
    by
    the Order of Confirmation.
    The bankruptcy court then examined and rejected the Saunders
    arguments
    that
    their
    claims were
    “unmanifested”
    and
    “unknown” and should not
    fall under the
    meaning
    of
    “claim”.
    With respect
    to
    “unmanifested”, Saunders
    argued that the
    contamination caused by
    Texaco
    Inc.
    was not visible
    at
    the surface
    of their land at the
    time of the Texaco
    Bankruptcy and, therefore, had not manifested
    itself. While the
    bankruptcy
    court agreed with Saunders on that particular fact,
    the court
    found that
    fact
    was not controlling
    of the issue of discharge. The controlling
    issue
    is,
    rather, whether
    the
    contamination was capable of being detected
    prior
    to
    confirmation
    of the plan. The
    court found that
    it certainly was capable of detection by reasonable
    investigation
    of the
    property prior to confirmation
    of the plan. As such the
    contamination
    would fall within
    the meaning of
    “claim”,
    as
    it was fully matured and
    uncontingent.
    In the instant
    matter before the Board, the claims of
    Complainants
    were easily
    capable of
    detection
    by
    long-standing
    methods
    of investigation of
    real property for the
    presence
    of the USTs and releases
    from the USTs. Like the
    Saunders claims,
    while any
    contamination
    may
    not
    have been not visible at the surface
    of the Property,
    any releases
    that
    existed in 1987 were
    certainly capable of detection
    at
    that
    time. Thus,
    Complainants’
    claims were discharged.
    The
    Saunders respondents
    also argued that they had no
    knowledge of the
    existence
    of
    their claims at the
    time
    of the Order of Confirmation.
    The bankruptcy court
    8

    assumed,
    for the
    purpose of
    its
    ruling, that
    the Saunders respondents’ assertions were
    true.
    Nevertheless, the bankruptcy
    court ruled that these claims were within the
    definition of
    a
    “claim”.
    Citing again
    to
    In Re
    Chateaugay, supra, the court found that
    response
    costs
    for pre-petition
    releases are within the definition of “claim”,
    regardless
    of when
    such costs are
    incurred.
    In the instant
    matter, there is no question that any releases that occurred
    under
    Texaco’s operation of the Property were prior
    to the Texaco Bankruptcy. Therefore, any
    response costs, no matter when incurred, including those which Complainants allege
    were recently incurred, are “claims” and have been discharged. Thus, the fact that
    these Complainants did own the Property
    at
    the time of
    the
    Texaco Bankruptcy, and,
    therefore, could not have filed
    a
    claim,
    does
    not change the rule
    that
    the
    debt
    for
    which
    they
    now
    seek
    recompense was discharged,
    and
    no
    one can now bring a
    claim for
    it.
    The
    decision of the bankruptcy court in Texaco v.
    Saunders
    is the law of the
    case
    in the
    Texaco Bankruptcy. As Complainants’ motion
    to
    strike this defense involves the
    Texaco
    Bankruptcy, Texaco v. Saunders is also the law of this
    case
    in determining the
    instant
    motion. For this reason, Complainants’
    reliance in their motion on decisions
    that
    Complainants argue
    would lead
    to a
    different result are simply not controlling
    here.
    For all of the foregoing reasons
    Respondent
    submits that Complainants’ motion
    to
    dismiss
    Affirmative Defense
    No.
    III should
    be
    denied.
    Affirmative Defense
    No.
    III
    — No
    Jurisdiction Under the
    Act
    Complainants’ motion
    to
    strike Affirmative Defense
    No.
    III should be denied
    because
    the
    provisions
    of the Act upon
    which
    the Complaint relies
    were enacted
    after
    9

    Texaco
    last owned or
    operated the USTs or the Property and these
    provisions cannot be
    retroactively
    applied.
    The Complaint,
    at
    paragraph
    4, alleges that Respondent is responsible
    for any
    liability
    of Texaco
    Inc.
    The Complaint,
    at
    paragraphs
    6 - 9,
    then alleges
    that Texaco Inc.
    owned and/or operated the Property and USTs on the Property from 1959
    through 1977
    and that releases occurred from
    the USTs. In Count I, at paragraphs
    28 - 34, the
    Complaint
    alleges that, as a
    result
    of these alleged releases, Texaco
    Inc. violated the
    current provisions of Section
    21(a)
    of the Act,
    which provides that
    “No
    person shall: (a)
    Cause
    or allow the open dumping of any waste”. 415 ILCS
    5/21(a) Complainants
    alleges that “waste” is defined
    as
    in Section
    5/3.535
    of the
    current provisions
    of the Act
    to
    include the alleged releases from the USTs. 415 ILCS
    5/3.535
    In Count II, at paragraphs 35 - 41,
    the Complaint
    similarly
    alleges that Texaco
    Inc. violated the
    current provisions of Section 21(e) of the Act which
    provides that
    “No
    person shall: (e)
    Dispose, treat, store or abandon any waste, or transport
    any waste into
    this State
    for disposal,
    treatment, storage or abandonment, except at a site
    or facility
    which meets the
    requirements of this Act and of regulations
    and
    standards
    thereunder”.
    415
    ILCS 5/21(a)
    The Complaint again relies on the current definition
    of “waste” as
    provided
    in Section
    5/3.535
    of the Act. 415 ILCS
    5/3.535
    Respondent’s affirmative
    defense alleges
    that
    (i) the Complaint
    alleges
    and
    relies
    on
    the
    current versions of various sections of the Act, (ii) these current
    versions
    were
    not
    in effect during 1977 or at any time prior to
    1977, (iii)
    these
    current versions are not
    applicable to
    any time when Texaco owned or operated the USTs
    or the Property, and
    (iv) these
    current versions may not be
    retroactively
    applied. As
    such, the
    defense
    10

    alleges
    that the Board
    is without
    jurisdiction
    to enforce
    these
    current versions
    against
    Respondent
    in this matter.
    Complainants
    respond
    by
    arguing
    that the
    Act
    (which
    became
    effective
    in
    1970)
    and all subsequent
    amendments
    to the
    Act,
    including
    those
    to
    Sections
    21(a) and
    (e),
    may
    be
    applied
    retroactively.
    Complainants,
    consequently,
    argue
    that the
    releases
    alleged,
    although
    admittedly
    alleged
    to
    have occurred
    not
    later than
    1977 are,
    therefore,
    subject
    to
    these
    current
    provisions
    of the
    Act. Complainants’
    motion
    is
    both
    misleading
    and plainly
    wrong.
    When
    the Act
    became
    effective in
    1970, section
    21(a),
    then
    being 1971
    Ill. Rev.
    Stat.,
    Ch.
    111½,Sect.
    1021(a),
    provided
    only as follows:
    No person
    shall:
    (a)
    Cause
    or
    allow
    the
    open
    dumping
    of garbage;
    There
    is no
    reference
    to “waste”
    in
    1021
    (a),
    nor
    did
    the
    Act in
    1970 even
    contain
    a
    definition
    for
    “waste”.
    “Garbage”
    was
    defined as:
    (e)
    “Garbage”
    is waste
    resulting
    from
    the handling,
    processing,
    preparation,
    cooking,
    and consumption
    of
    food,
    and
    wastes
    from the
    handling,
    processing,
    storage,
    and
    sale of produce.
    1971
    Ill.
    Rev.
    Stat.,
    Ch. 111½,
    Sect. 1003(e).
    As
    the
    definition
    of “garbage”
    obviously
    does
    not
    include
    releases
    of
    petroleum
    from
    USTs,
    it is
    clear that
    Section 21(a),
    in
    1970, did
    not
    relate
    to
    or
    regulate
    the
    releases
    from
    USTs that
    are
    alleged in
    the Complaint.
    The
    same
    conclusion
    is true
    for
    Section
    21(e).
    In 1970
    Section
    21(e) provided:
    No
    person
    shall:
    (e)
    Conduct
    any refuse-collection
    or refuse-disposal
    operations,
    except
    for
    refuse
    generated
    by the operator’s
    own
    activities,
    without
    a
    permit
    granted
    by
    the
    Agency
    upon
    such
    conditions,
    including
    periodic
    reports
    and
    full
    access
    to
    adequate
    records
    and
    the inspection
    of
    facilities,
    as
    may
    be
    necessary
    to assure
    compliance
    with
    this
    Act
    and with
    regulations
    adopted
    thereunder,
    after
    the
    11

    Board
    has
    adopted
    standards
    for
    the location,
    design,
    operation
    and
    maintenance
    of
    such
    facilities;
    1971
    Iii.
    Rev.
    Stat.,
    Ch.
    111½,Sect.
    1021(e)
    There
    is
    no reference
    to
    “waste”
    in
    1021(e),
    nor did
    the
    Act in
    1970
    even
    contain
    a
    definition
    for
    “waste”.
    “Refuse”
    was
    defined
    as:
    (k) “Refuse”
    is any
    garbage
    or other
    discarded
    solid
    materials.
    1971
    Ill. Rev.
    Stat.,
    Ch.
    111½,Sect.
    1003(k)
    As
    the
    definition
    of
    “refuse”
    obviously
    does
    not
    include
    releases
    of petroleum
    from
    USTs,
    it
    is
    clear
    that
    Section
    21(e),
    in 1970,
    did
    not
    relate
    to
    or
    regulate
    the
    releases
    from
    USTs
    that
    are alleged
    in
    the Complaint.
    And
    no
    other
    provision
    of
    the
    1970 version
    of
    Section
    1021,
    which
    is the
    only
    section
    of the
    1970
    Act prohibiting
    land
    pollution,
    related
    to or
    regulated
    the
    releases
    alleged
    from
    the
    USTs.
    See
    1971
    Ill. Rev.
    Stat.,
    Ch.
    111½,Sect.
    1021
    (b)
    — (d) and
    (0.’
    The
    Complaint
    alleges
    that Texaco
    ceased
    operating
    the
    USTs
    and the
    Property
    in
    1977.
    The
    1977
    Illinois
    Revised
    Statutes
    contain
    revisions
    to
    the Act
    passed
    to
    and
    including
    July
    2,
    1977.
    The
    1977
    version
    of the
    Act
    continues,
    at
    1021
    (a),
    to
    regulate
    only
    the
    open
    dumping
    of garbage,
    and,
    at
    1021(e),
    to
    regulate
    only
    the disposal
    of
    refuse.
    1977
    Ill. Rev.
    Stat.,
    Ch.
    111½,
    Sect.
    1021(a)
    and
    (e).
    The
    definition
    of “garbage”,
    at
    Section
    1003(e),
    remained
    the
    same, and
    the
    definition
    of
    “refuse”,
    at Section
    1003(k),
    also
    remained
    the
    same,
    except
    that
    radioactive
    materials
    are
    excepted
    from
    the
    definition.
    Thus,
    in
    1977
    the
    releases
    from
    the
    USTs
    alleged
    in
    the Complaint
    were
    not
    regulated
    by
    the
    Act.
    While
    the
    Act, in
    1970,
    defined
    the
    term
    “contaminant” as
    “any
    solid,
    liquid,
    or
    gaseous
    matter,
    any
    odor,
    or
    any
    form
    of energy,
    from
    whatever
    source”
    (1971
    Ill.
    Rev.
    Stat.,
    Ch.
    111½,
    Sect.
    1003(d)),
    the
    release
    or
    discharge
    of
    a
    contaminant
    is
    regulated
    only
    in
    respect
    to
    air
    and
    water
    pollution,
    not
    land
    pollution.
    See
    1971 Ill.
    Rev.
    Stat.,
    Ch.
    12

    The
    1979
    version
    of
    the Act,
    as contained
    in the
    1979
    Illinois
    Revised
    Statutes,
    makes
    the
    following
    relevant
    changes:
    1.
    Sections
    1021(a)
    and (b)
    are
    combined
    and
    the word
    “refuse”
    is
    substituted
    for
    “garbage”.
    Ch. 111½,
    Section
    1021
    (a);
    2.
    Section
    1021(e)
    became
    Section
    1021(d),
    but
    continued
    to
    regulate
    only
    refuse
    collection
    and
    refuse
    disposal.
    Ch.
    111½,
    Sect.
    1021(d);
    3.
    The
    term “refuse”
    is redefined
    to
    mean
    simply
    “waste”.
    Ch. 111½,
    Sect.
    1003(s);
    and
    4.
    For
    the
    first time
    the
    word
    “waste”
    became
    a defined
    term.
    Ch. 111½,Sect.
    1003
    (ff).
    Whether
    the
    term
    “waste”
    does
    or
    does
    not
    include
    the
    releases
    alleged
    in
    the
    Complaint
    is
    not
    relevant
    to this
    matter,
    as the
    earliest
    that
    any
    amendment
    contained
    in the
    1979
    Illinois
    Revised
    Statutes
    was
    effective
    is July
    1,
    1978,
    which
    is
    after
    the
    date
    that the
    Complaint
    alleges
    Texaco
    Inc. ceased
    operating
    the
    USTs
    or
    the
    Property.
    Therefore,
    a
    plain
    reading
    of
    Section
    21 of
    the Act
    from
    its inception
    in
    1970
    through
    1978
    demonstrates
    that
    the Act
    never
    regulated
    releases
    of
    petroleum
    from
    USTs;
    thus,
    the
    Act cannot
    be
    applicable
    to
    the
    releases
    alleged
    in
    the Complaint
    unless
    it
    were
    to be
    applied
    retroactively,
    which
    Respondent’s
    affirmative
    defense
    alleges
    cannot
    be done.
    The
    decisions
    of
    the Board
    have
    consistently
    confirmed
    Respondent’s
    position.
    In
    Casanave
    v. Amoco
    Oil
    Company,
    PCB No.
    97-84
    (1997),
    the
    Board
    refused
    to
    apply
    Section
    21 of the
    Act
    retroactively.
    There,
    the
    complainant
    brought
    a
    citizen’s
    enforcement
    action
    against
    Amoco
    regarding
    leaking
    USTs
    under
    Sections
    21(a),
    (d)-(f),
    (i)
    and
    (m)
    of the
    1996
    provisions
    of the
    Act. Amoco,
    however,
    had
    ceased
    operating
    the
    USTs
    and
    the
    property
    in
    1952 and,
    therefore,
    moved
    to
    dismiss
    the
    Complaint
    111½,Sect.
    1009
    and
    1012.
    13

    alleging
    the Act cannot
    be
    applied retroactively.
    The Board
    agreed
    with
    Amoco
    and
    held that, in order
    for Amoco
    to
    have
    violated
    the provisions of the
    Act relied
    upon
    by
    Complainants,
    Amoco
    must
    have
    engaged
    in the proscribed
    conduct
    after
    those
    provisions
    became
    effective
    (citing People
    v. Fiorini, 143
    Ill. 2d 318; 574
    N.E. 2d 612).
    The Board stated:
    Because
    the
    complaint
    does not
    allege that Amoco
    owned, operated,
    possessed or
    controlled
    the
    property
    or the underground
    storage
    tanks
    after the
    effective date
    of
    the
    Act
    in 1970
    or after the
    Section
    21
    provisions
    became effective,
    Amoco
    could not
    have allowed contamination
    to
    continue or
    disposed, stored
    or
    abandoned
    any
    waste based
    on the
    facts of
    this case
    after
    the Section
    21 provisions became
    effective.
    See
    Mandel,
    PCB
    92-33, slip
    op. at 5-6.
    Therefore,
    even
    assuming that
    all well-pleaded
    allegations are true,
    none of the
    conduct
    alleged
    in the
    complaint occurred
    after 1970, the
    effective
    date of
    the
    Act, or after
    the
    effective dates
    of
    the
    Section 21
    provisions. Consequently,
    no
    set of facts
    in
    the complaint
    can
    be
    proved that
    would entitle the
    complainant
    to
    relief.
    Hence,
    the
    complaint
    must
    be
    dismissed.
    People ex rel.
    Fahner v.
    Carriage Way
    West, Inc.,
    88
    Ill. 2d
    300,
    430 N.E.2d
    1005,
    1008-09
    (1981).
    Two years
    later
    in Union
    Oil Company
    v.
    Barge-Way
    Oil Company,
    et
    al.,
    PCB
    No.
    98-169
    (1999),
    the Board
    again held that
    Section 21 cannot
    be
    applied
    retroactively.
    There,
    Union
    Oil
    sought
    to enforce
    Section 21(e), as
    it was amended
    in 1979 to
    include
    “waste”,
    against actions
    of Mobil
    Oil
    Company
    that are
    alleged
    to
    have occurred on
    or
    about
    1974.
    Mobil
    moved to
    dismiss
    arguing that,
    in order for
    it
    to be
    liable
    under the
    1979
    amendments
    to
    Section 21, those
    amendments
    would
    have
    to
    be
    applied
    retroactively,
    and that they
    simply
    cannot be
    so
    applied.
    The
    Board
    agreed
    with
    Mobil
    and
    dismissed
    the
    claims,
    stating:
    Under
    Illinois
    law,
    a
    statutory
    amendment
    will be
    construed as
    applying
    prospectively
    absent
    express
    language to
    the contrary.
    People
    v. Fiorni,
    143 Ill.
    2d 318, 333,
    574 N.E.2d
    612
    (1991).
    As stated in
    Fiorini,
    “an
    exception to
    the rule of
    prospectivity
    arises where
    the
    legislature
    intended
    that the
    amendment apply
    retroactively
    and where
    the
    amendment
    14

    applies only
    to
    changes
    in procedure
    or
    remedies,
    rather
    than
    substantive
    rights,”
    (Emphasis
    added.)
    Fiorini,
    143
    Ill. 2D at
    333
    (citing
    Matier
    v.
    Chicago
    Board
    of
    Education,
    [10] 82111.
    2d
    373, 390,
    415
    N.E. 2d 1034
    (1980)).
    Thus,
    in
    order
    for
    retroactive
    application
    to
    be
    permissible,
    there
    must
    be
    both
    express
    statutory
    language
    allowing
    for such
    application
    and
    the law
    which
    is sought
    to be retroactively
    applied
    is not substantive.
    Id.
    Illinois
    courts
    have defined
    substantive
    law
    as that
    “which establishes
    rights
    and
    duties
    that may
    be
    redressed
    through
    the
    rules of
    procedure.”
    Fiorini,
    143
    Ill.
    2d at 333.
    The
    Board’s
    holdings in
    Casanave
    and
    Union
    Oil
    are
    controlling
    here.
    The
    complaint
    alleges
    that
    Texaco
    owned
    and/or
    operated
    the USTs
    and
    the
    Property
    between
    1959
    and 1977.
    The
    Complaint
    does not
    allege that
    Texaco
    owned
    or operated
    the
    USTs
    or the Property
    at any
    time
    after 1977.
    The
    provisions
    of
    Section
    21, upon
    which
    Complainants
    rely, were
    not
    amended
    to
    include
    a
    definition
    of
    the
    term
    “waste”
    that might
    apply
    to the alleged
    releases
    from
    the
    USTs
    until
    after
    1977.
    Thus, the
    only
    manner
    in which
    Texaco
    could
    be
    liable
    under
    the 1979
    amendments,
    or
    any post-1979
    amendments,
    to
    Section
    21 would
    be to
    apply
    the
    provisions
    of amended
    Section
    21
    retroactively,
    which
    the
    Board
    has
    clearly determined
    cannot be
    done.
    The
    amendments
    to
    Section
    21
    do
    not
    state
    they are
    to be
    applied
    retroactively.
    And,
    in
    any
    event,
    the prior
    decisions
    of the
    Board
    have
    determined
    that
    the
    amendments
    are
    substantive
    and,
    therefore,
    cannot
    be
    applied
    retroactively.
    See
    also Vogue
    Tyre
    &
    Rubber
    Company
    v.
    Illinois EPA,
    PCB
    96-10 (2004).
    Complainants
    rely
    on Grand
    Pier Center
    LLC
    v. American
    International
    Specialty
    Lines
    Insurance
    Company,
    PCB No. 05-157
    (2005),
    as
    finding
    that
    the Act
    can
    be
    applied
    retroactively.
    This reliance
    is
    misplaced.
    While the
    decision
    in Grand
    Pier
    relies
    on
    the opinion
    of the
    appellate
    court
    in
    State
    Oil
    Company
    v.
    State
    of Illinois,
    822
    15

    N.E.2d 876
    (2004),
    the
    decision
    is plainly
    wrong
    and in apposite
    to
    all existing
    decisions
    of the
    Board.
    Grand
    Pier
    did
    not
    overrule
    Casanave,
    Union
    Oil or Vogue,
    nor
    did
    it
    even
    refer
    to
    or
    distinguish
    these
    decisions;
    thus,
    Casanave,
    Union
    Oil
    and Vogue
    remain
    the
    law
    of
    the
    Board
    regarding
    the issue
    of
    retroactivity.
    Further,
    as
    the Board
    held in Casanave
    and
    Union
    Oil, there
    is
    a
    two-prong
    test that
    must
    be met
    before
    a
    statute
    may be
    applied
    retroactively:
    the statute
    must
    specifically
    provide
    that it is
    to be
    applied
    retroactively,
    and
    the
    statute
    must
    be
    of
    a procedural
    nature
    and not
    affect
    substantive
    rights.
    In
    Grand
    Pier, the
    two prong
    test
    was
    misapplied
    to
    extend
    retroactivity
    to
    Section
    21(e) of
    the Act. Section
    21(e)
    clearly
    affects a party’s
    substantive
    rights
    as it regulates
    a
    party’s
    conduct.
    Under
    People
    v.
    Fiorini,
    supra,
    which
    is an
    Illinois
    Supreme
    Court
    decision,
    a substantive
    statute cannot
    be
    applied
    retroactively.
    Thus,
    Fiorini
    is
    controlling
    here and
    the holding
    in Grand
    Pier is
    not
    controlling
    here.
    For
    all of the
    foregoing
    reasons
    Respondent
    submits
    that
    Complainants’
    motion
    to
    dismiss
    Affirmative
    Defense
    No.
    III should
    be denied.
    Affirmative
    Defense
    No.
    IV
    — No
    Jurisdiction
    to
    Award
    Cost Recovery
    Complainants
    move
    to
    strike
    this
    defense
    arguing
    that
    the
    Board
    has
    always
    ruled
    that it
    has the
    authority
    to
    award
    cleanup
    costs.
    Respondent
    is well
    aware of
    the
    Board’s
    decisions
    on
    this issue.
    Although
    the
    Board
    has
    determined
    that
    it has
    the
    authority
    to
    award cost
    recovery,
    it is undisputed
    that
    the Act,
    at
    415
    ILCS
    5/33
    (b),
    does
    not specifically
    grant
    this authority
    to the
    Board.
    The Board
    has,
    therefore,
    inferred
    that
    it has
    the
    authority
    to
    award
    cost recovery
    via
    the
    language
    in
    5/33(a)
    that
    allows
    the
    Board
    to “enter
    such final
    order,
    or make
    such
    final
    determination,
    as
    it shall
    16

    deem
    appropriate
    under
    the
    circumstances.”
    415
    ILCS
    5/33
    (a)
    But
    this
    position
    is not
    undisputed.
    In
    Casanave,
    supra,
    Board
    Member
    R.
    C.
    Flemal, in a
    special
    concurring
    opinion,
    opined
    that
    the
    Board
    does
    not
    have
    the
    power
    to
    hear
    private
    cost
    recovery actions.
    And
    in
    NBD
    Bank
    v. Krueger
    Ringier,
    Inc.,
    292
    Ill.
    App.
    3d
    691
    (1997),
    the
    appellate
    court
    held
    that
    a private
    right
    of
    action
    cost
    recovery
    does
    not
    exist
    under
    the Act
    for the
    circumstances
    of
    the
    instant
    case,
    stating:
    The
    Illinois
    Environmental
    Protection
    Act
    and
    companion
    regulations
    were
    not
    designed
    to
    protect
    the
    purchasers of
    real
    estate
    who
    discover
    after
    the
    conveyance
    that
    remedial action
    is
    necessary
    to remove
    contaminants
    from
    the
    property,
    nor
    was
    the
    Act designed to
    protect
    against economic
    losses
    resulting
    from
    the
    obligation
    to
    remove
    contaminants.
    Given
    the
    foregoing,
    Respondent
    respectfully
    requests
    that
    the Board
    revisit
    and
    reconsider
    its prior
    determinations
    allowing
    cost
    recovery.
    This
    request
    is
    especially
    relevant in actions
    such
    as
    this
    matter,
    where
    any
    reasonable
    due
    diligence
    by
    Complainants
    prior
    to
    purchasing
    the
    property
    would
    have
    disclosed
    the
    releases
    alleged
    and
    Complainants
    could
    have
    avoided
    incurring
    the
    costs
    which
    they
    now
    request
    the
    Board
    award
    to
    them.
    For
    all
    of the
    foregoing
    reasons
    Respondent
    submits
    that
    Complainants’
    motion
    to
    dismiss
    Affirmative
    Defense No.
    IV
    should
    be
    denied.
    Affirmative
    Defense No.
    V
    - Incurred
    Risk
    Affirmative
    Defense No.
    VI
    - Assumption
    of
    Risk
    Affirmative
    Defense
    No.
    VII -
    Avoidable
    Consequence
    These
    three
    defenses
    allege
    that
    the
    Complaint does
    not
    allege
    that
    Complainants
    performed
    any
    due
    diligence,
    which
    would
    surely
    have
    disclosed
    the
    existence
    of
    the
    USTs
    and
    the
    releases
    alleged.
    Given
    the
    foregoing,
    the
    defenses
    allege
    that
    17

    Complainants
    either
    incurred,
    assumed
    or could
    have
    avoided
    the
    risk
    of (a)
    the
    existence
    of
    the
    USTs
    and
    the
    alleged
    releases
    being
    on
    the Property,
    and
    (b)
    the
    remediation costs,
    which
    they
    now
    ask
    the
    Board
    to
    award
    them
    from
    Respondent.
    Complainants
    brush
    all three
    of
    these defenses
    aside
    stating
    “Respondent
    has
    articulated
    no
    legal
    theory
    by
    which
    a
    third
    party’s
    investigation
    (or lack
    of
    investigation)
    prior
    to entering
    into a
    contract
    for
    the purchase
    of property
    could
    possibly
    relieve
    Respondent
    of
    responsibility
    for violations
    of
    Sections
    21(a)
    or
    (e) .
    .
    Motion,
    at
    p.
    11.
    Complainants
    are
    not
    correct.
    Without
    the
    benefit
    of discovery
    it
    is not
    yet
    known
    what
    the
    contract
    documents
    between
    Complainants
    and
    their
    seller
    provided
    in
    respect
    to
    the
    environmental
    condition
    of
    the
    Property.
    Customarily,
    however,
    as
    a part
    of a
    buyer’s
    due
    diligence
    in
    a
    commercial
    real
    estate
    transaction,
    the buyer
    provides
    in the
    contract
    documents
    for
    a
    right
    to
    perform
    a Phase
    I and,
    if necessary,
    a
    Phase
    II investigation
    of the
    real
    estate
    to
    determine
    the environmental
    risks
    involved
    in
    acquiring
    the
    real
    estate.
    The
    allegations
    of the
    Complaint
    demonstrate
    that
    Complainants
    are
    sophisticated
    business
    enterprises
    and
    are,
    assumedly,
    represented
    by professional
    advisors.
    Thus,
    Complainants
    should
    have
    known
    what
    the
    environmental
    risks
    were
    in acquiring
    the
    Property
    prior
    to
    closing
    on it. From
    the
    allegations
    of
    the Complaint,
    however,
    it appears
    Complainants
    did not
    know,
    as
    they
    allege
    the
    USTs
    and
    the releases
    were
    first
    “detected”
    in
    2006
    after
    a
    2005 closing.
    Complaint,
    para.
    13-24.
    The
    post-closing
    discovery
    of USTs
    and
    related
    releases
    by
    a buyer
    of
    commercial
    real
    estate
    has
    been
    found
    by the
    Illinois
    appellate
    court
    to
    be
    simply
    the
    “disappointed
    commercial
    expectations”
    of
    the
    buyer.
    NBD
    Bank
    v. Krueger
    Ringier
    18

    inc,
    supra,
    at
    p.
    696. And the NBD Bank court held that the Act
    was not intended
    to
    be
    used by such a disappointed buyer
    to
    recover the
    costs
    of removal of
    contaminants.
    language
    quoted
    from NBD Bank,
    at
    Response,
    p.
    17.
    In the instant
    case
    these three affirmative defenses raise
    exactly
    that issue.
    Application of NBD Bank
    to the instant case
    finds that Complainants should
    not
    be
    allowed to use
    the Act
    to
    recover remediation
    costs
    that should
    have
    been resolved
    with
    their seller in their acquisition of the
    Property.
    For
    all
    of
    the foregoing reasons Respondent submits
    that Complainants’
    motion
    to dismiss
    Affirmative
    Defense Nos.
    V-Vu
    should be
    denied.
    Affirmative Defense No. VIII
    - Causation
    Complainants argue that this
    defense cannot
    be a
    defense because
    it presents no
    new facts and
    is merely
    a
    denial. However, an
    affirmative defense
    is not required
    to
    plead
    new facts, and any set of
    facts or law which could defeat a
    claim or take the
    opposing party by
    surprise must be pled.
    S
    Response,
    pp.
    1-3.
    As this defense alleges,
    releases
    may have occurred as a
    result of the actions of third parties
    operating
    the USTs
    after Texaco
    operated them
    by
    these
    third parties abandoning the
    USTs in place or
    removing
    them. Discovery
    will
    be
    taken on this issue and may
    support this
    defense.
    As
    this
    could be a
    defense to the claim or could take
    Complainants by surprise,
    at this early
    stage
    of this
    proceeding the defense
    should not
    be
    stricken.
    For
    all of the foregoing reasons
    Respondent submits that
    Complainants’ motion
    to
    dismiss
    Affirmative
    Defense No.
    VIII should
    be
    denied.
    Affirmative
    Defense
    No.
    IX - Laches
    Complainants
    argue
    that
    laches is not applicable here
    because
    they
    have not
    19

    unreasonably delayed
    in bringing this action; however, Complainants
    misperceive this
    issue. Laches requires two elements:
    unreasonable delay in bringing a
    claim and
    prejudice
    to the party against whom the claim is brought. People v. Skokie
    Valley
    Asphalt
    Co., PCB 96-98
    (2004).
    There is no question that the second element
    is met here.
    It has been over
    30
    years since Texaco
    operated the
    Property. Evidence that
    Respondent could use
    to
    defend itself certainly has been lost. Records may
    have
    been
    destroyed
    and witnesses may have died or cannot
    be
    found.
    The first
    element
    has also been met. It
    is not that
    these
    Complainants
    unreasonably
    delayed, as they acquired the Property in the past
    few years. But their
    recent acquisition of the Property
    does
    not wash away the fact that any releases caused
    by
    Texaco
    occurred more than
    30
    years
    ago.
    If the owner of the
    Property at the time
    that
    Texaco operated the USTs
    were
    to
    have brought this action at
    this
    time,
    the delay
    would
    be
    unreasonable
    and
    laches would certainly
    apply.
    That
    delay is not mitigated
    simply
    because Complainants recently acquired the Property.
    Given the time that has
    passed
    since these
    claims
    could
    have been brought, Complainants must be
    held
    to
    the
    same
    standard that the prior owner would
    have been held. A simple sale
    of the
    Property
    from
    a
    person who would have been subject to a laches
    defense to another
    person
    should not
    do
    away with the laches defense.
    For all
    of the foregoing reasons Respondent submits that Complainants’
    motion
    to
    dismiss
    Affirmative
    Defense No.
    IX should
    be
    denied.
    20

    Dated:
    June 26, 2009
    Joseph A. Girardi
    Robert B.
    Christie
    Henderson &
    Lyman
    Attorneys
    for Chevron
    U.S.A. Inc.
    175 W. Jackson
    Boulevard
    Suite 240
    Chicago,
    Illinois
    60604
    (312)
    986-6960
    Respectfully
    submitted,
    Chevron
    U.S.A. Inc.
    21

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    PROOF OF SERVICE
    BY
    MAIL
    I, Sarah
    A. Whitford,
    a
    non-attorney
    on oath, state
    that I served a copy
    of this
    Notice
    and
    Response
    of Chevron U.S.A.
    Inc. to
    Motion
    to
    Strike
    Affirmative
    Defenses
    on the persons
    to
    whom the Notice
    is directed at
    the address
    contained
    in the
    Notice
    by
    depositing
    the same in
    the
    U.S.
    mail
    at
    175
    West Jackson
    Boulevard, Chicago,
    Illinois
    60604 before
    5:00 p.m. on June
    26, 2009.
    Sarah A.
    Whitfor
    Subscribed
    and sworn
    to before
    me this
    26th
    day
    of
    June, 2009.
    STEPHANIE
    A
    DEMAS
    ,4.
    SSNEXPIRESOV2W13
    Notary
    Public

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