iN
THE MATTER
OF:
)
)
PETITION OF
JO’LYN CORPORATION
)
and FALCON WASTE AND RECYCLING)
for an ADJUSTED STANDARD from
)
35
ILL. ADM.
CODE PART 807 or,
)
in the alternative, A FINDING OF
)
INAPPLICABILITY.
)
Dorothy M. Gunn, Clerk
Illinois Pollution Control Board
James R. Thompson Center
100 West Randolph
Street
Suite 11-500
Chicago,
IL 60601
NOTICE
AS 04-02.
(Adjusted Standard
—
Land)
REC~VED
CLERK’S
OFFICE
JAN 312005
STATE OF ILLINOIS
Pollution
Control Board
Bradley P. Halloran, Hearing Officer
Illinois Pollution Control Board
James R. Thompson Center
100 West Randolph Street
Suite
11-500
Chicago, IL
60601
Elizabeth S. Harvey
Swanson, Martin & Bell
One IBM Plaza, Suite 3300
330 North Wabash Avenue
Chicago, IL
60611
PLEASE
TAKE NOTICE
that I
have
today
filed with
the
office of the
Clerk of
the
Pollution
Control Board a MOTION FOR EXTENSION OF TIME, copies of which are herewith served upon you.
BEFORE THE POLLUTION
CONTROL BOARD
OF THE STATE OF ILLINOIS
Respectfully submitted,
John JLKi:
Assistant Counsel
Special Assistant Attorney General
Division of Legal
Counsel
1021 North Grand Avenue, East
P.O. Box 19276
Springfield, Illinois 62794-9276
217/782-5544
217/782-9143
(TDD)
Dated: January 28, 2005
REC~JVED
CLERK’S
OFFICE
JAN
31
2005
iN THE MATTER OF:
)
STATE
OF ILLINOIS
)
Pollution Control Board
PETITION OF
JO’LYN CORPORATION
)
and FALCON WASTE AND RECYCLING)
AS
04-02
for an ADJUSTED
STANDARD from
)
(Adjusted Standard
—
Land)
35
ILL. ADM. CODE PART 807 or,
)
in the alternative, A FINDING OF
)
iNAPPLICABILITY.
)
MOTION
FOR EXTENSION OF TIME TO FILE POST-HEARING RESPONSE BRIEF
NOW COMES the Illinois
Environmental Protection Agency (“Illinois EPA”), by
one of
its
attorneys,
John
J.
Kim,
Assistant
Counsel
and
Special
Assistant
Attorney
General,
and,
pursuant
to
35
Ill.
Adm.
Code
101.500
and
101.522, hereby requests
that
the Illinois
Pollution
Control Board (“Board”) grant the Illinois EPA an extension oftime within which to file its post-
hearing response brief.
In support ofthis motion, the illinois EPA states as follows:
1.
On December 22, 2004, the parties participated in a hearing in this matter.
At the
conclusion
of the
hearing, the
parties
agreed that,
inter alia,
the
Illinois
EPA’s
post-hearing
response
brief
would be filed by no later than January 28, 2005.
2.
Due to
several other matters that have
also fallen due
in
the time period between
the
filing of the Petitioners’
post-hearing brief and the present date, the undersigned counsel for
the Illinois EPA has been unable to complete the post-hearing response brief in a timely fashion.
A
short
extension
to
January
31,
2005,
or
one
business
day,
will
be
sufficient
to
allow
completion and filing ofthe Illinois EPA’s post-hearing response brief.
3.
The
Petitioners
should
not
be
prejudiced
by
this
short
delay,
since
only
one
business day will elapse between the original due date and the extension date.
-
BEFORE THE
POLLUTION CONTROL BOARD
OF THE
STATE
OF ILLINOIS
1
WHEREFORE,
for
the
reasons
stated
above,
the
Illinois
EPA
hereby
respectfully
requests
that
the
Board
grant
the
Illinois
EPA
an
extension of time
to
file
its
post-hearing
response brief to January 31, 2005.
Respectfully submitted,
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY,
•
•
•
A~i~tant
Counsel
Special Assistant Attorney General
Division ofLegal Counsel
1021
North Grand Avenue, East
P.O;Box
19276
Springfield, Illinois 62794-9276
•
•
217/782-5544
217/782-9143
(TDD)
Dated: January 28, 2005
•
•
This
filing submitted on
recycled paper.
2
CERTIFICATE OF SERVICE
I, the undersigned attorney
at law,
hereby certify that
on January 28,
2005,
I served
true
and
correct
copies of a
MOTION FOR
EXTENSION
OF
TIME,
by
placing
true
and
correct
copies
in properly
sealed and addressed
envelopes and by depositing said
sealed envelopes in a
U.S.
mail drop box
located within Springfield,
Illinois,
with
sufficient
First
Class
Mail postage
affixed thereto, upon the following named persons:
Dorothy M. Gunn, Clerk
Illinois Pollution Control Board
James R. Thompson Center
100 West Randolph Street
Suite 11-500
Chicago, IL 60601
Elizabeth
S. Harvey
Swanson, Martin & Bell
One IBM Plaza, Suite 3300
330 North Wabash Avenue
Chicago, IL
60611
Assistant Counsel
Special Assistant Attorney General
Division ofLegal Counsel
1021
North Grand Avenue, East
P.O.
Box 19276
Springfield, Illinois
62794-9276
217/782-5544
217/782-9143 (TDD)
Bradley P. Halloran, Hearing Officer
Illinois Pollution Control Board
James R. Thompson Center
100 West Randolph
Street
Suite
11-500
Chicago, IL
60601
AGENCY,
John J~’Kim
