~S
POLLUTION CONTROL
BOARD
N~vezther28,
1972
:n the Matter :f
)
)
R 72—li
pen !trni:tq Regz.ations
pinicn tf the Beard
(by Mr.
Henss)
The Erxirontental Protection Agency filed its proposal to
rend the C;en Burning Regulations in order to allow the open
burning of landscape waste in snail municipalities outside of
netrcpolitan
areas.
On october 24, 1972 this Board ordered that
the
fina.
draft of the proposal be published in order to allow
the widest public corent.
We now detail the history of this
Regclatio:t
and
cur reasons for amending it.
in
.93 the Congress enacted Clean Air Amendments ordering
the ttited States Ertvironr.ental Protection Agency to establish
~ati:na1 Sient Air Quality Standards.
The Primary Air Quality
Standar: was defined by the Congress as that necessary to protect
the ~b:i:
health, and Congress ordered the States to attain this
Prizary Standard by May 30,
1975.
The Secondary Ambient Air
.uaLit~Standard was defined as that Standard ts’hic~is necessary
protect the public welfare and is to be achieved in a reasonable
tire.
‘Clean Air k~nendr.ents, Sec. 109 and 110)
tr. A;ril
23,
1971 the U.
S. Environmental Protection Agency,
as
directed, did adopt the :;ational Primary and Secondary Ambient Air
:uality Standards.
~atLcna1AmbIent Air Quality Standards were established for six
:f the principle air pollutants:
Particulate matter, sulfur oxide,
hydrtcarbcns, carbon zonoxide, photoche~ticaloxidants and nitrogen
cxides.
n acoptsr~gthe Stancards
the
Annxstrator of the Agency,
Mr.
Wifliar
D. Puckelshaus stated “current scientific knowledge of
the
health
and welfare !nzards of these air pollutants is imperfect.
:t
Lncrease and ircro;’e this knowledge the Environmental Protection
Acenc’ wi:l continue
tt
conduct and suoport relevant research.
At
thr~
sre tine the need f~rincreased knowlodge of the health and
we.fare effects cf air pollution cannot justify failure to take
~ct:tn hasri cn kncwlet-~epresently available.
The Clean Air Act,
as ~rer.-1ed,
recuires pronulgation at this tire of National Standards
f-.r six air p~llutantson the kasis of available data set forth in
~:r ~aiity
criteria docurents.
Thus,
the Adr~inistratoris required
tt
re:ce
~tjr~c.tsas to
the
proper
interpretation
of
the
presently
~vaflehs
‘3ata and
to
establish
::etional
Primary
Standards
which
6—357
—2—
include an adequate margin of safety to
protect
human
health.
Where
the validity of available research data has bean questioned, but not
wholly rofuted, the Administrator has
in
each
case
promulgated
a
National Prinary Standard which includes a margin of safety adequate
to protect the public health from adverse effects suggested by the
available data”.
Federal Register, Volume 36, No. 84, p. 1816.
In establishing the Primary Air Quality Standard Mr. Ruckelshaus
did not take into account any factors other than public health.
The
Clean Air Act as amended did not permit him to do so.
A number of
comments were made questioning the feasibility of implementing the
proposed Standards but no revisions were made on this basis.
The Federal EPA determined that the health related Standard for
particulate matter in the air should be:
75 micrograms per cubic
meter of particulate matter as an average (annual geometric mean)
and
260
micrograms per cubic meter, maximum 24 hour concentration
(not
to
be
exceeded
more
than
once
per
year).
This
is
a
Standard
which,
in
the
opinion
of
the
Administrator
of
the
Environmental
Pro-
tection
Agency, was necessary to protect the public health.
Federal law requires the various States to
submit
plans
for the
attainment
and
maintenance
of
the
Federal
Air
Quality
Standards.
Illinois has done so and is taking steps to
achieve
the
Primary
Standards in 1975 and to achieve the Secondary Standards within a
reasonable period of time.
In 1970 the Illinois Legislature enacted the Environmental
Protection Act.
EPA Section 9(c) states:
“No person shall cause
or allow the open burning of refuse”.
Refuse is defined by the
Legislature as “any garbage or other discarded solid materials”.
Section 3(k)
In
addition
the
Legislature
delegated
certain
authority
to
the
Illinois Pollution Control Board.
The statute specifically gives
the Board authority to prescribe the Ambient Air Quality Efijssion
Standards, and in adopting the regulations to make different pro-
visions as required by circumstances for different contaminant
sources and for different geographical areas.
EPA Section 9,
10
and 27.
The Statewide ban on open burning which was ordered by this Board
on September 2,
1971 was a valid exercise of this authority which had
been delegated by the Legislature to the Board.
The Board is required
to, and did, take into account the existing geographical conditions,
the character of the area involved, zoning classifications, nature of
S
—
388
—3—
existino
air quality,
and
technical feasibility and economic
reasonableness
of measuring or reducing
the particular
type
of
nollution.
In its
September
1971 Opinion
the Board referred
to the evidence
of danger
from leaf burning:
“Dr. George Arnold on hohalS
of
the
‘~‘iadison County Sanitation
and Pollution Committee argued
that leaf
burning creates
a hazard
of fire and of traffic accidents,
contributes
to
the violation of particulate air quality standards,
reduces visi-
bility,
endangers
health,
and destroys valuable organic matter.
(R.
64—67)
Several witnesses discussed from personal experience
the
adverse health effects of
leaf burning,
especially
on persons with
respiratory problems.
(R.
214.32)
An allergy specialist
testified
as
to
the serious health effects of burning
leaves,
especially
those
contaminated with pesticides,
upon people with allergies or respira’-
tory diseases.
(R.
184—91)
.“
The
Board allowed
a grace period until July
1,
1972
for people
without access to
a refuse collection service to make arrangements
to comply with the regulation.
There have been varying degrees of compliance with the ban on
open burning.
Monticello,
a town of 4,100 population,
has purchased
a
leaf ~racuum machine,
a chipping machine and has made arrangements
to mulch leaves onto farm property in order
to reduce
the quantity
ci material going into its landfill.
Monticello considered
purchase
of an
air curtaib destructor which would enable the burning
of
landscape waste but postponed
the purchase because
of
the $8,000—
$10,000
cost.
(Urbana
R.
103—108)
Palestine, population
1,686,
baled
its leaves
from windrows
in
the streets.
The bales were then used by gardeners and
by
farmers.
The cost of this operation,
however,
was about $15,000.
(Springfield
R.
67)
The ban on open burning of landscape waste was
in effect during
the Fall of 1971
for those communities which had
a refuse collection
service hut authorities apparently did not
take action
to enforce
the leaf burning ban during that leaf collecting
or burning season
and
in July 1972
the hnvironmental
Protection Agency filed
a promosal
requesting
a relaxation
of the leaf burning ban
for
the
smaller
communities.
The proposal was to
allow omen burning
of
landscape
waste
in municipalities
having
a population loss
than 1,000 and
outside of major metropolitan areas.
The
Agency included
1.5 counties
within
its definition
of major metropolitan
area.
Our newsletter published August
23,
1972 gave notice that hoorings
on this proposal would be held
at Joliet,
Pock.
island,
Urbana, Soring-
field,
Carbondale
and
Macomb.
Addi tional notices wore given
in
other
newsletters
and
in the newsgamere
cunlisherl
in
the
communities
in-
volved.
6
—
359
—4—
Testirrriv
was received
from State
Legislators,
elected
municipal
officials, municipal erployees,
pollution exeerts
of governmental
agencies, private citizens
and.
representatives
of contracting associ-
ations
and ecology groups,
Those who could not
or desired not
to
appear
at
the hearings did submit written statements detailing
their
views
Evidence
in
the
hearings
centered
around
the
quantity
of
particu-
late
matter
civen
off
by
the
burning
of
leaves,
and
the
problems
in-
volved
in
the
disposal
of
leaves
which
are
not
burned.
The
expert
witnesses
of
the
EPA
testified.
that
if
simultaneously
each
family
in
a
town
of
2,500
nersons
burned
one
nile
of
leaves
the
peak
one
hour
concentration
of
earticulates
at
the
downwind
edge
of
the
town
would
be
264
nic:rocTraxes
per
cubic
meter
of
air
and
if
this
level
of
burning
continued
for
eiqht
hours
the
resulting
24
hour
average
particulate
level
would
cc
93
uicrocrams
per
cubic
meter
of
air.
The
health
related
allowable
24
hour
standard
is
260
micrograms
per
cubic
meter
of
air
and
the
welfare
related
24
hour
standard
is
150
micrograms
ner
cubic
meter
of
air.
The
Agency
assumed
that
there
were
500
families
in
a
town
ci
2.5
snuaro
miles,
that
a
typical
leaf
piie
was
4!
x
4!
x
3’
,
the
duration
of
burn
was
1
hour,
the
estimated
emission
rate
enualled
.
8
lbs.
of
carticulate
per
hour
per
pile
(.1
grams
per
aeconcl)
and
that
wind
smeed
was
8
miles
per
hour.
It
was
estimated.
that
the
eceticulate
background
was
40
micrograms
per
cubic
meter
of
air
in
those
smaller
communities.
The
USA
witnesses
Dr.
John
Roberts,
Division
Manager,
and
Car’:
holvin,
:‘eteorolooist,
testified
that
the
open
burning
of
landscape
waste
in
r:n~cipalities
up
to
2,500
in
~opu1ation
would
not
cause
a
vitIation
of
Federal
Air
Quality
Standards.
They
relied
upon
the
cU~orvations
and
calculations
nublished
by
Dr.
Bruce
Turner,
Chici
ci
Air
Resources,
Field
Research
Office,
United
States
Environmental
Protection
Acency
in
his
‘Workbook
of
Atmosoheric
Dispersion
Estimates”
The
particulate
background
of
40
micrograms
per
cubic
meter
of
air
is
apclicable
only
in
rural
areas
and
in
the
cleaner
smaller
communities
in
the
State
of
Illinois.
Dr.
Roberts
testified
that
particulate
levels
in
the
major
metropolitan
areas
of
the
State
including
Chicago,
Rockford,
Quad
Cities,
Peoria
and
F.
St.
Louis
exceeded
the
Federal
Air
Quality
Standards.
The
EPA
testimony
was
not
based
upon
studies
of
air
quality
in
any Illinois municipality
at
a time when leaves were being collected
and burned
in that community.
Mr. Melvin stated
‘to my knowledge
there have
not been any studies performed within
this State
to
determine
precisely
the
contribution
of
open burning
or burning
of
landscape
waste
to
the
air
cuality--that
is
not
hard data”,
(Maccrab
P.
23)
An
EPA
statement
said:
“For
each
ton
of
landscape
waste
burned
without
the
aid
of
air
pollution
control equipment approximately
6
—
360
—
C—
17
lbs.
of
particulate,
60
lbs.
of
carbon
monoxide,
20
lbs.
of
hydro-
carbons
(as
methane),
and
2
lbs.
of
nitrogen
oxides
are
emitted
to
the
atmosphere.
See:
Compilation
of
Air
Pollutant Emission Factors
(Rev.
1972)
U.
S.
Environmental
Protection
Agency,
Office
of
Air
Programs,
Pub.
No.
AP—42,
pages
2-7,
Of
these
air
contaminants
particulate
matter
is
the
most
serious
in
‘terms
of
its
effect
on
air
quality,
even
thounh
emissions
of
carbon
monoxide
are
three
times
as
great.
This
paradox
can
be
understood
if
one
recognizes
that
safe
levels
of
carbon
monoxide
in
the
ambient
air
are
over
twenty
times
greater
than
the
levels
which
are
considered
acceptable
for
particu—
late
matter.
See:
36
C.F,R,
22384.
November
25,
1971.
Therefore,
the
principle
concern
with
any
relaxation
of
the
bin
on
burning
of-’
leaves
and
other
landscape
wastes
is
the
potential
for
violation
of
the
National
Ambient
Air
Quality
Standards
for
Particu-
late
Matter.
These
levels
are
established
at
75
micrograms
‘per
cubic
meter
for
the
health
related
standard
and
60
micrograms
per
cubic
meter
for
the
welfare
related
standard.
(annual
gecmet:ric
mean)
.
Twenty-four
hour
standards
of
260
micrograms
per
cubic
meter
(primary,
health
related)
and
150
micrograms
per
cubic
meter
(secondary,
welfare
related)
are
to
be
exceeded
no
more
than
one
day
per
yoar.”
Particulate
matter
exists
commonly
in
two
basic
forms--—solid
particulates
consisting
of
dust,
smoke
and
fumes;
and
lieuid
particu-
lates
consisting
of
mist
and
spray.
Solid
particulates,
with
which
we
are
now
concerned,
have
a
diverse
chemical
composition,
They
may
exert
a
toxic
effect
in
three
ways:
1)
the
particulate
may
be
intrinsically
toxic
due
to
its
inherent
chemical
or
physical
characteristics
(although
few
common atmospheric particulates
have
been
shown
to
he
intrinsically
toxic)
.
2)
The particulate may interfere with
one
or more
of
the
clearance mechanisms
in
‘the resoiratory tract.
3)
The particulate
may act as
a carrier of
an absorbed
tox:Lc substance.
Particulates
sometimes combine with other pollutants,
to form harmful products.
Synergism occurs when
two
or more pollutants combine
to produce
a
pollutant
more
damaging
than
the
sum
of
the
effects
of
the
individual
pollutants acting independently.
The presence
of
carbon
or
soot
as
a common particulate mollutant
is noteworthy,
as carbon
is well known
as an efficient adsorber of
a wide range
of organic and inorganic
comnounds.
Carcinogenic materials have
been
identified
in the atmos-
phere of virtually all
large cities
in which studies have been
conducted and
it may be seen that
large quantities
of particulates
may help carry these pollutants
into the human body.
(Air Quality
Criteria
for Particulate Matter,
U.S.
Dept.
of Health,
Education
and Welfare,
Jan.
1969,
AP-49,
Page
137)
Lung cancer mortality,
bronchitis,
and pulmonary mortality
in
males and bronchitis
in
females
have been strongly correlated with
particulate density.
A positive association between
the degree of
air pollution and the incidence
of both bronchitis
and lung cancer
6
—
361
-6—
have been made.
(Air Quality Criteria
for Particulate Matter,
U.S.
Dept.
of Health,
Education
and Welfare,
Jan.
1969, AP—49,
Page
172)
Two recent British studies showed increases
in respiratory illnesses
in children to be associated with annual mean smoke levels of about
120 micrograms per cubic meter.
A study
of
the Buffalo,
New York
area
found that increases
in
the mortality rate were significantly
linked
to higher
levels of suspended particulate pollution.
A study
in the Nashville,
Tennessee area found significant increases
in all
respiratory deaths
at soiling levels over
1.1 COH annual average.
The number
of deaths
in New York City was reviewed for
excess
mortality
in relation
to the air pollution episode of November
1953.
Excess deaths were related
to increased concentrations
of sulfur dioxide
and suspended particulates.
The lowest particulate
levels at which
health effects appear
to have occurred
in this country are reported
in
studies of Buffalo and Nashville.
The Buffalo study clearly
shows
increased death rates
from selected causes
in males and females
50
to 69 years old
at annual geometric means
of
100 micrograms
per cubic
meter and over.
The study suggests
that mortality may rise
in areas
with
two year geometric means
of
80 micrograms
per cubic meter
to
100
micrograms
per cubic meter.
The Nashville
study suggests increased
death rates for selected causes
at levels above
1.1 COHs.
Sulfur
oxides were also present during the periods studied.
(Air Quality
Criteria
for Particulate Matter,
U.S.
Dept.
of Health, Education
and
Welfare,
Jan.
1969,
AP—49, Page
183)
During
the recent hearings
it was variously stated that the open
hurninci of landscape waste causes
a
fire hazard,
a visibility
problem
on highways,
damage
to pavement and endangers
the health of citizens.
Other persons described.
the problems which accompanied the ban
on
burning:
the fact that leaves plug storm sewers when
they are not
disposed
of;
that compost piles in back yards often harbor rodents,
sometimes give off odors and are unsightly~ that the useful
life of
a landfill
is reduced by putting landscape waste
in
the
landfill;
that plastic bags
sometimes used for
the disposal
of leaves are not
readily degradable;
that machinery
and manpower to haul leaves
and
collect them costs money;
that
an air curtain destructor
for
the
burning of landscape waste also costs money and may not be very
efficient
for
the burning
of loose leaves.
There was
a considerable amount of testimony regarding
the
special problems
of
the smaller communities.
The smaller munici-
palities often have
a small
tax base which
is insufficient
to provide
the financing
for refuse and waste collection,
A higher percentage
of the citizens
in the smaller communities are senior citizens
living on
a more meager
income and unable
to handle
the additional
cost of collection
of
landscape waste.
Not
only
do the smaller communities have
a greater financial
probem
in
disposing
of
leaves
but
generally
they
have
a
better
air
ciuality.
They have
less
pollution
from
the
burning
oi
leaves.
—
362
—7—
EPA witness, David Gray,
testified
that
Illinois
had
540
land-
fills.
A majority of sanitary landfills are located close to
metropolitan
areas.
Smaller
communities,
quite
often,
are
not
near
a
landfill.
Relaxation
of
the
ban
for
the
smaller
communities,
he
said,
would
have
a
favorable
effect
on
the
life
of
those
landfills
and
reduce
the
problc.:~of
hauling
waste
a
longer
distance
which
is
gui
often
the
case
for
the
smaller
communities.
At most of the hearings the witnesses concentrated on showing the
smaller municipalities should be permitted to burn landscape waste
if they did not adjoin a larger metropolitan area.
Stanley A. Nelson,
Director of the Quad—City area Regional Air Pollution Control Agency
submitted a statement:
“Rock Island County
(as well as some of the
others listed) has a rural area several times that of the metro-
politan area.
Several of the small communities are situated only
a few miles from an adjacent county where a co~munityof similar
size would be permitted the exemption.
These communities feel that
this discriminates against those located in a ccunty containing a
metropolitan area.
They agree that any municipality, regardless of
size, which is contained in or is contiguous with a metropolitan
area should be included in the ban on open burnina applying to the
metropolitan area.
It would seem the primary consideration should
be the proximity of a community to a major metropolitan area rather
than just the county in which it is located”.
Donald A. Raselhoff representing the Bi-State Metropolitan
Planning Commission stated that it was unrealistic to designate
all of Rock Island County as a buffer zone.
He said,
however,
that open burning should be prohibited in the metropolitan area.
(Rock Island,Haselhoff, p.
5)
At the last hearing
(f4acomb October 12,
1972) representatives
of park districts and larger municipalities appeared and requested
authority to burn landscape waste for a period of several weeks in
the autumn and another period of several weeks in the spring of each
year.
This proposal was substantially different from the proposal
which had been submitted to the Board and had been published in our
newsletter.
Such a substantially different proposal would require
20 days notice to the public and a new schedule of hearings pursuant
to our statute, EPA Section 28.
The proposal came too late to
accomplish its purpose for the 1972 leaf disposal season.
We
suggest that any person or municipality desiring to make further
changes in the Regulation may make such a proposal pursuant to
Rules 203 and 204 of our Procedural Rules.
Those Rules provide
that ten copies of each Proposal for Anendment or Repeal of a
Regulation shall be filed with the Clerk.
The proposal shall
include the text of the proposed regulation or amendment and a
statement of reasons supporting the proposal.
S
—
353
—8—
In
an
effort
to
broaden
the
hearings
and
show
that
air
quality
in
some
of
the
larger
cities
meets
the
Federal
Standards,
the Rock
Island Park Director submitted
1971 data from
a
tape sampler which
is used
to determine Coefficient of
Haze
(COH)
in
downtown
Rock
Island.
This
method
of
sampling
does
not
conform
to
the
Federal
requirements
as
a
method
of determining
the weight of particulate
matter
in the
air.
Federal law requires that
a
Hi Vol
sampler be
used
for this purpose.
One
is located in Rock Island and shows
that in 1971
the geometric mean was
90 micrograms
per cubic meter—-
a
figure
in excess
of both the Primary and Secondary Air Quality
Standards.
It
appears,
however,
that the COB readings during
the
6
weak
leaf burning period of 1971
(October
15
-
November
30) were
only
slightly higher than
the annual average and Rock Island did
not
at any time approach
COH readings which would have required
an
Episode alert.
For the larger municipalities there are alternatives
to the
hurninq of landscape waste:
Municipalities have used vacuum tank
trucks
for
the
collection
of loose leaves and have used garbage
compacting
trucks
for
the
collection
of bagged leaves.
The loose
twius,
leaves,
and
brush
may
be
disposed of through incineration,
comnostinq or sanitar~ landfill.
The bagged leaves
are disposed
of at sanitary landfills.
Use of plastic bags and sanitary
landfill
is probably
the most practiced
and least desirable method
for disposal
of leaves.
The
leaves
as
a result
of
the high cellulose
content are not considered good
landfill material.
The plastic bags
full of leaves
use up
a landfill more rapidly
than necessary and
create
a hazard because
of
the pressure of gasses built
up beneath
the
unstable ground.
Public Works Journal Corporation,
F.
Stroudsbercj,
:eflns~,7lvania, Vol.
103,
No.
1,
January
1972,
p.
51.
This Board
previously stated
that
‘we have some reservations about
the spreading
practice
of placing leaves
in plastic bags
for collection.
Plastic
bags are relatively non-~degradahleand may interfere with normal
decomposition
of
the leaves
in
a sanitary
landfill.
Moreover,
the
gaseous products
of incineration
of plastic bags may not be desirable
additions
to the air”.
September
2,
1971 Opinion
Nunicipalities
or persons
who
have access to an air curtain
destructor
or similar
device may
apply
to the Environmental
Protection
Agency for a permit to burn landscape wastes.
Rules
404 (a) (4)
.
We
have
some doubt whether such devices are entirely effective for the
burning
of
loose
leaves.
One
nossible
solution
would
be
to
have
the
leaves
compressed
and
baled
before
introduction
into
the
destruction
pit.
Composting
is
probably
the
least
practiced.
method
of
municipal
disnosal
of
landscaoe waste.
However,
some communities are now
turning
to
the
recycling
of
leaves
with
connostinci
programs,
These
eropranmied
methods
can
take
30
cubic
yards
of
street
collected.
leaves
C ~i
cdu
a
t~e~
in
La onc cu~~
ya
ct
o~ r
ch
blaci
Ceaf
rio_n
~
c
—9—
when returned to the soil,
can promote growth and restore
a vital
link in nature’s chain.
Public Works Journal Corporation,
E.
Stroudsberg, Pennsylvania, Vol.
103, No.
1, January 1972,
p.
48.
Brookhaven, New York, population 250,000, has developed a
program which
includes publishing and distributing
free booklets
on composting and t~hedevelopment of composting demonstration
centers.
Plastic bags have been ruled out in favor of
a new bio-
degradable Kraft paper bag.
Maplewood, New Jersey which has had
a composting program since
1931 has been able to realize
a modest
profit from the sale of composted leaves.
Compost Science, Rodale
Press,
Emmaus,
Pa., Volume
12, Number
6, Nov.—Dec,,
1971,
p.
3.
Tennafly, New Jersey because of a municipal composting program
cleans catch basins and drainage systems only one—third as often
as before.
Wellesley, Mass., with a population of 28,000 has had
a leaf composting program for
12 years and reports
a production
of 5,000
cubic yards
of leaf mold.
Public Works Journal,
Jan.
1972,
pgs.
45-50.
Although not all of the communities utilizing composting
programs can report profit, most have reported reduced cost in the
handling of leaves in addition to environmental quality gains.
Individuals also will ordinarily have other methods for leaf
disposal available to them.
Where a relatively small quantity of
landscape waste is involved it may be convenient simply to place
it in bags
for municipal collection.
When it becomes available,
the paper bag is to be preferred.
If the municipality has a vacuum
tank collector the individual citizen might find it easier to rake
leaves to the designated area for collection by the vacuum machine.
Individuals who have a suitable area might find the individual
compost pile
a good solution to their problem.
Composting machines
may
be
rented
or
purchased
to
quicken
the
process
of
shredding
the
leaves for a compost pile.
These shredders are also available
to
reduce the volume of leaves and small
limbs for insertion into
bags.
Others will simply mulch the leaves onto the ground.
We find
from the evidence that smaller communities do not have
the financing
and
the manpower to provide good alternatives
to leaf
burning and in many cases
there is no landfill near the smaller
municipalities.
We further
find
it unlikely that the Federal
Air
Quality Standards will
be violated by open burning
of landscape waste
in municipalities of 2,500 persons or less which do not adjoin larger
municipalities
and are located outside our major metropolitan areas
of Chicago and
B.
St.
Louis.
We believe that the burning permitted
by the Regulation can be conducted wiLhout harm
to the public.
Care
must still be taken in setting individual
fires since the Regulation
is not intended
to condone open burning which constitutes
a nuisance
or causes
a violation of Air Quality
Standards.
Park districts
or
forest
preserves which are not located
in
a prohibited
area may conduct.
open burning
6
—
365
—10—
of landscape westa,
hut, because of
the quantities of waste which
may be involved need.
to take special care not to create a nuisance.
Such open burning
of landscape waste
is authorized
only
on the
premises where
it
is nenerated, when atmospheric conditions will
readily dissipate the contaminants and if the burning does not
create
a visibility hazard.
It has been calculated
that
this relaxation of
the ban will
affect about
5
of
the population of Illinois.
It is the unanimous
opinion of
the Board that
the relaxation should be made
at least
to that extent.
The
Board
is divided as
to the necessity’ for pro-
viding
still more
relief from the Regulation previously adopted
in
September
1971.
Mr.
Henss would amend
the Regulation
to allow open burning
of
leaves
by
those people who can show that they have no practical
and
ecologically sound alternative.
He states
that
the public should have
a sneedy and inexpensive method
of obtaining such permission from the
EPA if
they have
a unique disposal problem.
A majority of
the Board
have rejected
this recommendation.
In prohibited
areas,
the variance
procedure remains
as
the only method available
to
the public
to
obtain permission
to burn landscape waste without
an air curtain
destructor.
The
prohibition
remains
in
effect
in
municipalities
over
2,500
in population and
in their adjoining municipalities;
and within rural
areas
(unincorporated
areas)
1,000 feet or less from
municipalities
where open burning
of landscape waste
is banned.
Open burning of
landscape waste
is
prohibited
in all municipalities regardless
of
size
which
are
located
in
the
Chicago Metropolitan area,
i.e. wholly
within
40
statute
miles,
by
air,
of Meigs Field.
A similar ban applies
to all municipalities regardless of
size in
the
E.
St.
Louis metro-
nolitan area,
i.e.
wholly within
20 miles
of McKinley Bridge con-
necting
St.
Louis,
Missouri and Venice,
Illinois.
I,
Christen
1. Mo~fett, Clerk
of
the Dollution Control Boa~d
certiFy
that
the
J3oard
adonted
the
abo~e
Oninion this
day
of
November,
1972,
b
a
vote
of
~—Q
6
—
366
