BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF:
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REVISION OF THE BOARD’S
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R00-20
PROCEDURAL RULES: 35 ILL. ADM.
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(Rulemaking – Procedural)
CODE 101-130
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COMMENTS OF THE CHEMICAL INDUSTRY COUNCIL OF ILLINOIS
NOW COMES the Chemical Industry Council of Illinois (“CICI”) through its Regulatory
Affairs Director, Christie Bianco, and hereby submits the following comments relating to the
above-referenced matter.
CICI is a not-for-profit, statewide association the represents 189 corporations, over one
hundred of which are chemical firms who manufacture, blend, distribute and sell chemicals.
The chemical industry in the state of Illinois ranks third in the United States in chemical exports,
fourth in value of chemical shipments and maintains more than 62,000 employees.
CICI appreciates the opportunity to comment on proposed Part 130. CICI has reviewed
and endorses the comments submitted separately by the Illinois Environmental Regulatory
Group (“IERG”).
CICI echoes the intent of IERG in seeking confirmation from the Illinois Pollution Control
Board (“Board”) that its proposed Part 130 is not limited to trade secret claims for information
submitted to the Board, but also includes claims to the Illinois Environmental Protection Agency
(IEPA) and any other agency dealing with trade secret issues.
Preservation of rights and protection of confidentiality, especially when dealing with
business information, is of critical importance to the members of CICI. However, we understand
that public information needs to be readily available and accessible. CICI believes that the
comments and proposed revisions submitted by IERG will address both concerns. CICI
appreciates the work IERG has put forth in these comments and the Board’s anticipated
consideration.
Respectfully Submitted,
Chemical Industry Council of Illinois
By:
_____________________
Christie Bianco
Dated: June 15, 2000
Christie Bianco
Regulatory Affairs Director
Chemical Industry Council of Illinois
9801 West Higgins Road, Suite 515
Rosemont, IL 60018