Illinois Pollution Control Board
    February 22, 1984
    LAMPLIGHTER REALTY
    AND DEVELOPMENT COMPANY,
    Petitioner,
    v.
    )
    PCB 83—157
    ILLINOiS ENVIRONMENTAL
    PROTECTION AGENCY,
    Respoh(~ent.
    ROY M.
    HARSCH,
    ESQ., OF MARTIN, CRAIG, CHESTER
    & SONNENSCHEIN,
    APPEARED ON BEHALF OF PETITIONER.
    MARY E. DRAKE,
    ESQ,, APPEARED ON BEHALF OF RESPONDENT.
    OPINION AND ORDER OF THE BOARD
    (by J.
    Marlin):
    On October 26,
    1983 the Lamplighter Realty and Development
    Company
    (Lamplighter)
    filed
    a Petition for Variance from
    35
    Ill.
    Adrn.
    Code 309.241(a) as
    it relates
    to a connection
    to a
    sewer plant which is
    on Restricted Status.
    Th3 Illinois
    Environmental Protection Agency
    (Agency)
    filed on December
    14,
    1983 its Recommendation that the variance be granted.
    A hearing was held on January 13,
    1984 and petitioner waived
    the right to file
    a post—hearing brief.
    In
    1973 pet~itioner envisioned and designed
    a
    95 acre area
    which included
    a
    75 acre planned unit development.
    This develop-
    ment was to be
    a mixture
    of commercial, office, and high—tech
    light industrial uses.
    A series of option and land exchange
    contracts was entered into with the landowners
    (the Theideis)
    which provided that the petitioner would purchase a right
    to
    buy
    95 acres in installments,
    After the first option was
    exercised and the land developed,
    the proceeds would be used to
    purchase the next option,
    until the total acreage was purchased.
    Ground-breaking occurred in late 1976 or early
    1977 when public
    water and sewer service were available.
    An annexation agreement
    between Lamplighter, the Theidels and the Village of Willowbrook
    was entered into on July 25,
    1977 which imposed certain conditions
    on the petitioner as developer
    (P1.
    Exh.
    3).
    The conditions
    56-22b

    —2—
    listed
    be:iow were
    to be met regardless
    of the petitioner’s
    financial
    condition
    or status
    of
    the
    project:
    (1) construct
    a
    street:~
    (2)
    purchase
    and
    dedicate
    one acre of land to
    the Vjllage,
    ~3) construct and complete a
    12—inch water main,
    and
    (4)
    make ~ commitment for
    off—street water management.
    If
    the petitioner
    could not fund these
    improvements, the Theidels
    as
    signators
    would be liable
    (P1.
    Exh.
    3).
    Meanwhile, the
    Theidels have bought a
    200
    acre farm
    so as to build
    a bigger
    nursery
    than the former one, which was
    on the land which
    is
    the
    subject
    of
    these
    proceedinq~.
    in
    order
    to
    have
    enough
    cash
    to
    build,
    the
    farm
    was
    put
    up
    as
    collateral
    fcr
    loans
    (P1.
    Exh.
    7).
    The
    nursery development is not complete because
    of
    lack of payment by petitioner, due to the imposition
    of
    restricted status on the Marionbrook plant.
    On
    April
    30, 1979 the Marionbrook sewage treatment plant,
    under
    jurisdiction
    of
    DuPage
    County
    Department
    of
    Public
    Works
    (DuPage),
    was placed on Restricted
    Status.
    Petitioner tried
    to arrange for sewer and water service from
    the Hinsdale Sanitary
    District
    but
    was
    unsuccessful.
    Pursuant
    to
    court order in People
    v.
    Count~! of
    DuPaqe~
    80
    MR
    432,
    dated
    April
    14,
    1982,
    before any
    new
    connections
    to
    Mar:Lonbrook
    plant are made,
    current
    flows
    must
    be
    off~ioaded
    so
    as
    to
    achieve
    a
    net
    reduction
    in
    flow
    to
    the
    plant.
    Additionally,
    DuPage
    may
    connect
    up
    to
    75
    single
    family
    residents!
    population
    equivalent
    units
    (P.E.
    )
    per
    month;
    the
    units
    may
    accumulate
    Although
    I
    is
    estimated
    that
    550
    P. E.
    units
    are
    needed
    for
    the
    proposed
    project
    and
    many
    P.E.
    units
    have
    accumulotcd,
    no
    off-~lccdinç
    has
    occurred
    due
    to
    various
    delays.
    Therefore,
    no connections
    are
    allowed
    at
    this
    time.
    DuPage
    plans
    a
    series
    of
    Interceptor
    Systems
    and
    additional
    sewage
    treatment plants
    to
    accept
    off-loading
    from
    Marionbrook
    and
    eventually
    phase
    out
    that
    facility.
    Knoliwood,
    an
    interim
    plant,
    has been
    completed
    and
    DuPaqe
    plans
    to
    off—load
    179,950
    gallons
    per
    day
    from
    Marionbrook to
    the
    interim
    plant.
    Construction
    is
    to
    begin
    on
    a permanent Knollwood
    plant
    in early 1984.
    After
    the
    permanent
    plant
    Is
    operating,
    these
    improvements
    should
    effectively
    result
    in
    the
    lifting
    of
    restrictive
    status.
    As
    in
    any
    variance
    proceeding
    the
    burden
    is
    on
    the
    petitioner
    to
    show
    that
    compliance
    with
    the
    Board
    rules
    and
    regulations~
    specifically
    35
    III. Adm.
    Code
    309.2~l(a),
    would
    Impose
    an
    arbitrary
    or
    unreasonable hardship.
    The
    imposition
    of
    restricted status
    on
    the
    Mar:Lonbrook
    Plant
    suddenly
    halted
    the
    petitioner~s
    project
    which was
    proceeding
    under
    a
    phased
    schedule.
    This
    situation
    prevents
    the petitioner
    from
    developing
    the
    project
    which
    was
    to provide the funds ~to
    honor
    his
    annexation
    agreement
    and
    option
    to purchase the
    remainder
    of the
    Theidel
    land.
    The petitioner remains obligated
    to meet
    the annexation conditions even
    though he cannot complete
    the
    project.
    Three land sale
    agreements worth $700,000 were
    56-226

    —3—
    lost because of restricted status and the resulting unavail-
    ability of sewer service
    (Record at 20), which also has had
    a chilling effect on the number of potential buyers.
    In addi-
    tion, petitioner must expend at least $275,000 to fulfill
    the conditions
    in the annexation agreement
    (R at 18-20).
    As
    of October 1983 Lamplighter has paid $1,536,000 for 48 acres
    and is obligated under contact ~to buy
    27 more acres for
    $1,125,000
    (P1.
    Exh.
    1).
    As of October
    1983,
    $1,781,834 has
    been
    expended
    (including the cost of
    48 acres)(P1.
    Exh.
    1).
    Future costs are estimated to be $2,539,000, which includes
    the purchase of
    27 acres,
    completion
    of
    the annexation agreement
    conditions, and interest
    (P1.
    Exh.
    1).
    Total costs are
    $4,320,834
    (P1.
    Exh.
    1).
    The Agency has recommended that this variance be granted.
    The proposed development and its
    550 P.E.
    units will be phased
    in during the
    time
    the
    off-loading
    plan for the Marionbrook
    Sewage Treatment Plant
    is being implemented.
    The petitioner’s
    design also provides
    for a storm water capture and retention
    feature
    which
    will
    reduce flooding and infiltration inflow
    problems
    external
    to
    the
    site
    (R
    at
    63).
    According
    to
    the
    Agency,
    completion
    of
    the
    petitioner’s
    project
    will
    reduce
    total
    adverse
    environmental
    impact.
    In
    summary,
    the
    actual
    development
    was
    commenced
    long
    before
    imposition
    of
    restricted
    status.
    Efforts to arrange
    for alternate
    sewer service proved unfruitful through no fault
    of petitioner.
    Equally, if not more importantly, the petitioner
    has
    designed
    the
    project
    so
    as
    to
    decrease
    flooding
    problems
    and provide
    a lessening of environmental impact.
    Balancing
    the
    financial hardship and the reduction
    of
    environmental
    impact,
    the
    Board finds that denial of the
    variance
    would
    impose
    an
    arbitrary
    or
    unreasonable
    hardship
    on the petitioner.
    Therefore,
    the Board grants
    a
    variance from
    the terms of
    35
    Ill.
    Adr1l. Code
    309.241(a).
    This
    Opinion
    constitutes
    the
    findings
    of
    fact
    and
    the
    conclusions
    of
    law
    in
    this
    matter.
    ORDER
    Lamplighter Realty and Development Company is hereby
    granted
    a
    variance
    from
    35
    Ill.
    Adm..
    Code
    309.241(a)
    to
    allow
    the
    Agency
    to
    issue
    construction
    permits
    for
    sewer
    extension
    to
    service
    Willowbrook
    Office
    Campus
    planned
    unit
    development
    of the petitioner;
    thereby enabling DuPage County Department
    of Public Works
    to issue the necessary sewer connection permits,
    provided that:
    56-227

    —4—
    Within forty five days of the date of this Order,
    Petitioner shall execute and forward to the Illinois Environmental
    Protection Agency,
    Compliance Assurance Unit, Water Pollution
    Control Division,
    2200 Churchill Road, Springfield,
    IL
    62706,
    a Certificate of Acceptance and Agreement to be
    bound to all terms and conditions of this variance.
    This
    forty-five day period shall be held in abeyance for any
    period during which this matter is being appealed.
    The
    form of the certificate shall be as follows:
    CERTIFICATE
    I,
    (We)
    __________
    _______________________________________
    having
    read
    the
    Order
    pf
    the
    Illinois
    Pollution
    Control
    Board
    in PCB 83—157, dated ____________________________
    understand
    and
    accept
    the
    said
    Order,
    realizing
    that
    such
    acceptance
    renders
    all terms and conditions thereto binding
    and enforceable.
    Petitioner
    By:
    Authorized Agent
    Title
    Date
    I,
    Christan
    L.
    Moffett,
    Clerk
    of
    the
    Illinois
    Pollution
    Control Board, hereby certify the above Opinipn and Order
    were adopted on the
    ~
    day
    of
    ~
    .~,,
    1984 by
    a vote of
    ~
    7
    j
    Christan
    L.
    Moffett,
    rk
    Illinois Pollution Control Board
    56-228

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