ILLINOIS POLLUTION CONTROL BOARD
    May
    24,
    1979
    ENVIRONMENTAL PROTECTION AGENCY,
    Complainant,
    v.
    )
    PCB 77—143
    PETER D, GIACHINI,
    Respondent.
    MS CAROL M. PEARCE AND MS JILL LESLIE DRELL, ASSISTANT ATTORNEYS
    GENERAL, APPEARED ON BEHALF OF THE COMPLAINANT.
    MR. JOHN MURPHY, GIACHINI, MURPHY
    &
    MANN,
    APPEARED ON BEHALF OF
    THE RESPONDENT.
    OPINION
    AND
    ORDER OF THE BOARD
    (by Dr. Satchell):
    This matter comes before the Board upon an amended com-
    plaint filed
    on October 13,
    1977 by the Environmental Protection
    Agency
    (Agency).
    Respondent Peter
    D.
    Giachini was added
    as
    a
    party after discovery indicated he was the beneficial owner of
    fifty-three acres located near Palatine in Cook County, the
    area bounded by Dundee Road,
    Greenview Avenue, Glencoe Street,
    Portage Avenue, Northwest Highway and the Deer Grove subdivision,
    which was held by the original Respondent, Maywood-Proviso State
    Bank,
    under a trust agreement.
    The amended complaint alleges that
    since January
    1,
    1976 Respondent has allowed open dumping of
    refuse on land owned by him in violation of Section 21(b)
    of the
    Environmental Protection Act
    (Act)
    and Chapter
    7:
    Solid Waste
    Rules and Regulations, including Rule
    305,
    failure to place
    adequate daily cover of at least six inches of suitable material
    on all exposed refuse.
    Hearings were held upon the complaint on May 18,
    1978,
    June
    7,
    1978 and February 16,
    1979.
    The Agency presented its
    witnesses at the first two hearings and Respondent testified at
    the lasts
    Respondent appeared at the first hearing with counsel,
    stated that,
    among other things,
    he intended to file an inter-
    locutory
    appeal and walked out.
    There is no mention of such an
    appeal in the record.
    Respondent did not otherwise participate
    in the first two hearings and did not cross—examine the Agency’s
    witnesses.
    However, Respondent makes no arguments questioning
    due process aspects
    of the hearings.
    33—547

    —2—
    Mr. Kenneth
    Bechely, regional manager of the Agency’s Land
    Pollution Office, testified
    concerning four visits to the site on
    August
    18,
    1976, June 9,
    1977, October,
    1977 and May 17, 1978
    (R.
    33,
    38).
    He testified that there was a large volume of debris,
    including construction debris, waste from processing auto interiors
    and “people garbage”
    (R.
    34).
    The debris extended two hundred to
    three hundred feet from the highway into Respondent’s property and
    increased in volume between August,
    1976 and June,
    1977
    (R.
    36).
    The witness had
    never seen anyone dumping at the site, but testified
    that it was a tremendous amount of refuse just for people who come
    by and dump randomly and that it
    would take
    a
    good-sized truck
    to
    dump some of the piles
    there
    (R.
    42,
    43).
    There was no cover of any
    type on the material
    (R.
    42).
    Mr. Gilbert Gurber,
    a
    zoning
    in-
    spector for
    Cook County, testified concerning three visits to the
    site in June,
    1975,
    October, 1975 and November, 1975
    (R.
    26).
    He
    generally agreed with Bechely concerning the nature and extent of
    the refuse
    CR,
    27,
    28).
    In June, 1975 he had seen two dump
    trucks and one bulldozer leveling the earth
    (R.
    28).
    The principal
    factual issue concerned whether the refuse was
    on Respondent’s property
    or on the state highway right-of-way.
    Mr.
    Donald Miller,
    Survey Unit Engineer,
    and Mr. Donald Bohien, Surveyor,
    both employed
    by the Illinois Department of Transportation, testified
    concerning a survey they made of the fifty foot right-of-way line on
    April
    5,
    1978
    CR.
    48, 12).
    They testified that there was debris and
    that it was on Respondent’s property,
    as well as the right-of-way
    (R.
    16, 18,
    19,
    54).
    Mr. Miller testified also to the lack of cover
    (R.
    54).
    Photographs were introduced showing refuse located on
    Respondent’s property with respect
    to the survey flags
    (Comp. Ex.
    7,
    8,
    10).
    Two maps were
    introduced showing an area of refuse six
    hundred feet across, extending as much as two hundred feet into
    Respondent’s proerty
    (Camp.
    Ex.
    12A,
    18).
    One of the maps also
    shows another area of refuse six hundred feet across which extends
    over three hundred feet from the right-of-way
    (Comp.
    Ex. 12A).
    Mr.
    Bechely testified that this area had more refuse, but he was unsure
    whether it belonged to Giachini
    (R.
    39).
    Respondent did not cross-
    examine and does not directly argue that this pile is not on his
    property.
    He testified that his frontage was nine hundred feet
    (R.
    107), but implies
    in his brief that his frontage extends
    to
    Portage Avenue,
    a distance of some 1800 feet from Doe Road
    (R.
    18,
    Camp.
    Ex.
    12A,
    18).
    The map also shows smaller areas of refuse
    along almost the entire frontage.
    Respondent,
    Mr. Peter Giachini, was the only witness for
    the defense.
    He testified
    that he had never permitted anyone to
    dump on the property
    CR.
    64).
    He testified that he had hired or
    asked two men to watch the site when they passed it on the way to
    work and that they
    had never found anyone dumping
    (R.
    64,
    98,
    104),
    33—548

    —3—
    He or someone posted “one or two or three” no dumping signs
    CR.
    65,
    106).
    Complainant’s Exhibit
    2 includes a letter dated
    July
    16,
    1973,
    from Respondent to the Cook County sheriff asking
    for license numbers of persons seen dumping on the property.
    Respondent visited the site once a week and had never seen anyone
    dumping
    (R.
    65,
    99, 104).
    He admits there was a “nominal” amount
    of dumping on his property prior to September,
    1977
    CR.
    86),
    denies that there has been any debris dumped since then
    (R.
    89),
    but says some “material”,
    as opposed to “debris”,
    has been dumped
    CR. 101,
    102),
    Section 21(b)
    of the Act reads:
    “No person shall
    .
    cause or allow the open dumping of any other refuse in violation
    of regulations adopted by the Board.”
    Respondent has testified
    that he never permitted anyone to dump.
    However, the photographs,
    maps and the testimony of the Agency’s witnesses clearly establish
    that refuse has been dumped on
    a massive scale which involved the
    use of heavy equipment.
    The Agency has offered no evidence that
    Respondent actively permitted this or that he actually caused the
    dumping. However,
    the Board has previously held that “allow”
    includes inaction on the part of a landowner.
    The Board finds
    that Respondent’s conduct amounts
    to acquiescence sufficient to
    find, a violation of Section 21(b).
    EPA v.
    Dobbekke, PCB 72-130,
    5 PCB 219,
    Much of Mr. Giachini’s testimony concerns drainage.
    He says
    that the state raised the highway several years ago, interfered
    with the natural drainage and created a slough on his property
    CR.
    89—97).
    He contends the wet area attracts
    “fly dumpers”.
    This cannot be recognized as
    a defense.
    It is not obvious why a
    wet area would necessarily attract fly dumpers more than a dry
    area.
    It is well known, however,
    that a pile of refuse, such as
    the one Respondent maintains,
    tends to attract dumpers.
    Respondent’s pleadings offer four affirmative defenses.
    One alleges the failure of the State of Illinois to prevent the
    dumping by failing to erect a snow fence along the state’s
    right-of-way beside Respondent’s property line.
    Respondent has
    cited no authority imposing a duty on the state
    to either erect
    a snow fence or prevent dumping on property adjacent to highways.
    Respondent has alleged as a second defense that refuse has also
    been dumped on the state’s right-of-way adjacent to his property.
    The existence of refuse on another’s property is not made a
    defense by any rule or statute and is not logically relevant to
    any issue in the violation charged against Respondent.
    Respondent
    also attempted to file a counter—claim against the state alleging
    this,
    The counter-claim wa~sdismissed by Order of the Board on
    May 11,
    1978,
    for reasons set forth in the Board’s Order of
    January 19, 1978,
    in Owens—Illinois, Incorporated v.
    EPA, PCB 77-288.
    33—549
    A

    —4—
    Respondent’s
    third and fourth affirmative defenses raise
    £~j~dicataas
    a bar to this enforcement action.
    Respondent’s
    Exhibit
    5 is
    a summons and complaint issued by the Cook County
    Circuit Clerk, dated March 13,
    1974, charging:
    that Peter D.
    Giachini has on or about June 21,
    1973
    at Northwest Highway/West of Palatine committed the
    offense of 6.9 8—3—4 in that he is the beneficiary of
    land on which landfill operations are conducted without
    Special Use permit and debris has been dumped on the
    property.
    Respondent’s Exhibit
    4
    is also a summons and complaint which
    charges similarly that Respondent on or about May
    11,
    1977:
    committed the offense of violating the zoning ordinance
    in that he has
    a landfill and dump in a R—5, Single
    Family Residence District which is
    a prohibited use in
    violation of Article
    4 Section 4.57—10
    of the Cook
    County Zoning Ordinance.
    Respondent has the
    burden of proof on the affirmative defense
    of ~
    McNely
    V.
    Bd.
    of Education 9
    Ill.
    2d 143, 151
    (1956).
    Mr Giachini
    testified that there was a hearing and judg-
    ment
    of dismissal on the merits in each case
    CR.
    81, 88).
    No
    other evidence of the judgments appears in the record.
    Judgments
    are to be proved by a certified copy.
    Ill.
    Rev.
    Stat.
    Ch.
    51, §13
    (1977).
    However, since the Agency has no objection,
    the Board
    will consider Mr.
    Giachini’s testimony
    as competent evidence.
    However,
    the testimony is self—impeaching.
    Respondent says there
    was
    a judgment on the merits
    in both cases and that they were on
    the same cause of action as the case at bar.
    He says that the
    first and second cause of action are the same as the third.
    This
    is the same as saying the first
    is the same as the third and the
    second is the same as the third.
    Therefore,
    the first is the same
    as the second and res judicata was a bar to the second judgment
    also.
    Respondent
    does not explain how a judgment on the merits was
    reached in the second case
    when resjudicata was
    a defense there
    also.
    Illinois Courts have recognized two forms of res judicata,
    estoppel by verdict and estoppel by
    judgment.
    Hoffman
    v,
    Hoffman,
    330 Ill 413, 417
    (1928).
    In the case of estoppel by judgment,
    where a former adjudication
    is relied on as an answer and bar to
    the whole cause of action,
    it must appear that the cause of action
    is the same in both actions,
    On the other hand,
    in the case of
    estoppel by verdict,
    the cause of action need not be the same.
    Where a question has been directly in issue and decided by a court
    of competent jurisdiction, that issue cannot be relitigated in a
    future action between the parties on the same or a different cause
    of action.
    33—550

    —5—
    Respondent does not mention estoppel by verdict in his brief
    and the argument is deemed waived.
    However,
    since the pleading
    could be construed as raising estoppel by verdict, the Board will
    address the issue further.
    To raise this defense Respondent must
    point to some issue actually litigated in one of the former actions
    and demonstrate that the Agency
    is estopped on that issue in this
    case.
    The burden
    is on Respondent to do this by clear and conyjncjnq
    evidence.
    The Board cannot determine from the evidence before it
    what issues were actually litigated in the former actions.
    For
    instance, they could have been decided on the issue of ownership,
    which is admitted here.
    Therefore, Respondent has
    failed to meet
    the burden of establishing estoppel by verdict.
    When a former adjudication is relied upon as
    a complete bar
    to a subsequent action,
    the questions to be determined are whether
    the cause of action is the same in the two proceedings, whether the
    two actions are between the same parties or their privies, whether
    the former adjudication was a final judgment upon the merits and
    whether it was within the jurisdiction of the court rendering
    it.
    v.
    Kidd,
    398 Ill.
    405,
    408
    (1947).
    The parties do not argue
    the Circuit Court’s jurisdiction and it is assumed there was a final
    judgment upon the merits.
    The Agency argues that it was not in
    privity with Cook County and
    is not bound by the former judgments.
    Since there is evidence in the record that there was actual coopera-
    tion between the County and the Agency in this case,
    the Board does
    not need to address the question of privity in the abstract.
    The
    Board finds that they were in fact in privity.
    Bulk Terminals Co.
    v.
    EPA,
    29
    Ill, App.
    3d 978,
    331 NE 2d 260
    (1975)
    ,
    rev’d on other
    grounds 65 Ill 2d 31, 357 NE
    2d 430,
    cert. denied 97
    S. Ct.
    2674.
    The only remaining question
    is whether the former judgments were upon
    the same cause of action.
    In determining whether the nature of a
    second cause of action is the same as the prior one, the test is
    whether the same evidence would sustain both actions.
    Pillsbury v.
    Early,
    324 Ill.
    562,
    565
    (1927).
    The 1974 complaint appears to charge that Respondent owned
    land on which landfill operations were being conducted without a
    special use permit.
    The 1977 complaint charges violation of the
    zoning ordinance by having a landfill and dump in a single family
    residence district.
    Neither complaint mentions the Act or Board
    Rules.
    However,
    res judicata could still be a bar if the evidence
    to prove the former actions would also sustain a finding on the case
    at bar.
    The parties have introduced no evidence into the record of
    what these ordinances are.
    The Board must therefore draw upon its
    general knowledge of the law.
    In the case before the Board Respond-
    ent is charged with permitting open dumping without providing daily
    cover,
    The Board assumes evidence concerning daily cover was not
    necessary in either of the earlier cases.
    Respondent would have
    violated the zoning or special use ordinance whether he applied
    cover or not.
    It cannot, therefore, be said that Respondent has met
    his burden of establishing by clear and convincing evidence that the
    earlier judgments were on the same cause of action.
    33—55 1

    —6—
    Assuming, however, that in the abstract the causes of action
    are the same,
    they are different because they involve different
    dates.
    The earlier complaints charge violations on June 21, 1973
    and May
    11,
    1977, while the Agency’s complaint charges
    a continuing
    violation from January
    1, 1976 on to the date of the amended com-
    plaint of October 13,
    1977.
    A new cause of action arises under the
    Act and Board Rules each day Respondent either allows additional
    dumping or fails to provide cover.
    There is testimony that addi-
    tional dumping occurred between August,
    1976 and June,
    1977
    (R.
    36).
    There was no cover on the refuse on June
    9,
    1977 and May 17, 1978
    CR.
    38,
    41).
    The Board therefore concludes that res judicata is no
    bar because the Agency’s complaint relates
    to a different time
    period and not the same violation.
    Respondent raises for the first time in his reply brief the
    argument that the Board Rules are inapplicable since he is not
    operating a solid waste disposal site.
    The Agency has had no
    opportunity to respond to this contention, which should have been
    raised much earlier.
    It should therefore be deemed waived.
    However,
    the Board has previously held Section 21(b)
    and the Rules applicable
    in similar cases.
    EPA v.
    Dobbekke, PCB 72-130,
    5 PCB 219.
    Section 33(c)
    of the Act requires the Board to consider all
    the facts and circumstances bearing upon the reasonableness of the
    emissions, discharges or deposits.
    Respondent has offered no evi-
    dence bearing upon reasonableness and the Board finds that he has
    failed to meet the burden of proof required to establish a Section
    33(c)
    defense.
    Processing
    & Books
    v.
    PCB,
    64 Ill 2nd 68,
    351 NE
    2nd 865,
    However, the Board will consider Section 33(c)
    factors
    in
    mitigation in assessing its final Order.
    All witnesses, including Respondent,
    testified to the pres-
    ence of construction debris on the site
    CR.
    16,
    27, 33,
    34, 54,
    86,
    89, 101,
    102).
    Two witnesses said that there was some “people gar-
    bage” on the site
    CR.
    27,
    34).
    The Board finds, from the evidence,
    that the refuse constitutes
    a serious hazard to public health and
    safety by promoting rats and other disease vectors by providing food
    and habitat, and also threatens discharge of leachate into the
    ground and surface water.
    The Board finds that there is no social
    or economic value in open dumping.
    There is no evidence in the
    record pertaining to the suitability of the area and priority of
    location for a dump.
    It is technically practical to restrict access
    and to compact the refuse and apply a final cover of suitable
    impermeable material with readily available equipment.
    There is no direct evidence of Respondent’s financial con-
    dition in the record.
    However, it appears that he is
    a partner
    in the law firm of Giachini, Murphy and Mann, president of the
    Maywood-Proviso State Bank and owns fifty-three acres of land
    near Chicago.
    Prior to the hearing, the Agency posed interrog—
    atones relating to Respondent’s financial condition pursuant
    33—552

    7—
    to Procedural Rule 313 (a) (3).
    Respondent objected and refused
    to answer after ordered to do so by the Hearing Officer.
    As a
    result, pursuant to Rule 701(c)
    ,
    Respondent is deemed to have
    admitted that any Order of the Board would be economically
    reasonable.
    The Board therefore finds that Respondent Peter D. Giachini
    has violated Section
    21(b)
    of the Act by allowing open dumping of
    refuse in violation of Board Rules, Chapter
    7:
    Solid Waste,
    Rule 305 by failing to provide adequate daily cover.
    Respondent
    has delayed cleaning up the refuse and restricting access for
    more than three years.
    This delay no doubt conferred a substan-
    tial economic benefit on the Respondent in the form of interest
    on the money
    it would have cost to come into compliance.
    However,
    the Board cannot estimate from the record before us how much he
    saved by this delay.
    The value of Respondent’s land may have
    increased as a result of the dumping.
    He admits that he actively
    permitted dumping of clean clay without charge
    (R.
    103).
    He has
    obtained an economic benefit in the form of other free fill
    material.
    A fine of $1000
    is necessary to aid enforcement of the
    Act by encouraging voluntary compliance.
    The Board will order
    Respondent to take specific steps to restrict access to the site
    because of the extent of dumping which has occurred and the on-
    going nature of the violation.
    This Opinion constitutes the Board’s findings of fact and
    conclusions of law in this matter.
    ORDER
    It
    is the Order of the Pollution Control Board that:
    1.
    The Board finds Respondent in violation of Section
    21(b)
    of the Act by allowing open dumping of refuse
    on a site owned by him and failing to place adequate
    daily cover of six inches of suitable material on all
    exposed refuse.
    2.
    Within ninety days of the entry of this Order,
    Respondent shall cease and desist from further
    violations of the Act and Board Rules.
    3.
    Within ninety days of the entry of this Order,
    Respondent shall either remove the existing refuse
    to a permitted landfill or spread and compact it
    into layers not more than two feet thick and apply
    a final cover of not less than two feet of suitable,
    compacted, impermeable cover material.
    33—553

    —8—
    4.
    Within ninety days of the entry of this Order,
    Respondent shall do any and all acts necessary to
    restrict access to the site along the entire length
    of his frontage along Northwest Highway.
    5.
    Within forty-five days of the entry of this Order,
    Respondent shall, by certified check or money order pay-
    able to the State of Illinois,
    pay a civil penalty of
    $1000 which
    is to be sent to:
    State of Illinois
    Fiscal Services Division
    Environmental Protection Agency
    2200 Churchill Road
    Springfield, Illinois
    62706
    I, Chrjstaii~L.Moffett, Clerk of the Illinois Pollution
    Control Board, hereby certify the above Opinion and Order we e
    adopted on the
    ~L/~
    day of
    ,
    1979 by a vote of
    —o
    Illinois Pollution
    trol Board
    33—554

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