ILLINOIS POLLUTION CONTROL

BOARD

September 6,

1972

CITY OF SPRINGFIELD,

a Municipal Corporation

#72—143

V.

ENVIRONMENTAL PROTECTION AGENCY

ORDER

OF MODIFICATION

Opinion in the above-captioned matter

is modified by deleting

the last paragraph on page

7,

all paragraphs on page

8 and all

paragraphs within the quote on page

9 and substituting in lieu

thereof,

the

following:

In our Opinion of September

2,

1971, adopting the Open Burning

Regulations, we noted the reasons for adoption of the provisions

under consideration:

“3.

Leaves and Other Landscape Refuse:

“Backyard Incineration”.

There has been considecable confusion over the status of

leaf-burning under the new statute.

Today’s regulation makes it

clear that leaves and other landscape refuse may be burned on the

premises only outside municipalities and a one mile buffer

zone

beyond towns of 1000 or more people.

In populated areas leaf

burning is a nuisance.

The City of Chicago has recently banned

leaf burning,

and it reports

a significant reduction in complaints

as

a result

(R.

131,

132)

.

We have been urged by numerous wit-

nesses to ban leaf burning.

Dr. George Arnold,

on behalf of the Madison County Sanita-

tion and Pollution Committee,

argued that leaf burning creates

a

hazard of fire and of traffic accidents,

contributes to the viola-

tion of particulate air quality-standards, reduces visibility,

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 testi-

fied as to the serious health effects of burning leaves, especially

those contaminated with pesticides, upon people with allergies

or respiratory diseases

(R. 184—91)

.

There was also much evidence

as to alternative methods of leaf disposal,

including municipal

incineration and sanitary landfill

(R.

135)

as well

as mulching

and composting to make use of

the organic material

(R. 67-68,

5

361

---

100-02,

228-30)

.

Cost studies have concluded that the cost of

leaf collection

is moderate

($2.58 per family per year in Detroit

in 1967,

R.68), and that the cost of such collection is offset more

than three to one by the benefits of reducing pollution,

even

without considering either health effects or the possible benefits

of mulching

(Ex.

11)

Thus, we have concluded that there

is no excuse for leaf

burning in municipalities.

At the Agency’s request, however, we

have allowed a grace period until the middle of 1972 for people with-

out access

to

a refuse collection service.

At the other end of the spectrum we are persuaded that the costs

of alternative disposal methods are likely to be significantly high-

er because of low population density and that,

in contrast to the

overwhelming nuisance created even in rural areas by salvage or

garbage burning, the burning of relatively small quantities of

leaveE.,

weeds and other landscape refuse or paper and the like, at irregular

intervals on the premises on which they are generated, will cause

relatively little harm

(R.

105-06,

168-76)

.

We limit this exception

to non-commercial and farm refuse and specifically forbid the burning

of garbage.

We think industrial and commercial concerns, other than

farms, which are relatively remote, ought to bear the cost of pro-

viding for more acceptable means of disposal.

In the case of farms

we allow burning, but only

if

no economic alternative

is available.

It is therefore desirable in this case,

as authorized by

Section 27 of the Act,

to make different provisions for different

parts of the State in terms

of. population density.

It

is obvious-

ly impossible to draw a scientific line to separate with logical

precision those cases in which it is and is not acceptable to burn

landscape refuse; one is reminded of the necessity for choosing

a somewhat arbitrary voting age.

We believe the distinction drawn

is an appropriate one that will be easy

to administer and to under-

stand.

A word of caution

is in order as to

the

disposition of leaves.

We have some reservations about the spreading practice of placing

leaves

in plastic bags for collection.

Plastic bags are relative-

ly nondegradable and 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 (R.l35,139).

We are not today outlawing

the

use of plastic for

this purpose, since the issue is not before us, but we wish to warn

people to take care that in avoiding one environmental problem they

do not create another.”

IT

IS SO ORDERED.

I, Christan Moffett, Clerk of the Pollution Control B~~rd,certify that

the above Order of Modification was adopted on the ~

day of Septem-

ber,

1972, by a

vote of

~/

to p

5

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