cLERK~SD~~-
--
BEFORE THE
ILLINOIS POLLUTION-CONTROL BOARD
~1UG6 2003
PEOPLE OF THE STATE OF
)
STATE
IL
ILLINOIS,
)
h7C~ontro/B
)
Complainant,
)
)
V.
)
PCB00-180
)
JACOBS ENERGY CORPORATION
)
Respondent.
NOTICE OF FILING
To:
Roland A. Eckert
Law Office of Roland A. Eckert, P.C.
222 East Wisconsin Avenue, Suite 201
Lake Forest, IL 60045
PLEASE TAKE NOTICE that on this date I mailed for filing with the Clerk of the Pollution
Control Board of the State of Illinois, COMPLAINANT’S RESPONSE TO REQUEST FOR
MODIFICATION OF ORDER, a copy of which is attached hereto and herewith served upon you.
Respectfully submitted,
PEOPLE OF THE STATE OF ILLINOIS
LISA MADIGAN,
Attorney General of the
State of Illinois
MATTHEW J. DUNN, Chief
Environmental Enforcement/Asbestos
Litigation Division
BY:_____________________
THOMAS DAVIS, Chief
Assistant Attorney General
Environmental Bureau
500 South Second Street
Springfield, Illinois 62706
217/782-9031
Dated: August 1, 2003
CERTIFICATE OF SERVICE
.1 hereby certify that I did on August.1,2003, send by First Class Mail, with postage -
thereon fully prepaid, by depositing in a United States Post Office Box a true and correct copy
of the following instruments entitled NOTICE OF FILING and COMPLAINANT’S RESPONSE
TO REQUEST FOR MODIFICATION OF ORDER
To:
Roland A. Eckert
Law Office of Roland A. Eckert, P.C.
222 East Wisconsin Avenue, Suite 201
Lake Forest, IL 60045
and the original and ten copies by First Class Mail with postage thereon fully prepaid of the
same foregoing instrument(s):
To:
Dorothy Gunn, Clerk
Illinois Pollution Control Board
State of Illinois Center
Suite 11-500
100 West Randolph
Chicago, Illinois 60601
A copy was also sent L~yFirst Class Mail with postage thereon fully prepaid
To:
Brad Halloran
Hearing Officer
Illinois Pollution Control Board
100 West Randolph Street
Suite 11-500
Chicago, IL 60601-3286
Thomas Davis, Chief
Environmental Bureau
Assistant Attorney General
This filing is submitted on recycled paper.
RECEIVED
BEFORE THE
ILLINOIS POLLUTION CONTROL BOARD CLER~~S
OFFI(~r
PEOPLE
OF THE
STATE
OF ILLINOIS,
)
AUG
6 2003
-
Complainant,
)
Pollution
Control
Board
VS.
)
No. 00-180
)
(Enforcement)
JACOBS ENERGY CORPORATION,
)
)
Respondent.
)
COMPLAINANT’S RESPONSE TO REQUEST FOR MODIFICATION OF ORDER
Complainant, PEOPLE OF THE STATE OF ILLINOIS, by LISA MADIGAN, Attorney
General of the State of Illinois, hereby concurs with the Respondent’s Request for Modification
of Order, and states as follows:
1.
The Proposal for Settlement explicitly sets forth a negotiated schedule for the
payment of the agreed penalty.
2.
The Board may accept, suggest revisions in, or reject the proposal for
settlement, but has no authority to unilaterally alter the agreed upon terms and conditions.
3.
The parties assume that the payment provision in the July 11, 2003, Order,
resulted from inadvertence rather than any disagreement with the negotiated schedule for the
payment of the agreed penalty.
WHEREFORE, Complainant respectfully agrees that this Board ought to modify its July
11,2003, Order.
Respectfully submitted,
PEOPLE OF THE STATE OF ILLINOIS,
LISA MADIGAN
Attorney General
State of Illinois
1
MATTHEW J. DUNN, Chief
Environmental Enforcement Division
BY:______________________
THOMAS DAVIS, Chief
Environmental Bureau
Assistant Attorney General
500 South Second Street
Springfield, Illinois 62706
217/782-9031
2