CLEF?K’S OFFICE
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
JUN
022004
IN
THE
MATTER OF:
PROPOSED AMENDMENTS TO REGULATION OF
PETROLEUM LEAKING UNDERGROUND STORAGE
TANKS (35 Iii. Adm. Code 732)
)
STATE OF ILLINOIS
POIt~tj~~Control Board
)
R04-22
)
(Rulemaking
-
Land)
)
)
IN THE MATTER OF:
PROPOSED AMENDMENTS TO REGULATION OF
PETROLEUM LEAKING UNDERGROUND STORAGE
TANKS
(35
Ill. Adm. Code 734)
)
)
R04-23
)
(Rulemaking
-
Land)
)
)
NOTICE OF FILING
Dorothy Gunn, Clerk
Illinois Pollution Control Board
James R. Thompson Center
100 W. Randolph, Suite 11-500
Chicago, Illinois 60601-3218
SEE ATTACHED SERVICE LIST
Marie Tipsord
Illinois Pollution Control Board
James R. Thompson Center
100 W. Randolph, Suite 11-500
Chicago, Illinois 60601-3218
PLEASE TAKE NOTICE that I have today filed with the Office of the Clerk of
the Pollution Control Board the Response of the Consulting Engineers Council of Illinois
to the Illinois Environmental Protection Agency’s Amended Motion for Emergency
Rules, a copy of which is herewith served upon you.
Respectfully submitted,
Daniel J. Good~iJi,P.E.
SECOR International, Incorporated
400 Bruns Lane
Springfield, Illinois 62702
(217) 698-7247
Date: June 1, 2004
CERTIFICATE OF SERVICE
I hereby certify that the attached Response of the Consulting Engineers Council of
Illinois to the Illinois Environmental Protection Agency’s Amended Motion for
Emergency Rules will be served on the individuals on the attached Service List by
placing a copy in an envelope addressed to the address shown with first class postage
affixed and mailing prior to 5:00 p.m. on June 2, 2004.
Daniel J. Goodwi~P.E.
RECE~VE~
CLERK’S OFFICE
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
JUN 02
2004
STATE OF ILLINOIS
Pollution Control Board
IN THE MATTER OF:
)
)
R04-22
PROPOSED AMENDMENTS TO REGULATION OF
)
(Rulemaking
-
Land)
PETROLEUM LEAKING UNDERGROUND STORAGE
)
TANKS
(35
Ill. Adm. Code 732)
)
IN THE MATTER OF:
)
)
R04-23
PROPOSED AMENDMENTS TO REGULATION OF
)
(Rulemaking
-
Land)
PETROLEUM LEAKING UNDERGROUND STORAGE
)
TANKS (35 Ill. Adm. Code 734)
)
RESPONSE OF THE CONSULTING ENGINEERS
COUNCIL
OF ILLINOIS TO
THE ILLINOIS ENVIRONMENTAL PROTECTION AGENCY’S
AMENDED MOTION FOR EMERGENCY RULES
The Consulting Engineers Council of Illinois (“CECI”) hereby responds to the
Illinois Environmental Protection Agency’s Amended Motion for Emergency Rules as
follows:
1. On May 17, 2004, the Illinois Environmental Protection Agency (“Agency”)
filed its Amended Motion for the Adoption ofEmergency Rules, following discussions
with interested groups, including CECI, of its original Motion to Adopt Emergency
Rules.
2. CECI supports the Agency’s amended motion and recommends that the
Pollution Control Board adopt the Agency’s amended proposal at its next meeting.
3. It is CECI’s view that the subject proposal will serve satisfactorily as an
interim guide for the Agency’s decision-making on LUST budgets and reimbursement
requests until the onging process for adoption of revised permanent rules is carried to
completion.
4. While there are some aspects of the subject proposal CECI believes could be
improved, we believe it is important to adopt interim rules as soon as practicable, rather
than leave the Agency without the guidance it says it needs. Therefore, CECI prefers to
pursue further refinements as part of the permanent rules, and will do so as the hearings
continue.
5.
CECI believes the Board can appropriately adopt the Agency’s amended
proposal as emergency rules because it is in the public interest that the Agency be given
formal guidelines for determining reasonableness of LUST costs for reimbursement
purposes, and that those guidelines be known to all interested parties.
R p~ctfullysubmitted,
Daniel J. Goo*in, P.E.
Vice President
Consulting Engineers Council ofIllinois
June 1, 2004
