BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
~
~ P VF
1~
ILLINOIS ENVIRONMENTAL
)
~
PROTECTION AGENCY,
)
)
EPA No.
567-04-AC
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072005
Complainant,
)
SThTE OF ILUNOIS
Po:iution Control
Board
v.
)
)
NORTHERN ILLINOIS
)
SERVICE COMPANY,
)
Respondent.
)
1’
APPEARANCE
I hereby file my appearance in this proceeding, on behalfof NORTHERN ILLINOIS
SERVICE COMPANY, Respondent.
NORTHERN ILLINOIS SERVICE COMPANY,
Respondent,
By Peter DeBruyne, P.C.
B~flT~
Peter DeBruyne, Its Attorney
Peter DeBruyne
Peter DeBruyne, P.C.
838 North Main Street
Rockford,IL 61103
Telephone (815) 964-3810
1
CERTIFICATE OF SERVICE
I hereby certify that I did on the 4th day of February, 2005 by regular mail, with postage
thereon fully prepaid, by depositing in a United States Post Office Box a true and correct copy of
the foregoing Appearance on the following:
Illinois Environmental Protection Agency
Division ofLegal Counsel
1021 North Grand Avenue East
P.O. Box 19276
Springfield, IL 62794-9276
Peter DeBruyne
2
PEC~VL~DCLERK’S
OFFICE
BEFORE THE ILLiNOIS POLLUTION CONTROL BOARD
FEB 07 2005
ILLINOIS ENVIRONMENTAL
)
STATE OF ILLINOIS
PROTECTION AGENCY,
)
PoHut~onContro’ BO~r~
)
EPA No. 567-04-AC
Complainant,
)
0
NORTHERN ILLINOIS
)
I
SERVICE COMPANY,
)
)
Respondent.
)
NOTICE OF FILING
TO: Illinois
Environmental Protection Agency
Division of Legal Counsel
1021 North Grand Avenue East
P.O. Box 19276
Springfield, IL 62794-9276
PLEASE TAKE NOTICE that I have filed with the Office of the Clerk ofthe Pollution
Control Board the Petition for Review of NORTHERN ILLINOIS SERVICE COMPANY,
Respondent herein, a copy of which is herewith served upon you.
NORTHERN ILLINOIS SERVICE COMPANY,
Respondent,
By Peter DeBruyne, P.C.
By
)
~
Peter DeBruyne, Its Attorney
Peter DeBruyne
Peter DeBruyne, P.C.
838 North Main Street
Rockford,IL 61103
Telephone
(815)
964-3810
CERTIFICATE OF SERVICE
I hereby certify that I did on the 4th day of February, 2005, by regular mail, with postage
thereon fully prepaid, by depositing in a United States Post Office Box a true and correct copy of
the foregoing Notice ofFiling on the following:
Illinois Environmental Protection Agency
Division of Legal Counsel
1021 North Grand Avenue East
P.O. Box 19276
Springfield, IL 62794-9276
eter DeBruyne
RECE~VF~DCLERK’S
OFFICE
BEFORE THE ILLiNOIS POLLUTION CONTROL BOARD
FEB 072005
ILLINOIS ENVIRONMENTAL
)
STATE OF ILUNOIS
PROTECTION AGENCY,
)
Po~lutionControl
Board
)
EPA No. 567-04-AC
Complainant,
)
~..
v.
)
NORTHERN ILLiNOIS
)
SERVICE COMPANY,
)
)
Respondent.
)
PETITION FOR REVIEW
NORTHERN ILLINOIS SERVICE COMPANY, Respondent, herein, by its attorney,
Peter DeBruyne, P.C., hereby Petition for Review of the Administrative Citation for the
following reasons:
1. Respondent contests violation (1) “that Respondent caused or allowed the open
dumping of waste in a manner resulting in litter, a violation of Section 21 (p)(1) ofthe Act, 415
ILCS
512l(p)(l)
(2002)” because the material referred to in part ofthe Kaare Jacobsen report is
trees which is not “litter.” “Litter” refers to material oflittle or no value and trees which are cut
properly do have value. The examples oflitter set forth in the Litter Control Act do not mention
trees as an example oflitter in this Act and should provide guidance to the Board.
2. Wherefore, Respondent, by its attorney, Peter DeBruyne, P.C. respectfully pray that
violation (1) be dismissed with prejudice.
NORTHERN ILLINOIS SERVICE COMPANY,
Respondent,
By Peter.D~ruyne,P.C.
4’
I
By
Peter DeBruyne, Its Attorney
1
Peter DeBruyne
Peter DeBruyne, P.C.
838 North Main Street
Rockford,IL 61103
Telephone (815) 964-3810
CERTIFICATE OF SERVICE
I
hereby certify that I did on the 4th day ofFebruary, 2005, by regular mail, with postage
thereon fully prepaid, by depositing in a United States Post Office Box a true and correct copy of
the foregoing Petition for Review on the following:
Illinois Environmental Protection Agency
Division ofLegal Counsel
1021 North Grand Avenue East
P.O. Box 19276
Springfield, IL 62794-9276
I
J
~
?eter DeBruyne
2
