FHCE
    C
    ion Mate~s
    Recy~mg
    Association
    ~
    630/585
    7530
    faK 630/585
    7593
    )
    0~’
    To:
    Illinois Pollution Control Board
    RE:
    Case AS
    2004-002
    N ~
    D
    The CMRA is a 501c3 non-profit organization that promotes the recycling of construction and
    demolitioh (C&D) materials. Included in that purview are asphalt shingles, which hold
    promise
    as one ofthe more recyclable
    materials in construction and
    demolition activity. Proof ofthat
    comes from the website we developed
    under a grant from US EPA,wyshjnglerecycling.org.
    Indeed, that agency, as well as most state environmental agencies, and
    virtually all recycling
    professionals, consider us the leading experts on recycling
    C&D materials, especially asphalt
    shingles.
    It is with
    great interest we have followed Illinois EPA’s attempts to thwart Falcon Waste &
    Recycling’s plans to recycle asphalt shingles. No other state in the union has ever questioned that
    the processing of this manufacturer’s waste is a safe, environmentally friendly activity, or that
    the activity should fall under their regulations regarding waste. It is obviously
    recycling. In fact,
    a look
    at Illinois recycling statutes verify this: “any process by which materials that would
    otherwise be disposed of or discarded are collected, separated or processed and returned to
    the
    economic mainstream in the form of materials or products...”
    But it doesn’t take a recycling professional to realize what Falcon proposes to
    do
    is recycling,
    and only the first step toward making Illinois
    more environmentally friendly. One suspects there
    is
    more to the IEPA opposition thanjust a grasp to maintain control of another material. Also,
    any
    company that tries to recycle shingles in this state knows the IEPA won’t give them
    a permit
    for the activity. Why? For one
    thing, the landfill company currently accepting the waste will be
    out probably nearly $1
    million annually in disposal costs if the IKO shingle material is diverted
    to
    a recycling activity, and no landfill company will
    let that go easily. Landfill lobbyists camp in
    the IEPA Springfield office, and only
    someone naïve or from another state would think there is
    not pressure being brought to bear on IEPA
    in this matter. In addition,
    whatever governmental
    entity—state, county, or local—receiving a host fee from the disposal of that material is
    going to
    fight to stop the flow of the material to anotherjurisdiction.
    We deal with virtually all
    state environmental agencies
    across the country, in
    addition to the US
    EPA and innumerable local
    agencies. Illinois EPA is probably the most detrimental to recycling
    and
    reuse ofall the state environmentally agencies, and sadly is an embarrassment to all
    of us
    residents working to improve the environment. We hope IEPA will come to its
    senses, quit
    grasping at the straws outlined in its
    response to the petitioner’s brief, and join the rest of the
    country into supporting the environmental benefits of shingle recycling.
    William Turley
    Executive Director

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