RECE~VE~
March 17,2005
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I\IIn\IL
STATECERK~OFFK~EOF ILLINOIS
ULI
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Pollution Control Board
Clerkâs Office
Illinois Pollution Control Board
100 W Randolph Street, Suite 11-500
Chicago, IL 60601
Re:
#R04-22/23
Proposed 732/734 LUST Regulation Changes
To Whom It May Concern:
As an interested party in the proposed LUST regulation changes to Parts 732 and
734,
I
would like to request that a minimum of one additional hearing be held. To date, an
adequate delineation of tasks associated with subpart H pay items has not been made.
This results in a far too open-ended scope ofwork which places undue financial liability
on tank owners. Additionally, it concerns me to see such gross misconduct by
administrators to neglect to encompass and accept facts and data provided by professional
personnel with real world experience. It also concerns me that costs and activities
endorsed by the regulatory community blatantly disregard sound mathematical (i.e.
statistics) and engineering principles. Therefore, I suggest that the following items be
discussed:
Statistical analyses ofhistorical reimbursement costs should be conducted
to ensure that Subpart H maximum payment amounts are inclusive of
representative projects and an appropriate sample set size, and;
Scopes ofwork should be discussed for each pay item.
As a citizen of Southern Illinois, I have also been unable to attend any hearings to date
since they have been held in the northern part ofthe state, therefore I am requestingthat a
downstate hearing be held somewhere around Marion or Mount Vernon. Ifyou have any
questions please feel free to contact me at (618)437-5184.
si~~~/)~
DaitKing
306 West
3rd
Street
ma, Illinois 62846