RcLER~s

OFF~C~ 618-452-5190

June

20, 2005

iU~~2?2~

Marie E. Tipsord

Hearing Officer

Illinois

Pollution Control Board

100 West Randolph, Suite 11-500

Chicago, IL 60601

RE:

Proposed Revisions to Leaking Underground Storage Tank Regulations

R04-22 and R04-23

Dear Ms.. Tipsord:

I am. wntmg to express my concerns m regard to revisions proposed by the Illinois

Environmental Protection Agency (IEPA) to regulations governing leaking underground

storage tani s (USTs).

.

.

.

As I’m sure you are aware, UST Owners and Operators are required by Illinois leaking

underground storage tank (LUST) regulations to satisfy a financial responsibility

adequate to cover

all

costs of environmental clean-up incurred in response to a leaking

UST. Like most Illinois UST Owners and Operators, I rely on the Illinois LUST Fund to

satisfy this financial responsibility for costs exceeding my deductible. I consider the

deductible itseff to be a considerable sum of money. If there is even the slightest

potential that the revisions proposed by the IEPA will increase the amount of non-

recoverable costs from the LUST Fund beyond my deductible, I am not supportive of

these revisions. Iffinois UST Owners and Operators contribute to the LUST Fund for the

very specific purpose of satisfying our financial responsibility.

I will not support

regulations that will ultimately result in increasing the costs I must incur in order to

satisfy this financial responsibility.

I must rely on environmental professionals to assist me in my effort to comply with

LUST regulations. .1 must also rely upon the Illinois LUST Fund to ensure the cost of

professional assistance is recovered m full Bemg able to do so is critical to my financial

stability. I will not support prOpOsed revisions that cOuld potentially result in my ability

to recover only a portion ofthe costs I incur as a result of seeking professional assistance

to comply with LUST regulations. This is simply not a financial risk I am willing to take.

Spectrulite Consortium Inc.,

1001

College Street, P.O. Box 258, Madison, IL 62060

---

PE CTRULITE

618-452-5190

Page 2

—

I recognize the need for cost containment. However, this is an extremely important issue

that

must

be evaluated thoroughly and addressed responsibly. In the Illinois Pollution

Control Board (IIPCB) decision to move to First Notice, you acknowledged that the IEPA

proposed revisions were not well supported by scientific or statistical data. If the

proposed revisions are not well supported by scientific or statistical data, then it appears

to me that a thorough and responsible evaluation has not been performed. I fear that the

proposed revisions to provide cost containment measures will have a negative financial

impact on me and other Illinois UST Owners and Operators. I strongly urge the IPCB to

demand that

any

proposed revision be adequately supported by scientific and statistical

data to ensure the intended purpose (i.e., cost containment) is achieved without posing

unnecessary financial threats to Illinois UST Owners and Operators. In addition, this

information must be fully-disclosed and available to the public.

Thank you for your consideration.

Sincerely,

SPECTREJLITE CONSORTIUM, INC.

~

4. ~

Chris A. Barnes

President

NC.

Spectrulite Consortium Inc., 1001 College Street, P.O. Box 258, Madison, IL 62060