ORIGINAL

BEFORE

THE ILLINOIS POLLUTION

CONTROL BOARD

ADMINISTRATIVE

CITATION

RECEIVED

CLERK’S OFFICE

COUNTY OF VERMILION, ILLINOIS,

)

AUG

012095

Complainant,

)

AC No.

CG—

j

~

v.

)

County

File No. 05-01

)

PHIL ROUSE,

)

)

Respondent.

)

PETITION

TO CONTEST

ADMINISTRATIVE

CITATION

Phil Rouse, the

Respondent

to the above referenced proceeding,

files

this Petition pursuant

to Section

108.204 of Title

35 of the Illinois

Administrative

Code

Procedural Rules, and respectfully

responds as follows

to the allegations of the Administrative

Citation that

was served upon him on

or about July

1,

2005, in the

above referenced proceeding:

JURISDICTION

He admits the allegations of the “Jurisdiction” section of said

Administrative

Citation.

FACTS

1.

He

admits

the

allegations of paragraph

1

of the “Facts”

section of

said Administrative

Citation.

2.

He contests the allegations of paragraph 2 of the

“Facts” section of

said Administrative

Citation that the subject property

“is operated

as an

unlicensed open dump”, for the reason that he has never caused or allowed

said property to be operated

as an

open dump.

3.

He admits the allegations of paragraph

3

of the “Facts” section of

said Administrative

Citation.

---

VIOLATION

He contests all of the allegations of the “Violation” section of said

Administrative

Citation,

for the reason that

he has never been responsible

for

conducting an unlicensed open dump

at the subject address.

CIVIL PENALTY

He contests all of the allegations of the

“Civil Penalty”

section of said

Administrative

Citation,

for the reason that

he contests the allegations in

said Citation that

he

is operating or responsible

for conducting an unlicensed

open dump.

Dated:

July

26,

2005.

__________________________

Phil Rouge, Respondent

Bruce Meachum, Attorney for

Respondent

110

N. Vermilion St.

Danville,

IL 61832

Telephone:

217-442-1390

Certificate of Service

I hereby certify that

on JulyaQ,

2005,

I served a copy of the foregoing

Petition upon

the

Office of the State’s Attorney of the

County of Vermilion,

Illinois,

by

depositing same in the United States mail, with

postage prepaid,

in an envelope addressed

as follows:

Charles

D. Mockbee IV

Office of the State’s Attorney

7

N. Vermilion St.

Danville,

IL 61832

Bruce Meachum, Attorney

for Respondent