IN THE MATTER OF :
MICHAEL A. PETROSIUS and DARLA
)
G. PETROSIUS
)
Complainants,
)
v.
)
No . PCB 04-36
(Citizen's Enforcement
ILLINOIS STATE TOLL HIGHWAY
)
Noise)
AUTHORITY
)
Respondent .
)
NOTICE OF FILING
TO: Carol Webb
Victor Azar
Hearing Officer
Special Ass't Attorney General
Illinois Pollution Control Board
Illinois Tollway
1021 N . Grand Avenue
2700 Ogden Avenue
Springfield, Illinois 62794
Downers Grove, Illinois 60515
PLEASE TAKE NOTICE that on April 6, 2006, Mike and Darla Petrosious,
through their attorney Scott Dworschak, filed with the Office of the Clerk of the
Illinois Pollution Control Board, an original and ten copies of the attached Brief, a
copy of which is served, upon you . Pursuant to 35 III . Admin
. Code 101 .103(d)
this filing is submitted oh recycled paper
.
BEFORE THE POLLUTION CONTROL BOARD
OF THE STATE OF ILLINOIS
Scott Dworschak
1343 North Wells
Chicago, Illinois 60610
312-944-8200
THIS FILING SUBMITTED ON RECYCLED PAPER
Mike
PETROSIUS~
i
By their Attorney
RECEIVED
CLERK'S OFFICE
APR 0 6 2006
Pollution
STATE OF
Control
ILLINOIS
Board
Foe
,E IVIED
APR 0 6 2006
Pollution
STATE OF
Control
ILLINOIS
Board
MICHAEL A
. PETROSIUS and DARLA )
G . PETROSIUS
)
Complainants,
)
V .
)
No. PCB 04-36
(Citizen's Enforcement
ILLINOIS STATE TOLL HIGHWAY
)
Noise)
AUTHORITY
)
Respondent .
)
COMPLAINANTS BRIEF
Complainants, Michael and Darla Petrosius, files this brief in support of
their Complaint against the Illinois State Toll Highway Authority (hereinafter
referred to as the "Tollway")
. Complainants seek an order from the Illinois
Pollution Control Board (hereinafter referred to as the "Board") finding that the
noise emanating from Interstate 1-294 in LaGrange, Illinois is in violation of the
numerical noise emissions promulgated by the Board and creates an
unreasonable interference with the Complainants lives, and also those of other
nearby residents
. Complainants further seek an order commanding that the
Tollway take remedial actions to mitigate the noise as soon as foreseeable
.
I .
BACKGROUND
On September 9, 2003, Complainants filed a complaint against the
Tollway seeking an order that the Tollway cease violating the provisions of the
Illinois Environmental Act
. This action was taken following unsuccessful attempts
BEFORE THE POLLUTION CONTROL BOARD
OF THE STATE OF ILLINOIS
IN THE MATTER OF :
1
by Complainants requesting the Tollway take steps to mitigate the noise from the
Tri-State Tollway, Interstate 294 (hereinafter "Tri-State Tollway") reaching the
adjacent residential area
. Complainants also requested that the Tollway be
ordered to undertake specific remedial actions, including the installation of
additional noise abatement wall in the area to alleviate the excessive noise from
the Tri-State Tollway .
Commencing on December 5, 2005 the Board conducted a two-day
hearing on this matter during which testimony was presented from the
Complainants, as well as, from a sound expert retained by Complainants
.
Several local residents also presented public comment either in person, or by
letter, regarding the effects of the roadway noise on their daily living conditions
.
Testimony from an expert retained by the Tollway, and other Tollway officials,
was also presented at the Hearing
.
II .
FACTS
The Illinois State Toll Highway Authority owns and operates a system of
tollroads in Illinois under the provisions of the Toll Highway Act 605 ILCS 10/1-
35
. Toll revenues generated from motorists accessing the tollway system are
then used to finance, operate, and improve the toll road network
. The specific
interstate in question in this matter, the Tri-State Tollway, is one of these toll
roads .
The Tri-State Tollway was originally constructed in the late 1950's,
adjacent to the residential property in question
. Since the initial construction, the
Tri-State Tollway has been expended from four to eight traffic lanes in the area
.
2
In 1993, a new traffic interchange was constructed on the Tri-State Tollway at
75`h Street near the Petrosius residence .
The Complainants purchased the property in 1995 (Transcript Volume I at
15, hereinafter "Tr . Vol . I, at
") .
In fact, the Complainants and the Tollway
share a common property line . (Tr. Vol . I at 15)
. Complainants assert that the
excessive noise generated by vehicles traveling on the Tri-State Tollway has
disrupted and interfered with the lives of the Complainants, their family, and
nearby residents on a continuing basis . (Tr
. Vol . I at 30-4, 43, 80-81,83-86, 89)
As a result of the excessive roadway noise reaching his property, Mike
Petrosius made contact with Illinois Tollway representatives in order to seek
some type of relief . (Tr. Vol
. I at 38-42) Specifically, Petrosius requested that
additional noise barrier wall be installed in the area in order to reduce highway
noise reaching the property, and that of his neighbors
. (Tr. Vol . I at 44)
Unfortunately, despite numerous meetings with Tollway officials, the
Tollway refused Complainants' request to install additional noisewall in the area
.
(Tr. at 43) Petrosius continued to investigate the matter, including purchasing a
noise meter in order to determine the specific level of noise reaching his
property . (Tr. Vol
. I at 36) Due to the Tollway's refusal to comply with Petrosius'
request, the Complaint was filed .
At the Hearing, the Petrosius' presented testimony of how the noise from
the Tollway effects their daily lives . (Tr. Vol . I at 31-4, 43, 80-6, 89) Testimony
was also given from a noise expert stating that the sound levels measured from
the Tri-State Tollway reaching Complainants property violated the Illinois
3
numerical noise emission standards . (Tr
. Vol . II at 100 ; Complainants' Exhibit
18)Additionally, the noise expert testified that the noise levels constituted an
unreasonable interference to the Complainants daily lives
. (Tr. Vol . II at 106 ;
Complainant's Exhibit 18) Importantly, testimony presented by a noise expert
retained by the Tollway also depicted noise levels exceeding Illinois numerical
noise emission standards. (Tr. Vol . II at 198-201
; Respondent's Exhibit 18) .
The testimony of Complainants, and their expert witness, was not
reasonably discredited on cross-examination, nor did the Tollway present any
rebuttal testimony as to the noise effects upon the Complainants and their
neighbors, beyond that given by their own expert witness
. Further, the Hearing
Officer found all the testimony to be credible, and thus, the Board must accept
their testimony.
Ill . ARGUMENT
The excessive and unreasonable noise generating from the Tri-State
Tollway violates the numerical standards set forth at 35 III
.Admin
. Code §
901 .102, and constitutes a nuisance which is prohibited by 35 III
. Admin
. Code §
900 .102 .
A.
Numerical Violations
The evidence presented at the Hearing clearly illustrates that the noise
emanating from the Tri-State Tollway violates the numerical sound emission
standards set forth in 35 III
.Admin . Code § 901
.102, and constitutes a nuisance
which is prohibited by 35 III .Admin
. Code § 900 .102
.
No person shall cause or allow the emission of sound beyond the
boundaries of his property, as property is defined in Section 25 of
4
the
Illinois Environmental
Protection Act, so as to cause noise
pollution in Illinois, or so as to violate any provision of this
Chapter .
Also, Section 24 of the Environmental Protection Act provides that
:
"No person shall emit beyond the boundaries of his property any
noise that unreasonably interferes with the enjoyment of life
or with
any lawful business activity, so as to violate any regulation
or
standard adopted by the Board under this Act ." 415 ILCS 5/24
(2002)
The Board's Land Based Classification Standards (LBCS) describe
several types of land use types
. The land classification of a site depends
on the use of the property . Residential property is classified
as Class A
land . 35 III . Admin
. Code Subtitle H, Appendix B .
As a single family
residence, the home at 7335 Maridon Road can clearly be classified
as
Class A land . The Complainants noise expert testified that his
interpretation of the LBCS would classify the Tri-State Tollway
as Code
4130, with a designation of Class C under 35 IAC 901
land class . (Tr . Vol
II at 125
; Complainants Exhibit 18, page 2)
Expert testimony at the Hearing demonstrated that the noise
level
is 19 decibels above the Board regulations for C class land to A class
land . (Tr . Vol . II at 125
; Complainants Exhibit 18, page 7)
. Importantly,
testimony from Respondent's noise expert also depicted noise
levels
above Board regulations extending past Respondent's . (Tr
. Vol . II at 198-
201 ; Respondents Exhibit 18, page 8)
.
5
Therefore, evidence provided by both parties noise experts
demonstrates that the Tollway property emits noise exceeding levels
established by the Board .
B.
Nuisance Violations
The Complaint also alleges that the noise from the Tollway constitutes a
nuisance violation of 35 III
.Admin . Code § 900 .102
. A primary issue in this
allegation is whether the noise causes interference with the Complainants'
enjoyment of life. D'Souza v
. Marraccini, 1996 III
. ENV LEXIS 510 !2 (PCB 96-
22, May 2, 1996)
. In order to constitute a interference, the noise must
objectively affect the complainants' life
. Id .
At the Hearing, substantial evidence was presented depicting how the
noise from the Tollway interferes, and adversely affects, the Complainants lives
.
Complainants testified as to the constant loud noises emanating from the Tollway
(Tr. Vol . I at
. 29-30, 32, 80) Testimony was presented at the Hearing
demonstrating how the noise from the Tollway limited Complainants use of their
yard, continuously disrupted their sleep, precluded them from keeping their
windows open and increased their reliance upon their air conditioner
. (Tr. Vol . I
at 31-5, 43, 80-6, 89) Specifically, testimony was presented at the Hearing that
the noise from the Tollway interfered with the lives of the Complainants in the
following manner
:
1 .
Mike Petrosius testified that the Tollway noise effects the use of his
outdoor property (Tr . Vol
. I at 31,33), and adversely effects his
sleep. (Tr
. Vol
. I at 32) The sleep disturbance induced Petrosius to
seek professional medical assistance . His physician prescribed
multiple sleep assistance medications as treatment . (Tr. Vol . I at
32) Mr. Petrosius also testified as to how the noise limits his ability
to entertain guests at the property, and that the excessive noise
affects Complainants in that they " . . . seem to live a different way of
life than other people." (Tr . Vol . I at 43)
2 .
Darla Petrosius provided testimony depicting that the
Tollway noise limited her use of the property (Tr . Vol . I at
83) and continuously and adversely affected her sleep
"most nights" ; and "It's a very rare night that I'm not awakend
by some sort of significant noise (Tr . Vol . I at 85); and
induced her to spend time in portions of the home farthest
from the Tollway (Tr. Vol . I at 84) . Mrs
. Petrosius also
testified as to her belief that the Tolway noise has adversely
affected her quality of life (Tr . Vol . I at 89).
3 .
The Complainants also have to two minor children
.
Testimony was provided that the noise also adversely effects
their lives as well by limiting their use of the property . (Tr.
Vol . I at 86-7) .
4.
Public comment at the Hearing was presented by Krista
Dolgner, who lives adjacent to the Complainants . Dolgner
spoke how the noise impacts her everyday life (Tr . Vol . I at
11) .
7
5 .
Public comment at the Hearing was presented by Pat Biegel,
who also lives adjacent to the Complainants
. Biegel spoke
as to her inability to open her windows due to the noise, and
how the use of her outdoor property has been adversely
affected . (Tr
. Vol . I at 13-4).
The noise from the Tollway clearly interferes with the lives of the
Complainants . The Petrosius also believe that the noise causes an
unreasonable interference with their lives . The Board has prescribed a list of
factors which need to be considered in determining whether a noise causes an
unreasonable interference . These factors are :
1 .
Character and degree of injury or interference
;
2 .
Social or economic value of the source ;
3.
Suitability or unsuitability of the source ;
4 .
Technical practibility and reasonableness of control,
and ;
5 .
Subsequent compliance .
415 ILCS 5/33(c) . The following addresses each factor .
1 .
Character and Degree of Injury or Interference
The Board is required to consider the character and degree of
interference caused by noise originating from the Tri-State Tollway . The
Board must consider whether the noise substantially and frequently
interferes with a lawful activity, beyond minor trifling annoyance or
8
discomfort
. See Furlan v . University of Illinois School of Medicine, 1996
III . ENV. LEXIS 713, 10 (PCB 93-15, Oct 3, 1996)
.
Testimony at Hearing from the Complainants clearly establishes
that noise from the Tollway continuously disrupts their lives . (Tr. Vol . I at
43, 89 ) Complainants testimony also reveals the extent to which the
noise interferes with their lives (Tr . Vol . I at 31-5, 81-9)
Testimony was also presented from the Complainants' qualified
noise expert, Greg Zak, concerning the nuisance level of the noise
generated by Respondents toll road . (Tr. Vol
. II at 95-6, 100-07) Zak has
performed over 60 noise studies, (Tr. Vol
. II at 103), and testified that the
noise readings were the highest he had measured in since becoming a
private consultant . (Tr. Vol . II at 97)
A detailed noise study prepared by Zak was also presented at
Hearing (Complainants Exhibit 18) . In D'Souza v
. Marraccini, 1996 III .
ENV .LEXIS 510, at 15 (PCB96-22, May 2, 1996), the Board ruled that it
can look to measurements as guidance concerning the character and
degree of the noise from the site .
Noise readings taken at the site pursuant to Board regulations
depicted that noise levels experienced at the residential property
exceeded Board criteria from 2 to 19 decibels depending on frequency
.
(Tr. Vol
. II at 100, Complainant Exhibit 18, pg
. 7) Zak testified that noise
impacts at this level would adversely affect the Complainants quality of life
9
due to sleep disruption and reduction in the use of their yard. (Tr. Vol . II at
106, Complainant Exhibit 18, pg . 8)
It appears that one of the Tollway's principal defenses is that the
Board rules do not apply to them . (Tr . Vol . II at 247) . Nonetheless, there
can be little doubt that the noise levels reaching Complainants property
cause significant and frequent interruptions .
2 .
Social or Economic Value of the Source
Uncontroverted evidence, and testimony, was introduced at the
Hearing depicting the economic value of the entire Tollway system, and
the annual revenue derived from the Tri-State Tollway . (Tr. Vol . I at 160-
63 ; Complainants Exhibit 13) . There is no dispute that the Tollway
system, and the Tri-State Tollway in particular, provides economic value to
the area
.
However, this value should not run roughshod over the economic
value of the adjacent residential communities
. Clearly, the negative noise
impacts endured by the Complainants and their neighbors, effecting their
property values and the conduct of their daily lives, could be lessoned
.
Specifically, a commitment from the Respondent to substantially reduce
the noise that reaches adjacent residential areas .
3 .
Suitability or Unsuitability of the Tri-State Tollway to the
area.
Automobiles and trucks driving on the tollway system are the
primary source of the excessive noise experienced by Complainants
. (Tr.
10
Vol . II at 21) . Traffic on the tollway system is increasing and larger traffic
volumes tend to generate additional traffic noise . (Tr.
Vol . II
. at
77)
Additional traffic lanes have been subsequently added to the Tri-
State Tollway since its initial construction, most recently in the early
1990's (Tr. Vol . II . at 4-5) The additional pavement has contributed to a
fifty percent increase in traffic on the tollroad adjacent to the property in
question since 1988 . (Tr. Vol . II at 77 ; Complainants Exhibit 11)
The Respondent also constructed a new interchange at 75th Street
on the Tri-State Tollway in 1993, nearly adjacent to Complainants home .
(Tr. Vol . II at 10-11) The new interchange is a contributing factor towards
additional traffic on the Tri-State Tollway in the area . The interchange
also contributes to a higher proportion of truck traffic experienced in the
area as compared to the entire tollway system . (Tr. Vol . I at 192-93)
Respondent's ability to promote increased traffic volumes on the
Tollway have stretched the suitability of the adjacent residential area to
co-exist with the Tri-State tollroad operations and negatively impacted the
area residents .
4.
The Technical Practicability and Economic
Reasonableness of Reducing or Eliminating the Noise
Emissions From the Tri-State Tollway
.
Complainants do not seek the elimination of Tri-State Tollway
operations in these proceedings . (Tr. Vol . I at 46-7)
. Instead, they seek
a reduction in the roadway noise reaching the residential area . This
reduction can be accomplished through the installation of additional noise
II
mitigation, in the form of higher and longer noise barrier walls
. The
specific solution is further discussed in the proceeding Remedy section
.
It is important to note that Complainants have attempted numerous
noise mediation efforts since purchasing the residence
. These remedies
included
: seeking medical assistance in the form of prescription sleeping
aids
; adding more weather insulation to the home where possible
; the
purchase of a sound machine to assist with their efforts to sleep
; and the
planting of 30 trees adjacent to the tollroad
. All of these efforts were
intended to reduce, or reflect, the noise impacts upon the lives of the
Complainants .
(Tr. Vol . I at 32, 34-5) These efforts have not reduced
the noise penetration to an acceptable level .
C .
Remedy
Complainants request that the Tollway be ordered to cease and
desist violating numerical emissions standards set forth at 35 III
. Admin .
Code § 901
.102, and from violating the nuisance noise standards of 35 III
.
Admin . Code § 900 .102 .
Since the evidence clearly demonstrates a violation of IPCB
nuisance noise standards, the Complainants request the Tollway to
undertake substantive steps to address the excessive noise originating
form the Tri-State Tollway .
These changes would allow for the continued
unregulated operation of the Tollway system, while easing the impact to
nearby residents .
1 .
Construct Additional Noise Barriers
.
12
Complainants seek the installation of additional noise barriers in the
area in order to reduce the noise levels . (Tr. Vol . I at 44-7) The Board
has previously ordered the installation of noise barriers in order to
guarantee compliance with noise regulations . See Zarlenqa v .
Partnership Concepts (PCB No. 89-169,), and Thomas v. Carry
Companies (PCB 91-195) .
Complainants' noise expert, Greg Zak, testified that the installation
of additional noisewall at the site would significantly reduce the noise
impacts originating from the Tri-State Tollway . (Tr. Vol . II at 107-10) .
Specifically, it was recommended that a noise barrier wall of
approximately 18 feet in height, extending a quarter mile adjacent to the
property, be installed . (Tr. Vol . II at 112-3) . Zak also stated that the noise
barrier would also reduce noise reaching other residents in the area (Tr.
Vol . II at 116-18)
Respondents noise expert also agreed that additional noise
barrier wall would effect other homes in the area . (Tr. Vol
. II at 218) Many
of these residents either gave public comment at the Hearing or provided
subsequent written comment as to the noise affects on their lives .
2 .
The Existing Noise Barrier is Insufficient .
In the early 1990's, the Tollway installed noisewall barriers along
portions of the Tri-State Tollway . (Tr. Vol . II at 18-20) Partial noisewall
barriers were also installed adjacent to Complainants property at this
time . (Complainants' Exhibit 14) Unfortunately, this noise barrier wall has
13
been shown to be ineffective at reducing noise to Board criteria levels by
both parties noise experts
. (Complainants Exhibit 18, Respondents
Exhibit 18)
The existing noise barrier is inadequate for several reasons
. First,
uncontroverted evidence was presented depicting that sections of the
noisewall are of insufficient height to block line of sight of traffic operating
on the Tollway . (Tr. Vol
. II at 111, 216 ; Complainants Exhibit 5)
Restricting the line of sight from noise generator to receptor is critical to
achieving effective noise reduction . (Tr. Vol
. II 109, 124-5) Line of sight
also effects how the noise affects those individuals receiving it
. (Tr. Vol . II
at 217)
Tire noise generated by vehicles traveling on the on the Tollway are
a significant source of noise . (Tr.Vol
. II at 21, 96) Specifically, the current
noise barrier wall directly adjacent to Complainants home, allows for a
direct sight line to the Tri-State Tollway pavement
. (Tr. Vol
. II at 111) This
direct line of sight allows for an unrestricted stream of noise from the
Tollway to Complainants property
. The unrestricted noise consists of tire
noise, engine noise, jake brakes, and trucks hitting holes in the road
surface . (Tr. Vol
. II at 96) All of these specific sounds create noise levels
exceeding Board criteria
. (Complainants Exhibit 18, Respondents Exhibit
18)
Second, the existing noise barrier wall is not of sufficient length to
achieve adequate noise reduction
. Currently the noise barrier wall ends at
14
the end of Complainants property
. (Complainants Exhibit 16) However,
the Tri-State Tollway and the traffic noise generate on it, continues well
past this point . Thus, an avenue for noise penetration has been left open
.
Zak testified that an additional quarter mile of noise barrier wall installed in
this area would reduce noise levels reaching the residential area . (Tr. Vol .
II at 114)
Thus, providing additional height and length to the existing
noisewall would substantially reduce the noise levels reaching residential
areas adjacent to the Tollway .
3.
The Current Noise Barrier Wall was Incorrectly Installed
The Tollway hired a consultant (Versar, Inc
.) to assist them in
determining the height and location of noise barriers along the Tri-State
Tollway . (Tr . Vol
. II at 29) At the Hearing, evidence was presented
demonstrating that the existing noise barrier wall was not installed
pursuant to the recommendations provided by Respondent's consultant
.
Tr. Vol . II at 43-56 ; Complainants Exhibit 17)
. Specifically, the Tollway
consultant recommended that an 18 foot high noise barrier wall be placed
adjacent to the Complainants residence . (Tr. Vol
. II at 45) However, the
Tollway did not install an 18 foot high wall in this location (Tr
. Vol
. II at 52)
Instead, a barrier wall varying between 14 and 8 feet was constructed
.
(Tr. Vol
. I at 21, Complainants Exhibit 4)
. At Hearing, the Respondent
offered no uncontroverted evidence as to why the existing noise barrier
wall was constructed lower than recommended
. In fact, the Tollway's
15
consultant recommended a wall height matching that recommended by
Mr. Zak at the Hearing
. (Tr. Vol
. II at 113, Complainants Exhibit 17)
Constructing a higher wall is feasible
. Testimony was presented by
Respondent's own engineer, Mr
. Wagner, that noise barrier wall heights
up to 25 feet are feasible
. (Tr. Vol . II at 71-73)
Further, he testified
that the Tollway has previously installed noise barrier walls exceeding 18
feet
. (Tr. Id)
. Therefore, it is unknown as to why the noisewall installed in
this area did not match the previously recommended height
.
4.
The Tollway Has Previously Augmented Existing Noise
Barrier Walls
At the Hearing, evidence was presented depicting areas in which
the Respondent has augmented existing noise barrier walls
. (Tr . Vol
. II at
56-64
; Complainants Exhibit 14) At least two other areas along the Tri-
State Tollway received additional noisewall after the initial wall
construction
. Respondent's actions demonstrate that they are capable of
adjusting existing noise barriers in order to reduce roadway noise, and
that such actions are feasible .
It is Complainants belief that additional noise barrier wall is
necessary, technically feasible, and economically reasonable considering
the number of residents that will be positively impacted by the reduction in
roadway noise.
16
CONCLUSION
Testimony presented at the Hearing clearly depicts that the sound
generated by the Tri-State Tollway reaching Complainants violates the
Board's numerical noise emission standards in violation of 35 III . Admin .
Code §901 .102 . Furthermore, the oppressive noise creates an
unreasonable interference with the Complainants lives, and those of their
neighbors, in violation of 35 III
. Admin . Code § 900 .102 . Evidence
presented by both party's noise experts establishes that the area is
receiving noise nuisance levels exceeding Board criteria .
Greg Zak testified that there was a technical and economically
viable solution to reduce the noise originating from the Tri-State Tollway
reaching the adjacent residents . Specifically, Complainants request the
installation of noise barrier wall 18 feet high in place of the current
substandard wall, and, installing an additional one-quarter mile section of
noisewall adjacent to the subject area as per their noise experts
recommendations . Based upon testimony received from Tollway
engineers, additional noisewall heights are technically feasible
.
Further, the Tollway has previously spent millions of dollars to
install noise barrier wall along their road network, including wall
augmentations when necessary . Based upon this previous investment,
and the large revenues obtained from the tollway system, additional noise
barrier wall requested by Complainants can be considered economically
feasible .
17
Complainants do not ask for a continuous noise monitoring
program following any changes made to the existing noise barrier wall at
this time . However, they reserve the right to assert that requirement if
necessary.
Further, since Respondent is a government agency, Complainants
refrain from seeking civil penalties, or requiring a performance bond, at
this time
. Complainants strongly believe that any moneys expended in
this matter should be directed towards financing their reasonable request
at mitigating the existing roadway noise pollution
.
Respectfully submitted,
Scott Dworschak
Attorney for Complainants
1343 North Wells
Chicago, Illinois 60610
312-944-8200
18
CERTIFICATE OF SERVICE
I, Scott Dworschak, an attorney, hereby certify that on Thursday, April 6, 2006, I
caused a copy of the attached Complainant's Brief to be served by U .S
. Mail,
properly addressed and postage affixed, on the following parties :
Carol Webb
Hearing Officer
Illinois Pollution Control Board
1021 N . Grand Avenue
P .O Box 19274
Springfield, Illinois
62794
Victor Azar
Special Ass't Att . General
Illinois Tollway
2700 Ogden Avenue
Downers Grove, Illinois
60515
