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ENGINEERING & APPLIED
SCIENCE
ENVIRONMENTAL
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MUNICIPAL.
•
GEOTECHNIC.v.
GROUNDWVIER
May 8. 2006
Marie Tipsord,
Hearing Officer
Illinois Pollution Control Board
100 West Randolph
Suite 11-500
Chicago, 11 . 60601
Re: R04-23B (UST Rulemaking - Consolidated)
Public Comment
Madam Hearing Officer :
The record reflects that more than one half billion Illinois tax dollars has been distributed
to owner-operators of leaking, underground storage tanks during the past one and one half
decades. Yet, the record lacks any specificity as to just what those tax dollars actually
purchased. Landfill air space? Earth moving? Trucking? Consultant's man-hours' The
only reliable statistics in the record that reflect the distribution of the expenditures are
those that were developed by a private sector participant to identify the recipients off the
money, not how it was spent
.
So, although I can appreciate the Agency's effort in
itemizing tasks and assigning to them man-hours and unit costs, it must be said that the
Agency's conclusions are not supported by actual data : they are largely guesswork
.
The Board has been asked to install cost controls to rein in an assumed, but unarticulated
problem, with measures that have been assembled by arbitrary and subjective means, in a
process that is seemingly no more complex than a round table discussion
.
Is this
credible?
No .
Even less credible is the assertion that resources are unavailable to
compile a statistical data base . I respectfully submit that, in the absence of hard data, the
Board should order, for the present time, that LUST Fund reimbursements be made on
the basis of time and materials .
Secondly, and to the extent that the Board may believe
that there exists a problem with LUST Fund over-payment, the record in these
proceedings not containing any actual evidence of such, I think it appropriate that the
Board direct the Agency to compile statistically valid LUST Fund expenditure data
.
That data, collected over some reasonable period of time, say twelve months, should then
be presented to . the Board for its further consideration . Thank you
.
Respectfully Submitted,
Michael
W.
Rapps,
P.E .
P.O . Box7349
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821 Sorrx
DDiuciN
DRIVE
•
SPRINGFIELD, IL62791.7349
.
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(217) 787-2118
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EAX (217)
7 87-6641
ORIGINAL
RECEIVED
Y - 6 2006
Pollution
Control Boa
d
EsnBusr-u n
IN1978
SPRINGFIELD,
ILLINOIS
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CARBONDALE, ILLINOIS
TLi
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