BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
RECEIVED
CLERK'S OFFICE
ILLINOIS ENVIRONMENTAL
)
MAY 1
~ 2007
PROTECTION AGENCY,
)
STATE OF ILLINOIS
Pollution Control Board
Complainant,
)
IEPA No
. 58-07 AC
and
0198025005 Champaign County
1
RENEE C. LO
)
Respondent
)
RESPONSE TO CITATION AND ENTRY OF APPEARANCE
Renee C
. Lo, by her attorney, Miller & Hendren, LLP, for her Response to the
Citation herein made, states the
:
1 .
She has cleared the subject property, and will continue to clean up
debris deposited on her land by trespassers
.
2.
Prior to the entry of this citation Respondent had cleared the subject
premises several occasions from unauthorized dumping of garbage, old furniture
and trash on this property
.
3.
The condition reviewed by the environmental inspection was caused by
unknown parties on several occasions with an effort each time by the
Respondent to clear the property
.
4.
Assurance is hereby given that Respondent will timely act each time to
correct known violations of environmental regulations by those trespassers
.
WHEREFORE, Respondent respectfully requests that the Citations be vacated on
the grounds that she will expend every effort to clear dumping by trespassers
.
Respectfully submitted,
Prepared by :
Miller & Hendren, LLP
PO Box 980
Champaign, IL 61824-0980
Tel (217) 352-2171
Fax (217) 352-3839
By :
& Hendren, LLP,
-, L.
Attorneys
Counsel
RECEIVED
I3EFORE THE ILLINOIS POLLUTION CONTROL BOAItRK'S OFFICE
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
Complainant,
)
LPC #0198205005 Champaign, Illinois
v.
)
(IEPA No
. 58-07-AC)
RENEE C. LO
)
Respondent
.
)
CERTIFICATE OF SERVICE OF :
A .
Notice of Filing of Response to Citation ;
B.
Notice of Entry of Appearance thereto.
To :
Clerk of Illinois Pollution Control Bard
State of Illinois Center
100 West Randolph, Suite 115
Chicago, 11, 60601
and to
Illinois Environmental Agency's Division
Legal Counsel
1021 North Grand East
P.O
. Box 19276
Springfield, 11 . 62794-9276
The undersigned, for and on behalf of Renee C
. Lo, Respondent, hereby certifies that on
this date, the above addresses were duly provided a copy of her Response to the above entitled
Citation, by forwarding copies thereof to each by depositing the same in the U
.S
. Mail Service in
Champaign, Illinois, properly addressed, and with appropriate postage affixed
.
May 10, 2007
Prepared by
:
Miller & Hendren, LLP
P .O. Box 980
Champaign, 11
. 61824-0980
Tel (217) 352-2171
Fax (217) 352-3839
MAY 1 4 2007
PollutionSTATE
OF
Control
ILLINOIS
Board
