1. BEFORE THE POLLUTION CONTROL BOARD
      2. To: Dorothy M. Gunn, Clerk
      3. NOTICE
      4. BROWN, HAY & STEPHENS, LLP
BEFORE THE POLLUTION CONTROL BOARD
STATE
OF ILLINOIS
JOYCE FARMS RECYCLING, INC.,
Petitioner,
v.
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY,
Respondent.
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PCB No. 08-
-----
(Permit Appeal- Ninety Day Extension)
To:
Dorothy M. Gunn, Clerk
Illinois Pollution Control Board
James
R. Thompson Center
Suite 11-500
100 West Randolph Street
Chicago, IL 60601
NOTICE
Greg Richardson
Division of Legal Counsel
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O. Box 19276
Springfield, IL 62794-9276
PLEASE TAKE NOTICE that I have today filed with the office of the Clerk of the
Pollution Control Board a REQUEST FOR NINETY
DAY EXTENSION OF APPEAL
PERIOD, copies
ofwhich are herewith served upon you.
Respectfully submitted,
JOye;:::S?/
By:
-----7'<..lr
One of Its Attorneys
BROWN, HAY
&
STEPHENS, LLP
Claire
A.
Manning (Reg. No. 3124724) -
Charles
Y.
Davis (Reg. No. 6286010)
205
S. Fifth Street, Suite 700
P.O.
Box 2459
Springfield, IL 62705-2459
(217) 544-8491
Electronic Filing - Received, Clerk's Office, March 4, 2008
* * * * * PCB 2008-049 * * * * *
BEFORE THE POLLUTION CONTROL BOARD
STATE
OF ILLINOIS
JOYCE FARMS RECYCLING, INC.,
Petitioner,
v.
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY,
Respondent.
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)
)
)
)
)
)
)
)
)
PCB No. 08-
_
(Pennit
Appeal- Ninety Day Extension)
REQUEST
FOR NINETY DAY EXTENSION OF APPEAL PERIOD
NOW COMES the Petitioner, Joyce Farms Recycling, Inc. ("Joyce Fanns"), by and
through its attorneys, Brown, Hay
&
Stephens, LLP, and, pursuant to Section 40(a)(1) of the
Illinois Environmental Protection Act (415 ILCS 5/40(a)(1)) and
35 Ill. Adm. Code 105.208,
hereby requests that the Illinois Pollution Control Board ("Board") grant an extension
of the
thirty-five (35) day period for petitioning for a hearing
to June 2, 2008, or any other date not
more than a total
of one hundred twenty-five (125) days from the date of service of the Illinois
Environmental Protection Agency's ("Illinois EPA") final decision. In support thereof, Joyce
Farms respectfully states
as follows:
1.
On January 28, 2008, the Illinois EPA issued a final decision to Joyce Farms.
2.
On February 27,2008, Joyce Fanns made a written request to the Illinois EPA for
an extension
of time by which to file a. petition for review, asJ.9ng the Illinois EPA to join in
requesting that the Board extend the thirty-five (35) day period for filing a petition
to ninety (90)
days.
Electronic Filing - Received, Clerk's Office, March 4, 2008
* * * * * PCB 2008-049 * * * * *
3.
The additional time requested by the parties may eliminate the need for a hearing
in this matter or, in the alternative, allow the parties to identify issues and limit the scope of any
hearing that may be necessary to resolve this matter.
4.
The Illinois EPA filed a Request for Ninety Day Extension
of Appeal Period,
which included its final decision in this matter. By filing its Request with the Board, Joyce
Farms hereby joins in the Illinois EPA'srequest for a ninety (90) day extension.
WHEREFORE, for the reasons stated above, the parties request that the Board, in the
interests of administrative and judicial economy, grant this request for a ninety (90) day
extension ofthe thirty-five (35) day period for petitioning for a hearing.
Respectfully submitted,
By:
:>"'-'\
One of Its Attorneys
BROWN, HAY
&
STEPHENS, LLP
Claire A. Manning (Reg. No. 3124724)
Charles
Y.Davis(Reg. No. 6286010)
205
S. Fifth Street, Suite 700
P.O.
Box 2459
Springfield, IL 62705-2459
(217) 544-8491
2
Electronic Filing - Received, Clerk's Office, March 4, 2008
* * * * * PCB 2008-049 * * * * *
to:
PROOF OF SERVICE
I, on oath state that I have served the attached by placing copies in an envelope addressed
Dorothy M. Gunn, Clerk
Illinois Pollution Control Board
James
R. Thompson Center
Suite 11-500
100 West Randolph Street
Chicago,IL 60601
Greg Richardson
Division of Legal Counsel
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O. Box 19276
Springfield,IL 62794-9276
from Brown, Hay
&
Stephens, LLP, 205 S. Fifth Street, Ste. 700, Springfield, Illinois, before the
hour of 5:00 p.m. on this 4th day ofMarch, 2008&.w
C
<
2
Electronic Filing - Received, Clerk's Office, March 4, 2008
* * * * * PCB 2008-049 * * * * *

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