BEFORE
    TifE ILLINOIS POLLUTION CONTROL BOARD
    E
    C
    E
    V
    E
    D
    CLERK’S
    OFFICE
    FOX MORAINE, LLC,
    )
    JUL
    202009
    Petitioner,
    )
    STATE
    OF
    ILLINOIS
    Control
    Board
    )
    PCB No. 07-146
    UNITED CITY
    OF YORKVILLE,
    CITY
    )
    COUNCIL,
    )
    )
    Respondent.
    )
    Notice of
    Filin2
    To:
    All Counsel of
    Record
    (see
    attached
    service
    list)
    On July 17,
    2009,
    the undersigned filed with the Illinois Pollution Control Board, 100
    W.
    Randolph St., Chicago, IL, the Amicus Curiae Brief of Friends of Greater
    Yorkville,
    which
    is
    also served on you.
    Respectfully submitted,
    James
    H.
    Knippen, II
    Adam C. Kruse
    WALSH,
    KNIPPEN, KNIGHT &
    POLLOCK, CHARTERED
    2150
    Manchester Rd., Ste. 200
    Wheaton, IL 60 187-2476
    630-462-1980
    GREATER
    YORKVILLE

    BEFORE
    TifE
    ILLINOIS
    POLLUTION
    CONTROL
    BOARD
    RCS
    OFFICE
    FOX
    MORAiNE,
    LLC,
    )
    -ILIL
    2
    U
    2009
    Petitioner,
    )
    POllUtior
    STATE
    OR
    Contro
    IL
    v.
    )
    )
    PCB
    No.
    07-146
    UNITED
    CITY
    OF
    YORKVILLE,
    CITY
    )
    COUNCIL,
    )
    )
    Respondent.
    )
    Amicus
    Curiae
    Brief
    of Friends
    of Greater
    Yorkville
    In
    considering
    the
    decision
    of a
    municipality’s
    governing
    body
    that
    has
    denied
    a siting
    application,
    the plain
    language
    of
    Section
    40.1(a)
    of
    the Environmental
    Protection
    Act
    allows
    the
    Pollution
    Control
    Board
    to
    consider
    “the
    fundamental
    fairness
    of
    the procedures
    used
    by.
    .
    .
    the
    governing
    body
    of the
    municipality
    in
    making
    its
    decision”
    415
    ILCS
    5/40.1(a)
    (emphasis
    added).
    The
    case
    law has
    interpreted
    this
    to
    mean
    that,
    “[i]n
    a
    local
    siting
    proceeding,
    fundamental
    fairness
    incorporates
    only
    the
    minimal
    standards
    of
    procedural
    due
    process.”
    Peoria
    Disposal
    Co.
    v. PCB,
    385
    Ill.
    App.
    3d
    781,
    797
    (3d Dist.
    2008)
    (emphasis
    added).
    Substantive due
    process
    is
    not
    within
    this
    parameter.
    An
    administrative
    agency
    only
    has
    that
    jurisdiction
    set forth
    in
    its
    enabling
    legislation:
    As a
    creature
    of
    statute,
    [an
    administrative
    agency]
    may
    exercise
    only
    the
    powers
    conferred
    upon
    it
    by the
    legislature.
    Any
    power
    or
    authority
    claimed
    by
    an
    administrative
    agency
    must
    find
    its
    source
    within
    the
    provisions
    of
    the statute
    by
    which
    the agency
    was created.
    The
    agency’s
    authority
    must
    either
    arise
    from
    the
    express
    language
    of
    the
    statute
    or devolve
    by
    fair
    implication
    and intendment
    from
    the
    express
    provisions
    of
    the
    statute
    as
    an
    incident
    to
    achieving
    the
    objectives
    for
    which
    the agency
    was
    created.
    Nader
    v.
    Ill.
    State
    Bd.
    of
    Elections,
    354
    Ill.
    App.
    3d
    335,
    340
    (1st
    Dist.
    2004)
    (internal
    citations
    and
    punctuation
    omitted).
    The
    Illinois
    legislature
    has
    not
    given
    this
    Board
    authority
    to
    address
    substantive
    due
    process
    as
    it
    relates
    to
    citizen
    participation
    in
    siting
    hearings
    and
    the other
    1

    statutory
    and
    constitutionally
    protected
    citizen
    activities
    that
    occurred
    in
    the
    period
    leading
    up
    to
    the
    denial
    of
    Fox
    Moraine’s
    siting
    permit
    application.
    In
    contrast
    to
    this
    fundamental
    law,
    Petitioner
    Fox
    Moraine
    asks
    the
    Board
    to
    interpret
    “fundamental
    fairness”
    to
    go
    far
    beyond
    the
    procedures
    that
    the
    Yorkville
    City
    Council
    used.
    It
    asks
    this
    Board
    to
    expand
    its
    inquiry
    to
    whether
    comments
    made
    by
    members
    of
    the
    general
    public
    outside
    of
    the
    siting
    hearing
    caused
    the
    whole
    siting
    process
    to
    be
    fundamentally
    unfair.
    As
    Fox
    Moraine
    admits,
    these
    are
    not
    ex
    parte
    contacts
    with
    members
    of
    the
    City
    Council.
    They
    are
    public
    conmients
    made
    at
    other
    city
    council
    meetings
    and
    during
    the
    election
    campaign
    that
    was
    occurring
    at
    about
    the
    same
    time
    as
    the
    siting
    hearing.
    These
    are
    plainly
    matters
    that
    are
    beyond
    the
    scope
    of
    what
    this
    Board
    can
    review
    as
    part
    of
    its
    “fundamental
    fairness”
    inquiry.
    In
    fact,
    any
    effort
    to
    extend
    procedural
    due
    process
    into
    this
    area
    of
    substantive
    fundamental
    fairness
    would
    result
    in
    this
    Board
    making
    determinations
    of:
    (1)
    what
    is
    and
    is
    not
    “fair”
    in
    annexation
    proceedings,
    plan
    commission
    hearings
    and
    regular
    City
    council
    meetings;
    (2)
    what
    citizens
    should
    and
    should
    not
    be
    permitted
    to do
    in
    the
    election
    of
    local
    officials;
    and
    (3)
    the
    manner
    in
    which
    citizens
    may
    participate
    in
    a
    siting
    hearing
    where
    the
    statute
    not
    only
    contemplates,
    but
    encourages,
    local
    citizen
    participation—and
    even
    more
    troubling—the
    parameters
    of
    citizen’s
    First
    Amendment
    rights
    in
    these
    various
    processes
    and
    proceedings.
    None
    of
    these
    concepts
    are
    embodied
    in
    section
    40.1(a)
    and
    to
    attempt
    to
    infer
    that
    they
    are
    would
    open
    a
    Pandora’s
    Box
    of
    deliberative
    confusion.
    If
    this
    Board
    were
    to
    buy
    into
    Fox
    Moraine’s
    position,
    the
    Board’s
    ruling
    would
    have
    the
    inevitable
    consequence
    of
    chilling
    and
    restraining
    First
    Amendment
    speech,
    peaceable
    assembly,
    and
    other
    political
    and
    procedural
    rights
    as
    provided
    Illinois
    citizens
    under
    the
    case
    law,
    municipal
    code,
    and
    the
    siting
    statute.
    2

    What Fox Moraine
    is asking
    the Board to fmd
    is that the
    exercise of various First
    Amendment
    rights by citizens
    of Yorkville
    deny
    Fox Moraine fundamental
    fairness.
    These First
    Amendment
    rights include
    the citizens’
    right to make public
    comments—orally
    and by posting
    signs on matters
    of
    political
    concern
    to the local community.
    They include
    the citizens’
    rights
    to
    petition their
    elected officials
    as to the manner in
    which they
    wish
    to be represented.
    They
    include
    the citizens’ rights
    to
    inform
    their
    fellow community
    members about political
    issues
    in
    an election. And they
    include
    the
    citizens’ rights to vote
    for those
    elected
    officials whom they
    believe will
    best represent them.
    This is the political
    process acting
    in its purest form.
    The
    underlying
    problem with
    Fox Moraine’s
    position is that
    it really
    seeks
    relief for what
    it
    perceives—but
    fails to identify—as
    violations of substantive
    due process;
    not to the
    procedural
    due process
    to which it is entitled
    and which
    it received.
    If this Board
    were to entangle
    itself in the
    question
    of whether the
    citizens’ exercise
    of
    their First Amendment
    rights
    denied Fox Moraine
    “fundamental
    fairness,”
    this
    would
    have to
    be
    considered an issue
    of substantive due
    process. Such
    an analysis would
    go
    far
    beyond
    the
    question
    of
    whether
    the
    “minimal
    standards
    of procedural
    due process”
    were met—which
    is the
    question
    this Board is authorized
    to consider
    in this context. Rather,
    it would
    ask
    that,
    even if the
    City Council provided
    adequate
    procedural due process,
    the hearing
    was nevertheless unfair
    because
    of the content of the
    citizens’
    public
    comments and speech
    during the
    course of the
    election.
    Such
    analysis clearly
    exceeds the
    scope of what the
    General Assembly
    has authorized
    this Board to consider
    by
    the
    plain
    language of section
    40.1(a) and the
    cases interpreting it
    and
    cited
    herein.
    For
    these
    reasons,
    the Board should confme
    its
    analysis
    of “fundamental
    fairness” to the
    procedures used by
    the Yorkville City
    Council
    in conducting
    the siting hearing.
    This Board
    3

    should
    not
    consider
    public
    comments
    that
    citizens
    made
    during
    the
    hearings
    on
    annexation
    or
    during
    an
    election.
    It
    should
    not
    consider
    the
    political
    affiliations
    of
    particular
    citizens
    and
    candidates
    or
    their
    positions
    on
    the
    landfill
    during
    the
    election.
    It
    should
    not
    even
    consider
    the
    substantive
    content
    of
    the
    public
    comments
    made
    during
    the
    siting
    hearings,
    beyond
    ensuring
    the
    procedures
    satisfied
    Fox
    Moraine’s
    right
    to
    minimal
    standards
    of
    procedural
    due
    process.
    In
    sum,
    this
    Board
    should
    not
    engage
    in
    the
    wide-open
    inquest
    of
    whether
    independent
    citizens’
    exercise
    of
    First
    Amendment
    rights
    had
    the
    effect
    of
    denying
    Fox
    Moraine
    its
    rights
    to
    due
    process.
    A.
    Under
    the
    plain
    language
    of
    Section
    40.1
    and
    the
    case
    law
    interpreting
    that
    statute,
    the
    Board
    must
    limit
    its
    inquiry
    to
    the
    fairness
    of
    the
    procedures
    used
    during
    the
    siting
    hearing.
    By
    refusing
    to
    consider
    anything
    beyond
    the
    procedures
    that
    the
    Yorkville
    City
    Council
    used
    during
    the
    siting
    hearing,
    the
    Board
    will
    simply
    be
    following
    the
    case
    law.
    In
    Residents
    Against
    a
    Polluted
    Environment
    v.
    PCB,
    293
    Ill.
    App.
    3d
    219,
    222-23
    (3d
    Dist.
    1997),
    the
    Appellate
    Court
    affirmed
    the
    Board’s
    refusal
    to
    allow
    landfill
    opponents
    to
    present
    evidence
    of
    an
    applicant’s
    involvement
    in
    La
    Salle
    County’s
    process
    of
    amending
    its
    Solid
    Waste
    Management
    Plan,
    prior
    to
    the
    applicant’s
    application.
    The
    Appellate
    Court
    held
    that
    section
    40.1
    does
    not
    authorize
    the
    Board
    to
    review
    these
    kinds
    of
    matters
    outside
    the
    siting
    process.
    Id.
    at
    223.
    Here,
    Fox
    Moraine
    is
    asking
    this
    Board
    to
    delve
    into
    First
    Amendment
    issues
    far
    more
    unwieldy
    and
    complex
    than
    the
    amendment
    of
    the
    solid
    waste
    management
    plan
    in
    Residents.
    Just
    as
    the
    Appellate
    Court
    held
    that
    section
    40.1
    does
    not
    authorize
    the
    Board
    to
    review
    the
    applicant’s
    involvement
    in
    the
    amendment
    of
    that
    solid
    waste
    plan,
    this
    Board
    should
    not
    attempt
    to
    review
    citizens’
    public
    comments
    made
    at
    the
    annexation
    hearings.
    4

    The
    annexation
    process
    provided
    for
    public
    comment,
    and
    its.
    procedures
    were
    governed
    by
    the
    Municipal
    Code
    (65
    ILCS
    5/1 et
    seq.).
    Likewise,
    any
    review
    of
    the
    canvassing
    activity
    or
    political
    affiliation
    of
    individuals
    during
    the Yorkville
    election
    of
    2007
    would
    be fraught
    with
    First
    Amendment
    issues
    beyond
    the scope
    of what
    the
    Board
    can
    review.
    The
    plain
    language
    of
    section
    40.1
    is clear:
    the
    board
    is
    only
    allowed
    to
    consider
    “the
    fundamental
    fairness
    of
    the
    procedures
    used
    by
    the
    [Yorkville
    City
    Council]
    in
    reaching
    its
    decision.”
    415
    ILCS
    5/40.1(a)
    (emphasis
    added).
    B.
    The
    content
    of
    public
    comments
    must
    be
    distinguished
    from
    the
    procedures
    the
    City
    Council
    used
    in
    allowing
    those
    comments.
    An
    argument
    similar
    to Fox
    Moraine’s
    position
    was addressed
    and
    rejected
    in
    Waste
    Mgt.
    of
    Illinois
    v.
    PCB,
    123
    Ill. App.
    3d
    1075,
    1081
    (2d
    Dist.
    1984).
    There,
    the
    petitioner-applicant
    argued
    that “the
    intensity of citizen
    opposition”
    at
    the public
    hearing
    and
    “the
    substantial
    negative
    public
    reaction
    to
    its
    application”
    caused
    the county
    board’s
    decision
    to
    be
    fundamentally
    unfair,
    in
    that
    it
    was
    “based
    ‘not
    on
    the evidence
    but
    on
    political
    concerns.” jj,
    The Appellate Court
    disagreed,
    stating:
    The
    statute
    requires,
    however,
    only
    that
    the
    procedures
    be
    fundamentally
    fair.
    The
    procedures employed
    by
    the
    Hearing
    Committee
    provided
    a
    full
    and
    complete
    opportunity for petitioner
    to
    support
    its
    application.
    *
    *
    *
    [T]he
    existence
    of
    strong
    public
    opposition
    does
    not
    invalidate
    the
    [county
    board’s]
    decision.
    j
    Reasoning further,
    the
    Court
    stated
    that
    “[w]here
    the
    statute
    requires
    the
    [county
    board]
    to
    conduct
    a
    public
    hearing,
    a
    decision
    does
    not
    become
    unfair
    merely
    because
    elected
    officials
    recognize public
    sentiment.”
    j
    at 1082.
    The
    natural
    corollary
    of
    this
    reasoning
    is
    the fact
    that
    the
    siting
    process
    does
    not
    become
    fundamentally
    unfair
    because
    citizens
    convey
    their
    public
    sentiment
    to their
    elected
    officials.
    The
    protection
    of
    the
    First
    Amendment
    extends
    to both
    the
    citizens’
    right
    to petition
    their
    elected
    5

    officials
    and
    to
    have
    their
    elected
    officials
    actually
    receive
    and
    consider
    those
    petitions.
    Stahelin
    v.
    Forest
    Preserve
    Dist.
    of
    DuPage
    County,
    376
    Iii.
    App.
    3d
    765,
    777
    (2d
    Dist.
    2007).
    In
    fact,
    section
    39.2
    requires
    local
    officials
    to
    receive
    and
    consider
    citizens’
    public
    comment
    in
    making
    its
    decision.
    Section
    39.2(c)
    states
    that
    “[a]ny
    person
    may
    file
    written
    conmient
    ...
    concerning
    the
    appropriateness
    of
    the
    proposed
    site
    for
    its
    intended
    purpose.”
    Section
    39.2(d)
    requires
    a
    public
    hearing
    be
    held.
    Section
    39.2(c)
    requires
    that
    the
    “governing
    body
    of
    the
    municipality
    shall
    consider
    any
    comment
    received
    or
    postmarked
    not
    later
    than
    30
    days
    after
    the
    date
    of
    the
    last
    public
    hearing.”
    In
    other
    words,
    public
    comment
    is
    a
    mandatory
    part
    of
    the
    siting
    procedure.
    The
    fact
    that
    the
    content
    of
    that
    public
    comment
    was
    largely
    an
    expression
    of
    strong
    negative
    opinions
    about
    Fox
    Moraine’s
    application
    did
    not
    cause
    the
    procedure
    used
    to
    be
    unfair.
    In
    People
    ex
    rel.
    Klaeren
    v.
    Village
    of
    Lisle,
    202
    Ill.
    2d
    164
    (2002),
    our
    Supreme
    Court
    recognized
    the
    principle
    that
    when
    a
    statute
    provides
    for
    procedural
    due
    process
    in
    a
    legislative
    hearing,
    the
    procedures
    afforded
    must
    be
    meaningful.
    Section
    39.2
    provides
    citizens
    with
    the
    right
    to
    public
    comment
    as
    part
    of
    their
    right
    to
    procedural
    due
    process.
    The
    content
    of
    the
    citizens’
    exercise
    of
    their
    meaningful
    right
    to
    procedural
    due
    process
    is
    not
    something
    that
    can
    deprive
    Fox
    Moraine
    of
    its
    right
    to
    procedural
    due
    process.
    The
    statutory
    requirement
    that
    the
    public
    be
    allowed
    to
    comment
    distinguishes
    the
    siting
    application
    process
    from
    a
    more
    traditional
    judicial
    or
    adjudicatory
    proceeding.
    Consider
    the
    difference
    if
    the
    siting
    process
    were
    a
    one-on-one,
    adversarial
    proceeding
    where
    a
    trier
    of
    fact
    was
    called
    on
    to
    consider
    only
    the
    evidence
    the
    parties
    chose
    to
    present.
    If
    that
    were
    the
    case,
    then
    public
    comment
    would
    have
    no
    place
    in
    the
    procedure.
    An
    ordinary
    citizen
    would
    have
    no
    First
    Amendment
    right
    to
    express
    any
    opinion
    to
    the
    trier
    of
    fact.
    If
    a
    judge
    in
    such
    a
    proceeding
    6

    were
    to allow public
    comment,
    then
    the fact of
    public
    comment
    itself might
    violate
    due process.
    But
    the
    violation would
    be the
    fact
    of
    public
    comment,
    not
    the content
    of
    the
    comments
    themselves.
    Here, the
    General
    Assembly
    does not
    create such
    a judicial
    or adjudicatory
    procedure.
    It
    decided
    that
    the procedure
    for
    deciding landfill
    siting
    applications
    should
    be one
    in which
    “[p]public
    participation
    not
    only is encouraged,
    but
    is required
    by
    the
    statute.” Waste
    Mgt.,
    123
    Ill. App.
    3d at
    1081
    (citing
    415 ILCS
    5/39.2(c)).
    As such,
    courts
    have recognized
    that
    “[a] local
    siting
    authority’s
    role in
    the
    siting approval
    process
    is
    both quasi-legislative
    and
    quasi-
    adjudicative.”
    Land
    & Lakes
    Co. v.
    PCB, 319
    Ill.
    App. 3d
    41,
    48
    (3d
    Dist.
    2000). Thus,
    even
    though
    section
    39.2
    sets
    out the nine
    statutory
    criteria that
    must
    be satisfied
    before
    a local
    body
    can grant
    approval, “a
    local
    governing
    body
    may
    fmd
    the applicant
    has
    met
    the
    statutory criteria
    and
    properly
    deny
    the
    application
    based
    upon
    legislative-type
    consideration.”
    Southwest
    Energy
    Corp.
    v. PCB,
    275 Ill.
    App.
    3d 84,
    91
    (4th
    Dist.
    1995).
    And one
    such legislative-type
    consideration
    that
    local
    governing
    body
    may—and
    must—take
    into
    account is
    its
    constituents’
    public
    comments
    regarding
    the
    proposed
    landfill.
    Because public
    comment
    is
    a
    mandatory
    part
    of the
    procedure,
    and because
    citizens
    are
    making
    these public
    comments
    to
    their elected
    representatives,
    the case
    law
    has
    not
    extended
    “fundamental
    fairness”
    to apply
    to the content
    of citizens’
    public
    comments.
    To
    the
    contrary,
    section
    39.2 expressly
    prohibits
    the content
    of
    a public
    office-holder’s
    statements
    about
    a siting
    application
    from being
    used
    as a basis
    to
    prevent that
    person
    from
    voting
    on
    the
    application:
    The
    fact
    that a member
    of
    the county
    board or governing
    body of the
    municipality
    has publicly
    expressed
    an opinion
    on an
    issue
    related
    to a site review
    proceeding
    shall not
    preclude
    the
    member from
    taking part
    in the
    proceeding
    and voting
    on
    the
    issue.
    7

    415ILCS
    5/39.2(d).
    As
    the
    Court
    in
    Southwest
    Energy
    stated,
    that
    provision
    “demonstrate{es]
    the
    General
    Assembly’s
    understanding
    that
    it
    has
    called
    upon
    locally
    elected
    officeholders
    on
    municipal
    or
    county
    boards—not
    judges—to
    adjudicate
    whether
    the
    siting
    criteria
    st
    forth
    in
    section
    39.2(a)
    .
    .
    .
    are
    present
    in
    a
    given
    case,”
    and
    because
    of
    that,
    “standards
    governing
    judicial
    behavior
    cannot
    and
    do
    not
    apply
    to
    local
    officeholders.”
    at
    92.
    If
    section
    39.2
    provides
    that
    elected
    officials
    may
    make
    public
    statements
    without
    the
    content
    of
    those
    statements
    precluding
    them
    from
    voting
    on
    the
    application,
    how
    could
    the
    same
    basic
    principle
    not
    apply
    to
    expressions
    of
    opinions
    by
    individual
    citizens?
    Plainly,
    the
    statute
    does
    not
    allow
    the
    expression
    of
    opinion
    by
    any
    person
    to
    be
    intermingled
    with
    an
    analysis
    of
    whether
    the
    procedures
    were
    fair,
    especially
    where
    those
    procedures
    allow
    for
    public
    comment.
    Speech
    does
    not
    violate
    procedural
    due
    process
    because
    it
    is
    loud,
    vociferous,
    or
    makes
    Fox
    Moraine
    uncomfortable.
    The
    First
    Amendment
    even
    protects
    this
    type
    of
    speech.
    Brandenburg
    v.
    Ohio,
    395
    U.S.
    444,
    447-48
    (1969).
    C.
    The
    legislature
    created
    a
    process
    in
    which
    a
    high
    level
    of
    citizen
    participation
    is
    encouraged,
    and
    this
    participation
    is
    fully
    protected
    by
    the
    First
    Amendment.
    This
    participation
    was
    heightened
    by
    the
    fact
    that
    a
    municipal
    election
    was
    occurring
    at
    the
    same
    time,
    with
    all
    election
    activities
    being
    protected
    by
    the
    First
    Amendment.
    The
    citizens
    of
    Yorkville
    had
    a
    First
    Amendment
    right
    to
    oppose
    the
    siting
    of
    this
    landfill
    in
    Yorkville.
    Fox
    Moraine
    had
    no
    right
    to
    be
    unopposed.
    The
    statutory
    provision
    for
    public
    hearings
    with
    public
    comment
    indicates
    that
    these
    hearings
    are
    held
    to
    elicit
    and
    evaluate
    the
    reactions,
    comments,
    and
    complaints
    of
    private
    citizens
    about
    the
    fact
    that
    a
    landfill
    might
    be
    built
    in
    their
    community.
    With
    the
    issue
    of
    landfill
    siting,
    the
    Illinois
    General
    Assembly
    saw
    fit
    to
    create
    a
    procedure
    whereby
    the
    public
    participated
    more
    directly
    than
    with
    other
    issues.
    By
    creating
    this
    procedure,
    the
    General
    Assembly
    advances
    significant
    First
    Amendment
    interests.
    All
    citizens,
    8

    regardless of the
    content
    of
    their ideas, have the right to petition the government.
    This is a core
    political right acknowledged or provided by the Illinois
    Legislature
    in
    the siting statute.
    Equally as important, though, the citizens of Yorkville had a
    First Amendment right to
    elect
    representatives whom they believed would best represent the community. Those
    residents
    who were opposed to the landfill siting had
    the
    right to support representatives whom they
    believed
    were
    also opposed to the landfill siting, just as any
    residents
    who
    supported the landfill
    would have a right
    support representatives whom, they believed also supported
    the landfill.
    They
    had the right to canvas during the election and
    speak freely about an important
    political
    issue affecting the
    community. This,
    again, is a core political right; as was
    their
    right to express
    themselves by
    the
    posting of signs carrying their
    message. These things are not some sort of
    procedure that the Board can
    analyze
    from fundamental fairness
    standpoint.
    To
    adopt a contrary
    position
    would essentially communicate to a siting
    applicant that it should file its siting
    application and go forward
    with the siting hearing during an election because, if
    the siting
    is
    subsequently
    rejected
    by
    candidates supported by siting opponents,
    the applicant enhances its
    position
    to overturn the denial because
    citizens
    exercised
    their
    free speech and
    political
    rights to
    elect their favored
    candidates. There is nothing in the siting statute to
    even suggest that this
    concept
    should
    be
    entertained by
    this Board.
    It is obvious
    that Fox Moraine had all the same First
    Amendment rights that landfill
    opponents
    had. Fox Moraine
    could
    have mounted a campaign during
    the election to inform
    citizens
    about the benefits that the landfill
    would
    have
    brought to Yorkville. It could have
    mobilized more
    citizens
    who wanted a
    landfill
    to
    advocate
    on its behalf through public
    comments.
    It could
    have supported candidates favorable to
    its position. It may well have even
    done
    these things.
    But even if it did, it does not change the charge of
    this Board to review
    the
    9

    procedural
    due
    process
    provided
    at
    the
    siting
    hearing.
    It
    is
    more
    than
    significant
    in
    the
    context
    of
    this
    Board’s
    review
    standard
    that
    Fox
    Moraine
    does
    not
    contest
    that
    it
    was
    given
    all
    reasonable
    opportunity
    to
    present
    its
    evidence
    and
    position
    at
    the
    siting
    hearing.
    Fox
    Moraine
    made
    the
    tactical
    decision
    to
    submit
    its
    siting
    application
    to
    the
    City
    of
    Yorkville
    five
    months
    before
    a
    municipal
    election
    was
    to
    occur.
    Fox
    Moraine
    knew
    that
    an
    election
    was
    going
    to
    take
    place
    about
    the
    same
    time
    as
    the
    public
    hearings
    on
    its
    application.
    It
    is
    naïve
    to
    think
    that
    Fox
    Moraine
    did
    not
    anticipate
    that
    the
    landfill
    would
    become
    an
    issue
    in
    the
    municipal
    election.
    There
    is
    nothing
    that
    makes
    landfill
    siting
    an
    off-limits
    issue
    for
    citizens
    and
    candidates
    to
    discuss.
    D.
    What
    Fox
    Moraine
    is
    asking
    would
    require
    this
    Board
    to
    engage
    in
    a
    substantive
    due
    process
    analysis,
    which
    is
    beyond
    what
    is
    required
    by
    “fundamental
    fairness”
    in
    this
    context.
    Ultimately,
    what
    Fox
    Moraine
    is
    asking
    in
    this
    case
    is
    that
    the
    Board
    interpret
    fundamental
    fairness
    as
    incorporating
    principles
    of
    substantive
    due
    process—that
    the.
    Yorkville
    citizens’
    exercise
    of
    their
    First
    Amendment
    rights
    manipulated
    the
    political
    process
    to
    the
    point
    where
    Fox
    Moraine
    did
    not
    receive
    a
    fair
    hearing,
    even
    if
    the
    City
    Council
    followed
    proper
    procedures.
    A
    similar
    argument
    was
    presented
    to
    and
    rejected
    by
    the
    U.S.
    Court
    of
    Appeals
    for
    the
    First
    Circuit
    in
    the
    case
    of
    Nestor
    Colon
    Medina
    &
    Sucesores.
    Inc.
    v.
    Custodio,
    964
    F.2d
    32,
    45-47
    (1st
    Cir.
    199.1).
    There,the
    plaintiff
    was
    an
    applicant
    who
    sought
    to
    build
    two
    hazardous
    waste
    facilities.
    Ii
    at
    34.
    The
    state
    board
    responsible
    for
    issuing
    permits
    denied
    the
    plaintiff
    its
    permits,
    despite
    the
    plaintiff’s
    allegations
    that
    it
    had
    satisfied
    all
    of
    the
    relevant
    siting
    criteria
    necessary
    to
    receive
    a
    permit.
    j
    at
    34-35.
    The
    plaintiff
    alleged,
    among
    other
    things,
    that
    the
    true
    reason
    for
    the
    denial
    was
    political
    manipulation
    of
    the
    permitting
    process
    by
    opponents
    of
    the
    10

    landfill,
    and
    that
    this violated
    its right
    to
    substantive
    due
    process.
    jj
    at 36.
    On
    the
    question
    of
    whether
    this
    violated
    substantive
    due
    process,
    the
    court
    stated:
    The
    substantive
    due
    process
    claim
    must
    rest
    on
    suggestions
    of
    political
    manipulation
    of
    the permitting
    process
    aimed
    ***
    at stopping
    the project
    for some
    other
    reason,
    such
    as
    popular
    opposition
    to
    a
    dump
    of
    this nature.
    As noted,
    the
    project
    stirred
    up
    opposition
    by
    many
    elements
    of
    the
    local
    community.
    The
    question
    thus
    arises
    whether
    allegations
    of
    political
    interference
    with
    the
    permitting
    process
    give
    rise
    to a
    substantive
    due
    process
    claim.
    We
    think
    not,
    on
    this
    record.
    Id. at
    46.
    The
    Court
    further
    stated
    that
    for
    courts
    “to
    attempt
    to regulate,
    as a
    matter
    of
    substantive
    due
    process,
    the
    permissible
    extent
    to
    which
    government
    administrators
    may
    take
    such
    opposition
    into
    account
    would
    seriously
    embroil
    them
    in
    unpromising
    and
    unwarranted
    efforts
    to tailor
    the
    democratic
    process.”
    j4
    at
    47.
    The
    reasoning
    in
    the
    Nestor
    case
    provides
    support
    for the
    Board
    to
    refuse
    to
    interpret
    fundamental
    fairness
    as
    incorporating
    the
    Yorkville
    citizens’
    expression
    to
    the
    City Council
    of
    public
    opposition to
    the
    landfill.
    For
    the
    Board
    to
    attempt
    to
    regulate,
    through
    fundamental
    fairness,
    the
    permissible
    extent
    to
    which
    local
    elected
    officials
    may
    take
    citizen
    opposition
    into
    account
    would
    seriously
    embroil
    the Board
    in unpromising
    and
    unwarranted
    efforts
    to
    tailor
    the
    democratic process.
    If the
    Board
    were
    to
    try
    to
    do
    this,
    what
    standards
    could
    it
    possibly
    apply?
    The best
    way
    to avoid
    this
    is to
    limit
    the
    analysis
    of
    fundamental
    fairness
    to the
    procedures
    that
    the
    City
    of
    Yorkville
    Council
    used
    in
    the siting
    hearing,
    and
    not change
    the standard
    of review
    established
    by
    the legislature
    and
    confirmed
    by
    the
    courts.
    E.
    The
    court
    should
    avoid
    a
    substantive
    due
    process
    analysis
    where
    the
    issue
    can be
    decided
    on
    non-constitutional
    grounds.
    In one
    respect
    this
    Board
    could
    avoid
    the
    morass
    of
    substantive
    due process
    analysis
    that Fox
    Moraine
    is
    seeking
    by deciding
    that
    Fox
    Moraine
    has
    failed
    to
    meets
    its
    burden
    on
    one
    or
    more
    of
    the nine
    siting
    criteria.
    “A
    negative
    decision
    as to
    one
    of the
    criteria
    is
    sufficient
    to
    11

    defeat
    an
    application
    for
    site
    approval
    of
    the
    pollution
    control
    facility.”
    Town
    &
    Country
    Utilities.
    Inc.
    v.
    PCB,
    225
    III.
    2d
    103,
    109
    (2007).
    The
    Board
    should
    continue
    its
    past
    practice
    of
    not
    delving
    into
    substantive
    due
    process
    as
    an
    element
    of
    its
    review
    except
    to
    conclude
    that
    substantive
    due
    process
    is
    not
    its
    statutory
    function.
    Friends
    of
    Greater
    Yorkville
    will
    not
    address
    the
    nine
    criteria
    in
    this
    amicus
    brief.
    Friends
    of
    Greater
    Yorkville
    simply
    adopts
    the
    arguments
    of
    the
    Respondent
    and
    requests
    that
    this
    Board
    find
    that
    its
    decision
    was
    not
    against
    the
    manifest
    weight
    of
    the
    evidence.
    Conclusion
    For
    all
    the
    reasons
    cited
    above,
    Friends
    of
    Greater
    Yorkville
    respectfully
    requests
    this
    Board
    to
    affirm
    the
    decision
    of
    the
    Yorkville
    City
    Council
    in
    denying
    Fox
    Moraine’s
    siting
    application.
    James
    H.
    Knippen,
    II
    Adam
    C.
    Kruse
    WALSH,
    KNIPPEN, KNIGHT
    &
    POLLOCK,
    CHARTERED
    2150
    Manchester
    Rd.,
    Ste.
    200
    Wheaton,
    IL
    60
    187-2476
    630-462-1980
    Respectfully
    submitted,
    OF
    GREATER
    YORKVILLE
    12

    Certificate
    of
    Service
    The
    undersigned
    attorney
    certifies
    that
    on
    July
    17, 2009,
    I served
    a copy
    of
    the
    Arnicus
    Curiae
    Brief
    of Friends
    of Greater
    Yorkville
    on the
    following,
    via
    email:
    Via
    email
    — hallorab@ipcb.state.il.us
    Bradley
    P.
    Halloran
    Hearing
    Officer
    Illinois
    Pollution
    Control
    Board
    James
    R. Thompson
    Center
    100W.
    Randolph
    St.,
    Ste.
    11-500
    Chicago,
    IL 60601
    Via email
    — chelsten@hinslawlaw.com
    Charles
    F.
    Heisten
    Hinshaw
    &
    Culbertson,
    LLP
    100 Park
    Ave.
    P.O.
    Box
    1389
    Rockford,
    IL
    61105-1389
    Via email
    — george@muelleranderson.com
    George
    Mueller
    Mueller
    Anderson,
    P.C.
    609
    Etna
    Rd.
    Ottawa,
    IL
    61350
    James
    H.
    Knippen,
    II
    Adam
    C.
    Kruse
    WALSH,
    KNIPPEN,
    KNIGHT
    &
    POLLOCK,
    CHARTERED
    2150
    Manchester
    Rd.,
    Ste. 200
    Wheaton,
    IL
    60 187-2476
    630-462-1980
    Via email
    — dombrowski@wildman.com
    Leo
    P.
    Dornbrowski
    Wildman,
    Harrold,
    Allen
    & Dixon
    225
    W.
    Wacker
    Dr.,
    Ste. 3000
    Chicago,
    IL 60606-1229
    Via
    email
    — jharkness@momlaw.
    corn
    James
    S.
    Harkness
    Momkus
    McCluskey,
    LLC
    1001
    Warrenville
    Rd.,
    Ste. 500
    Lisle,
    IL 60532
    Via
    email
    — eweis@co.kendall.il.us
    Eric
    C. Weiss
    Kendall
    County
    State’s
    Attorney
    Kendall
    County
    Courthouse
    807
    John St.
    Yorkville,
    IL
    60560
    Via
    email
    — katie@mckeownlawfirm.com
    Katie
    Eisnaugle
    McKeown
    Fitzgerald
    Zoliner
    Buck
    Hutchinson
    &
    Ruttle
    2455
    Glenwood
    Ave.
    Joliet,
    IL
    60435
    (hi
    13

    Back to top