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R86-009 Forcade Dissent 10/02/86
IN THE MATTER OF: HAZARDOUS WASTE PROHIBITIONS
Handle: Document-31602
Owner: Site Administrator (User-2, admin:DocuShare)DS
Friday, December 20, 2002 02:07:56 PM CST
Wednesday, November 2, 2011 08:49:07 AM CDT
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  • ILLINOIS POLLUTION CONTROL BOARD
October 2, 1986IN THE MATTER OF: ) HAZARDOUS WASTE PROHIBITIONS ) R 86-9DISSENTING OPINION (by B.
  • Forcade):
I dissent from today’s action.
  • If the Board determines that the
regulated entity knew of the constraints in advance but failed toadequately plan ahead, the variance is denied because of “self—imposed hardship,” Today’s action represents the ultimateresponse to self—imposed hardship.
  • Turf fights between sister agencies about statutory
interpretation may indeed constitute a “threat to the publicinterest,” but they provide a very poor basis for emergencyrulemaking.
  • Whi...
Allowed
Adobe Portable Document Format (.pdf) - application/pdf
OCR0004.pdf
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836611
No
Appears In: R 86-009
Preferred Version: R 86-009 Forcade Dissent 10/02/86