By Philip L. Comella

Ending, for the time being, a fiercely contested rulemaking in which even the Chicago Tribune’s editorial board weighed in, the Illinois Pollution Control Board on August 23, 2012 issued its Final Rule changing the standards for Clean Construction or Demolition Debris (CCDD) Fill Operations. The heart of the controversy in this

By Philip L. Comella

Rulemaking procedures underway before the Illinois Pollution Control Board’s (Board) in the First Notice of proposed amendments to Clean Construction or Demolition Debris (CCDD) Fill Operations (35 Ill.Adm.Code 1100) show that battle lines have been drawn over how CCDD will be regulated in the State of Illinois.  One of the key

By Philip L. Comella

In July 2010, the Illinois General Assembly enacted amendments to the Illinois Environmental Protection Act that increase the regulation of Clean Construction and Demolition facilities and also create a new form of regulated facility known as an “Uncontaminated Soil Fill Operation.” The legislation set forth a two-tiered rulemaking process: The IEPA