National Waste & Recycling Ass'n v. County of Cook

2016 IL App (1st) 143694
CourtAppellate Court of Illinois
DecidedJune 2, 2016
Docket1-14-3694
StatusUnpublished
Cited by1 cases

This text of 2016 IL App (1st) 143694 (National Waste & Recycling Ass'n v. County of Cook) is published on Counsel Stack Legal Research, covering Appellate Court of Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
National Waste & Recycling Ass'n v. County of Cook, 2016 IL App (1st) 143694 (Ill. Ct. App. 2016).

Opinion

2016 IL App (1st) 143694 Fourth Division May 26, 2016

______________________________________________________________________________

IN THE APPELLATE COURT OF ILLINOIS FIRST DISTRICT ______________________________________________________________________________

NATIONAL WASTE AND RECYCLING ) Appeal from the ASSOCIATION, an Illinois Not-For-Profit) Circuit Court of Corporation, ) Cook County. )

Plaintiff-Appellant, ) No. 14 CH 6107

)

v. ) Honorable ) LeRoy Martin, THE COUNTY OF COOK, ) Judge Presiding. )

Defendant-Appellee. )

______________________________________________________________________________

JUSTICE COBBS delivered the judgment of the court, with opinion. Justices Howse and Ellis concurred in the judgment and opinion.

OPINION

¶1 The instant appeal arises from a complaint filed by plaintiff National Waste & Recycling

Association,1 an Illinois not-for-profit corporation, which challenged certain provisions of the

Cook County Solid Waste and Recycling Ordinance (SWRO), recently enacted by defendant

Cook County (County). Cook County Code of Ordinances § 30-776 (approved Jan. 15, 2014).

The trial court granted summary judgment in favor of defendant, finding that the County had the

authority to enact the SWRO, and as such, it was enforceable. On appeal, plaintiff contends that

1 National Waste & Recycling Association is a trade organization which represents for-profit waste and recycling companies with its principal place of business in Washington, D.C. No. 1-14-3694

the trial court erred in finding that the SWRO was enforceable because the County has neither

home rule nor statutory authority to enact the challenged provisions of the SWRO, which renders

it void as a matter of law. For the following reasons, we affirm.

¶2 BACKGROUND

¶3 Pursuant to the Solid Waste Planning and Recycling Act (Solid Waste Act) (415 ILCS

15/1 et seq. (West 2012)), the County's Board of Commissioners (Board) adopted its Solid Waste

Management Plan Implementation Ordinance on April 18, 2000, which established the "Solid

Waste Article" (Article) of the Cook County Code of Ordinances.2 On January 15, 2014, the

Board approved and adopted the SWRO, which renamed the Article the "Solid Waste and

Recycling Article" and imposed fees, regulations, and reporting requirements on operators of

Cook County-based solid waste and recycling facilities. The Board's stated purpose in enacting

the SWRO is to "secure for present and future citizens of the community an environment which

is clean, healthful and wholesome." Cook County Code of Ordinances § 30-2 (1980). The

following provisions of the SWRO are relevant to the instant appeal.

¶4 Division 1 vests rulemaking authority in the Cook County Department of Environmental

Control (CCDEC) and provides a hearing process and penalties for ordinance violations. It also

provides numerous technical definitions that are specifically applicable to the SWRO, including

the definitions of the solid waste and recycling facilities it intends to govern. The SWRO defines

solid waste facilities as "sanitary landfills, municipal solid waste transfer stations, and clean

construction or demolition debris fill operations located within Cook County, except within the

corporate limits of the City of Chicago." It defines recycling facility as "any building, portion of

a building or area in which recyclable material is collected, stored, or processed for the purpose

2 The County purposely excluded the City of Chicago from its ordinance, which is required to adopt its own plan. 2

No. 1-14-3694

of marketing the material for use as raw material in the manufacturing process of new, reused or

reconstituted products."

¶5 Division 2 "implements a solid waste management plan for the management of municipal

waste within the County, *** in order to satisfy the requirements of [the Solid Waste Act]." It

provides that "[m]unicipal governments have the primary role and responsibility in providing or

arranging for waste management services within their jurisdictional areas, whereas the County

will implement the coordination, planning, and monitoring of the solid waste management plan

throughout [the County] and establish delegation agreements with sub-county waste management

agencies and the Illinois Environmental Protection Agency." The Division also provides that for

purposes of tracking the implementation of the Solid Waste Management Plan, "any waste hauler

operating within the boundaries of Cook County *** shall submit quarterly reports to the Solid

Waste Coordinator of the [CCDED] *** documenting the volume and/or tonnage of municipal

waste and the volume and/or tonnage of recyclables collected" from residential and

nonresidential properties within the County's boundaries.

¶6 Division 3 applies to solid waste facilities. It provides that each facility must comply with

operational requirements including specific measures for equipment availability and

maintenance; utility capacity; facility cleaning; mud, litter, dust, rodent, noise, and odor control;

safety and security measures; waste screening; driveway and parking grading; and

recordkeeping. It requires facility operators to: (1) submit to the County any Illinois

Environmental Protection Agency (IEPA), U.S. Environmental Protection Agency or Army

Corps Engineers correspondence pertaining to violations; (2) notify the County of cessation of

waste acceptance; (3) remove or containerize waste within certain time limits; (4) maintain waste

volume not to exceed the operator's IEPA permit; (5) cover outside storage containers to prevent

blowing debris; and (6) remove leaking containers. Additionally, the division requires both

sanitary landfill and municipal waste transfer station operators to file quarterly reports to the

County "specifying the quantities of waste and/or recyclable materials accepted" and pay an

operating fee to the County. The fees collected from the facilities are assessed on a per ton basis,

and are to be paid at the time each quarterly report is submitted. Division 3 also requires clean

construction or demolition debris operators to submit reports to the County "indicating the

weight or volume of all materials collected"; these operators must also acquire a County permit,

in which case, the County is authorized to assess a permit application fee. Finally, Division 3

creates the Solid Waste Management Fund which authorizes the County to use the operating fees

collected from sanitary landfills and municipal solid waste transfer stations "only for the

purposes stipulated in 5/22.15 of the [Environmental Protection Act 415 ILCS 5/22.15 (West

2012))]."3

¶7 Division 4 applies to recycling facilities. The division imposes operational requirements

similar to those in division 3, including mud, litter, dust, rodent, noise, and odor control as well

as requirements for storage, signage, refrigerant recovery, waste and used liquid transfer and

storage, runoff prevention, and tire storage. Division 4 requires that recycling facilities submit

reports to the County summarizing recycling activities, including, "(1) the weight of all materials

collected in total by the permittee; and (2) the weight of all materials recycled." It also mandates

all recycling facilities to operate under a County recycling permit, and authorizes the County to

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National Waste and Recycling Association v. County of Cook
2016 IL App (1st) 143694 (Appellate Court of Illinois, 2016)

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