Archer Daniels Midland v. Pollution Control Board

The Illinois Environmental Protection Agency (EPA) filed a complaint before the Pollution Control Board (Board) alleging that Archer Daniels Midland Corporation (ADM) violated certain provisions of the Environmental Protection Act (Act) (Ill. Rev. Stat. 1981, ch. lll1/2, par. 1001 et seq.) and the regulations promulgated thereunder. The Board found that ADM had committed certain violations of the Act and regulations and imposed a penalty of $40,000. On appeal we upheld the Board’s findings but vacated the penalty. We remanded the cause to the Board for a “determination as to whether under all…