116 Hamilton Place Vernon Hills, IL 60061-1041 March 23, 2000
	Sierra Club Woods & Wetlands Group

Dear Ms. Knysz:

The Woods & Wetlands Group of the Sierra Club represents the environmental concerns of over 2000 members in the NE IL region. We are deeply concerned that the remaining wildlife areas in our region are being obliterated by bulldozers. All too often the Corps has miscarried its duty to enforce the Clean Water Act by allowing destruction and damage to wetlands. Typically the Corps narrowly defines wetlands, allows them to be replaced by unproved mitigation, while ignoring the value of surrounding hydric soils. The consequence is destruction of ecosystems that have evolved here since the last ice age, dysfunctional retention ponds, damage to the health of neighboring wetlands, and frequently, erosion and flooding. Your decision not to consult the USF&WS regarding this application indicates a similar predisposition, and we request that you reconsider, and that you request the IEPA to deny any Section 401 waiver, or certification, without thorough consideration of these consequences.

The massive 1390 home, 605 acre development proposed for this property, if allowed, will :
 

• damage the directly impacted ADID wetland homes of threatened and endangered species. No filling of Antioch Bog, named among the "highest quality wetlands in IL," should be allowed. At least 100’ buffers should be required, as specified in the Lake County WDO. US Fish & Wildlife concurs, and should be formally consulted. Mitigation will not recover its value and should not be allowed. There is no justification for decreasing the 1.5:1 mitigation ratio for other wetlands on the site, and it should be required on-site, and independent from the buffer areas.
• be subject to flooding. The site plan has new homes in areas shown on FEMA and Flood of Record maps as floodplains. This should not be allowed. Delineations should be updated and the application amended, including: expanding farmed wetlands, corrections for illegal draining by the late Homer White, unusually dry springs of recent years, and soil sampling errors that were made in dry soils during dry periods, and misrepresent the site.
• cause flooding and damage to surrounding ADID wetlands. The soils at the site are 34% highly erodible, and 32% wetlands. Removing, covering, and draining these soils will result in erosion, polluting: Antioch Bog, Redwing Slough (both IL and Lake County conservation areas), Homer White Lake, and Huntley Lake. Detention ponds planned are insults to the existing ecology, inadequate in size, and ignore existing drainage tiles. The application also lacks an upland alternative, a glaring omission for these wet soils and this wetland area. Please refer to Lake County Soil & Water NRI 00-2002 for a thorough explication. Flooding of adjacent residences is also likely.
• destroy scenic quality of the area. Over 900 mature trees in Oak Knolls Savanna and the Evergreen Forests will be razed and replaced with wall to wall town-homes, houses, and roads. Present residents will suffer a severe loss.
• severely impact congestion on local roads. Thousands of extra car trips will further overburden Rt. 173 and Miller Road. The plan has no provision for public transit, and is remote from existing service.

Sincerely, Sincerely, Evan L. Craig Chair