March 23, 2000
U.S. Army Corps of Engineers
Chicago District, Regulatory Branch
Attn.: 200000222, Ms. Marcy Knysz
111 North Canal Street, 6th Floor
Chicago, IL  60606-7206

Re: 200000222 - Neumann Homes

Dear Sir or Madam :

The Illinois Chapter of the Sierra Club, which has many members who live in Lake County, Illinois and elsewhere who would be affected by damage to Red Wing Slough, the Antioch Bog Natural Area and other areas that will be harmed by this proposed permit, objects to the draft Section 404 permit and requests a public hearing. Further,  the permit should not  be granted until an Environmental Impact Statement is prepared that carefully considers all the environmental impacts or the project as well as all the viable alternatives to the development.

The Illinois Chapter objects to this permit on the grounds that it would destroy ADID wetlands, increase flooding, degrade water in waters near the site, destroy wildlife habitat and injure rare species including the state-endangered Iowa Darter.  Permits should not be granted to destroy  ADID wetlands at all. Any  destruction of non-ADID wetlands that is unavoidable should be mitigated at a much higher ratio than is proposed by the applicant.

Subjects to be covered in the public hearing requested by the Illinois Chapter include:

  1. Alternatives to the development as currently planned including the alternatives that have been set forth by IDNR and the Lake County Soil and Water Conservation District.

    2.  
  2. The extent of the wetland acreage to be affected by the proposed development.

    3.  
  3. The effect of the development on rare and endangered species.

    4.  
  4. The extent to which the development is located in floodplain.

    5.  
  5. The likely effect of the proposal on Red Wing Slough and the Antioch Bog Illinois Natural Area.

    6.  
  6. The extent to which the Corps of Engineers may legally permit destruction of ADID wetlands.

    7.  
  7. The need for special conditions on the permit to protect water quality and rare species.

    8.  
  8. The adequacy of the proposed mitigation.

    9.  
  9. The extent to which any part of this proposed development is "water-dependent" under the relevant Corps regulations.
We thank you for your consideration.
 
Sincerely,
 

Albert Ettinger
Water Issues Coordinator

cc:
IEPA Permit Section
IDNR (K. Shank)
USF&WS (K. Kramer)
LCSWCD (P. Kerpec)
Neumann Homes