DEPARTMENT OF THE ARMY CHICAGO DISTRICT, CORPS OF ENGINEERS 111 NORTH CANAL STREET CHICAGO, ILLINOIS 60606-7206	APRIL 05,1999 COPY
	REPLY TO ATTENTION OF:

SUBJECT: Request To Fill 2.98 Acres of Wetland For Construction of Residential Subdivision Located South of Route 173, West of Route 45 and North of Grass Lake Road in Antioch, Lake County, Illinois

Neumann Homes
Attn.: Mr. Morgan James
4355 Weaver Parkway
Warrenville, Illinois  60555

Dear Mr. Morgan:

Enclosed are copies of the comment letters the U.S. Army Corps of Engineers received in response to the public notice issued for the above-referenced project.

Various concerns were raised in the comment letters that must be addressed before a decision can be reached by this office on your application.  The concerns include:

a. Stormwater:  One of the major concerns is that drainage from the project site, both during construction and after construction, may adversely affect Redwing Slough, Antioch Bog and other lakes/wetlands on and off the project site. Furthermore, these areas may be affected long term by lawn chemicals, pesticides, salt, herbicides, etc.

b. Mitigation:  The adequacy of the proposed mitigation cannot be evaluated due to lack of information.  There are also concerns regarding the appropriateness of a reduced mitigation ratio due to the presence of highly sensitive areas.

c. Upland habitat:  There are serious concerns regarding the loss of overall habitat values that will result from the proposed clearing of the oak savannahs and evergreen forests that currently exist on the project site.

d. Management plans:  Management plans need to be developed for the existing high quality wetland complexes on the property. Without appropriate management, these areas will degrade further upon construction of the subdivision.  We also recommend long term ownership and management of the wetlands and buffers by an experienced land management agency or non-profit agency.

e. Wetland impacts/mitigation:  Wetland impact areas, buffers and mitigation areas were not clear on any plans submitted thus far.  The project may not satisfy Section 404(b) (1) Guidelines because it is not a water dependent activity and it is presumed that there are alternatives to the project as proposed.  Without adequate site plans, it is difficult to evaluate the stormwater management, best management practices, and buffers for adequacy in protecting wetlands.

f. Wetland delineation review:  The U.S. Fish and Wildlife Service has requested a field review of the wetland delineation during the growing season.  We strongly suggest you coordinate a meeting with the appropriate federal, state and local agencies.

g. Tile Survey:  A complete tile survey is necessary to locate the vast amount of tiles on the property.

h. Illinois Department of Natural Resources-Endangered Species Consultation:  IDNR consultation must be completed prior to any permit decision by the U.S. Army Corps of Engineers.

i. Flooding:  There is a paramount concern regarding flooding within the vicinity of the proposed project.  Many nearby residents currently experience significant flooding.  Part of the proposed project will be built in a floodplain.  It is imperative that you demonstrate how your proposed project will not exasperate flooding problems in the area.  In doing so, you must also prove that the wetlands located on-site will not be used as detention.  I has been noted that frequent inundation of wetlands by urban runoff causes notable degradation to wetlands.

j. Alternatives:  Alternatives to the proposed project must be examined.

k. Endangered and threatened species:  To what extent will endangered and threatened species (plant and animal) be effected? A growing season field visit is recommended to document the presence and location of these species.

l. Natural hydrology:  A residential development of this magnitude poses serious threats to the natural hydrology of the on-site wetlands and the two nearby Illinois Natural Inventory Sites (Antioch Bog and Deer Lake-Red Wing Slough).

m. Drinking water supply:  There are concerns regarding the source of the drinking water for the proposed development.  The proposed water supply is located 3.5 miles from a superfund site. Furthermore, there are concerns regarding human waste, septic material and ammonia tanks that were allegedly dumped in the northeast corner of the site.  The Environmental Protection Agency and the Lake County Health Department need to be contacted regarding this matter.

n. Erosion:  There are concerns regarding erosion into existing wetlands and lakes due to mass grading and the removal of a significant amount of trees on the project site.

o. Traffic:  How will the local roads accommodate a significant increase in traffic?

In accordance with Title 33 of the Code of Federal Regulations Part 325.2(a) (3), this office requests that you review the letters and furnish your views on the issues raised to assist us in determining whether the project is in the public interest. You may contact persons objecting to your proposal in an attempt to resolve their concerns.  You must however submit a written response to the letters to this office within 30 days of the date of this letter.  Your response should attempt to resolve or rebut each of the concerns raised.  If you require more time to provide a response, please contact this office as soon as possible.

Your prompt attention to this matter will enable the Corps of Engineers to proceed with the evaluation of your application in a timely manner.  If you do not provide your response within 30 days of the date of this letter (and you have not been granted additional time), it will be presumed that you no longer wish to pursue the project and your application will be withdrawn without further notification.

Once again, this office strongly recommends that you schedule a meeting with the Federal and state agencies most likely to be involved in the permit review process.  These agencies include the U.S. Fish and Wildlife Service, U.S. Environmental Protection Agency, Illinois Environmental Protection Agency and the Illinois Department of Natural Resources.

A copy of this letter is being forwarded to each of the commenting parties to acknowledge receipt of their letter.  If you have any questions, please contact Ms. Marcy Knysz by telephone at (312) 353-6428, extension 4032, or email at marcy.r.knysz@usace.army.mil .
 

Sincerely, Leesa A Beal Chief, Permit Section Regulatory Branch

Enclosures

Copies Furnished (w/o enclosures)

U.S. Fish and Wildlife Service (Mengler)
Illinois Environmental Protection Agency (Yurdin)
Illinois Department of Natural Resources/OWR (Jereb)
Illinois Department of Natural Resources (Shank)
Illinois Department of Natural Resources (Semel)
Illinois Nature Preserves Commission (Byers)
Lake County Stormwater Management Commission (Corona)
Lake County Soil and Water Conservation District (Vaughan)
Lake County Health Department (Pfister)
Natural Resources Conservation District (Brandt)
Village of Antioch (Silhan)
Christopher B. Burke Engineering (Lingle)
Commentors