116 Hamilton Place  Vernon Hills, IL 60061-1041  November 4, 2001
	Sierra Club Woods & Wetlands Group

Regarding the Rt. 53 Draft Environmental Impact Statement:

The Woods & Wetlands Group of the Sierra Club represents the environmental concerns of 2300 members in NE Cook and Lake County. The DEIS is our chance to assess the damage that the Rt. 53 extension would cause, scrutinize whether it would provide the benefits promised, and weigh these against the baseline and alternative plans. We are concerned that serious flaws in this DEIS prevent us from doing so.

In releasing the DEIS, you (IDOTand the Toll Highway Authority) have presented baseline and transit improvements as insufficient, and asked us to choose between the Rt. 53 sprawl invitation, and to consider a plan that includes a ludicrous St. Mary's Road expansion as an alternative. We find this contemptuous. You show how this poor alternative impacts more homes and businesses than Rt. 53, and present Rt. 53's higher wetlands and agricultural impacts as a reasonable tradeoff. We find this misleading and unreasonable. You indicate that 53 would not relieve as much local traffic congestion. We find this an understatement.

We raise these specific problems with the DEIS:

• It assumes predominant N-S traffic patterns, ignores data calling for NW-SE improvements to access employment, and recommends wrong remedies to the wrong problem. The maps you present confirm the dense employment areas in the SE corner of the area. The Rt. 53 plan does not provide improved access to those jobs. This incorrect assumption invalidates the DEIS conclusions.
• It grossly understates the impacts of Rt. 53 to remote wetland systems by ignoring contiguous wetlands beyond the narrow corridor; and, by focusing on impacts to flowing streams, ignores the impact of runoff on sensitive isolated wetland and headwater ecosystems. Your questionable expectations that poor municipal stewardship of our region’s wetlands will overshadow impacts from Rt. 53 should not relieve you from considering its impacts beyond the corridor.
• Inclusion of St. Mary's road in the "alternative" makes the detailed distinctions between impacted pristine wetland acres and degraded acres - which seem to favor 53 - ridiculous. More ambitious transit proposals seem more appropriate to move commuters from more densely populated areas around this river and wetland rich area to employment centers to the SE.
• The DEIS ignores and dismisses the future impacts of new highway sprawl, tallying land use impacts only within a half mile of the 53 corridor, and blaming "reasons other than transportation" for an expected loss of more than 90% (5,500 acres) of the open space presently there. The Rt. 53 extension has been an imaginary threat for decades. It is unreasonable to expect municipalities not to modify their zoning ordinances to reflect the actual presence of a new 6 lane limited access highway inside their boundaries should that unlikely event actually occur.
• It dismisses long-term groundwater impacts without accounting for a significant fraction of the salt and other roadway pollutants, defers noise abatement issues until after approval, and is tragically incomplete in its evaluation of air pollution in a corridor that encroaches on homes and schools. These impacts likely contribute to findings that highway corridors can create cancer corridors.
• The baseline improvements are limited, unimaginative, overdue, and underrated, and additional transit improvements are only included in package deals with the poor road "choices." With such slow progress being made toward baseline improvements, we challenge whether it is realistic - and point out the irony - to call it the "No Build" scenario. For instance, dozens of simple intersection improvements could quickly and economically augment the baseline, but only two are indicated. Expanded use of our existing rail network could access additional areas, but only double tracking the WI Central is included. Badly needed RR overpasses are totally missing. There are many common sense remedies to our traffic problems that have been overlooked amid this grandiose and expensive tollway justification exercise.

Evan L. Craig  Chair
PROTECT AMERICA'S ENVIRONMENT For our Families ... For our Future