116 Hamilton Place
Vernon Hills, IL 60061-1041
June 1, 2001
Sierra Club Woods & Wetlands Group

U.S. Army Corps of Engineers 
Chicago District, Regulatory Branch 
Attn: 200001139, Mr. Michael Murphy 
111 North Canal Street, 6th floor 
Chicago, Illinois 60606-7206
Dear Mr. Murphy:
The Woods and Wetlands group of the Sierra Club promotes enjoyment and protection of the environment in the north east Illinois region. The Group includes 2000 Sierra Club members in Lake and Northeastern Cook counties, with over 30 members in Lincolnshire. We object to the above referenced proposal to fill wetlands.
We are gravely concerned by the continuing reduction in size and decline in quality of our wildlife areas, and the loss of the benefits that these areas provide. Moreover, we are alarmed that the topsoil that confers these benefits, and has survived erosion from conversion of prairies to farmland, is now being totally stripped away to support construction of superimposed biologically dysfunctional suburbs. While wetlands serve an important function, we are convinced that removal of topsoil to create them is an unwarranted sacrifice, and will be an unsuccessful approach. The permeable soils of Illinois serve not only to absorb and cleanse runoff; they also moderate its flow, and generate hydrology that supports the native matrix of biodiversity and the health of our ecosystems. We object to the proposed excavation within the wetlands and the floodplain for either development or mitigation purposes.
We have reviewed the wetland fill notice. While it serves some mutual concerns, it draws different conclusions, and it raises many other concerns. 
Invasive species.	The site presently supports a large area of Teasel on the uplands. This stress tolerant exotic species grows to the exclusion of more beneficial native plants and should be removed. The applicant wants to replace it with blacktop. We think it should be replaced by native grasses and flowering plants that will help buffer the existing wetlands from polluted runoff and other stresses.
Stressed conditions.	The open wetland areas of the site are presently covered almost completely with invasive canary grass. Predominance of this plant indicates that the area has been highly disturbed. Rather than use this as a justification for drastically altering the present hydrology, development of the site should instead include additional buffer zones to reduce the stresses on the existing wetlands, and a restoration and maintenance plan to displace the invasives.
Floodplain.	Floodplains are subject to radical changes in water level, and a flux of nutrients and pollutants carried by the flow. . Healthy wetlands do not tolerate these conditions. The applicant claims wetland mitigation in the floodplain as an enhancement. We disagree. Mitigation of wetlands in floodplains should not be permitted. If permitted, it should not be credited for either floodplain or wetland mitigation. 
Wetlands.	The existing wetlands include wooded wetlands with stable hydrology, and healthy understory flora. This ecosystem is rare and should not be damaged. The mature trees on the site should be preserved. Pollutants stressing the existing wetlands should be reduced. Buffers should be provided and improved to protect these wetlands. The proposal includes an ambitious proposal to introduce native wetland species, but many of these species are not well chosen, and in total, do not represent a comparable replacement for the existing mature wooded wetlands.
Mitigation.	Any mitigation allowed on the site should be limited to areas with soils that evidence previous wetlands, that is presently drained, and offers the opportunity for proper on-site buffers. Off-site mitigation of large wetlands areas, as proposed, should not be permitted outside the immediate sub-watershed area where the runoff can be successfully absorbed. 
Scale.	The developer seeks to radically alter the entire wetland area, and superimpose a new drainage regime. Experience has shown this approach to be unsuccessful. Instead, they should reference historical hydrological patterns, seek to restore them, and minimize any other wetland impacts. There is no evidence of any such effort in the notice. 
Alternatives.	None are given. Too much development has been allowed in communities in the floodplain, and proximity should not be considered justification for more. Upland alternatives should be considered and presented by the developer before floodplain or wetland fill is proposed.
Need.	There are several other grocery stores within 5 miles of this location. We don't need another one, and the applicant has not demonstrated otherwise. The principal neighboring property is the Mariott, and the Forest Preserve District. These neighbors, and the general public will be much better served by preservation of the existing wetlands.
Sincerely,



Evan L. Craig
Group Chair

c:	IEPA
	IDNR
	LCSMC
	Mr. Anthony DeSantis