May 31, 2001

Illinois Environmental Protection Agency
Division of Water Pollution Control, Permit Section #15
1021 N. Grand Avenue East
P.O. Box 19276
Springfield, Illinois 62794-9276

Illinois Department of Natural Resources
Office of Water Resources
201 W. Center Ct.
Schaumburg, Illinois 60196-1096

Public Notice/Application Number 200001139
Mr. Anthony DeSantis

The Illinois Chapter of the Sierra Club hereby objects to the proposal to fill 12.85 acres of floodplain wetlands in the Indian Creek watershed for a commercial development. The Sierra Club has numerous numbers members who live in the Indian Creek watershed and nearby areas who may be adversely affected by destruction of wildlife, lowering of water quality or increased flooding cause by this project.

The bases for the Sierra Club objections are as follows:
 

1. The draft permit has not been developed in sufficient detail to give notice to the public of the project or for the Corps, Illinois EPA and IDNR to give it proper consideration. Most obviously, the specific mitigation and mitigation ration should be determined before the public and the agencies are called upon to make final comments and render final decisions on the proposal.
   
   
2. It does not appear that any efforts have been made to avoid wetland impacts. A commercial development is certainly not water dependent. There are upland sites where the proposed facility could be built. The proposed destruction of wetlands is not necessary to accommodate important social or economic development.
   
   
3. To the extent the mitigation is spelled out, it does not appear that the proposed mitigation is adequate. A project such as this should have at least a 3:1 mitigation ratio. Wetland mitigation should be done by restoring prior converted wetlands rather than digging a wetland out of riparian areas. Further, it does not appear that measures to provide compensatory flood retention capacity are sound. 
   
   
4. The floodplain forest community to be destroyed by this proposal is of great ecological value. Destroying this community to build stores and parking lots is not in the public interest. 
   
   
5. The project would adversely impact water quality in Indian Creek by destroying natural conditions, increasing impervious surface in the floodplain, and promoting run-off.

Submitted by,
Albert Ettinger
Water Issues Coordinator

cc: Mr. Anthony DeSantis