116 Hamilton Place Vernon Hills, IL 60061-1041 July 18, 1999
	Sierra Club Woods & Wetlands Group

Dear Ms. Gordon:

I chair the Woods & Wetlands Group of the Sierra Club, with 2000 members from most of Lake County, and parts of the Des Plaines River watershed into Cook County. I write representing their concerns for the preservation of the Lake County environment, requesting that you deny the application 199900678 under Section 404 of the Clean Water Act of 1972 (33 U.S.C. 1344) by Indeck to destroy or impact over three acres of wetlands.

We find this application unacceptable for these reasons:

1. Wetlands  These wetlands, if destroyed, will not be replaced locally, and the ecological and hydrological value they presently contribute will be lost. Instead, Indeck proposes ineffective "in-lieu fee payments" and problematic remote wetland mitigation banking. Historically, less than 40% of mitigation wetlands have survived as wetlands, and only a few percent have significant ecological value. The USACOE should enforce section 404 of the clean water act, which requires no net loss of wetlands, and exercise extreme reluctance to resort to mitigation until it is proved to be an effective measure over a significantly long term.

In addition, the targeted wetlands are in the Des Plaines River watershed, where the USACOE has failed to present an acceptable floodplain management plan, and is presently proposing yet another herculean undertaking (deep tunnel) to attempt to remedy the net impact of widespread wetland destruction in the wet lands of Lake County. Mitigation as proposed might likely occur outside the watershed where it will not replace the benefit of the present wetlands, to say nothing of the absorbent prairie soils.
2. Upland Alternative  This application fails to present any upland alternative whatsoever, as called for in the section 404 guidelines. The applicant has not addressed their need to use or discharge water from the facility (see below), so location away from wetlands is not contraindicated.
3. Water Use and Disposal Our present understanding based on a similar plant proposed for McHenry is that the proposed facility will intake around 100,000 gallons of water per day. This is not mentioned in the application notification, and we request that the many possible impacts be added to the application. This includes: the intended source for this supply of water, what contaminants in the water not suitable for the process will be removed, how those contaminants will be disposed of, what the quality of the discharge stream will be, where it will be discharged, and what the consequences of such discharge and disposal will likely be. Because these materials might include radioactive material from the aquifer (common in this area), and will likely be at elevated temperature, or as water vapor with micro-particulates, the discharge might likely adversely impact our waters and our environment, or precipitate fog. We are also concerned that such great usage not overdraw our quota of Lake Michigan or aquifer water and divert it into the local stormwater treatment system, and overburdened Des Plaines River. Considering the number and magnitude of possible impacts related to this issue, please consider including an environmental impact statement to this application.
4. Misrepresentation  The sourcing and discharge of the quantities of water discussed above could have significant impacts on the ability of the source (aquifer or Lake Michigan) to provide, and the receiver (wetland, stormwater treatment, Des Plaines River) to process and absorb; and so should have been disclosed in the permit.

In addition, the application states that the peaking facility will generate electricity to Lake County users during peak demand periods. However, electricity generating sources for the Lake County area are already adequate. The electricity placed on the grid by this plant if constructed will more likely supply the needs of Chicago and Indiana.
5. Species Inventory  A short hike at the site revealed species indicative of a rich native ecosystem where endangered plants and animals might occur: Prairie Dock, Purple Coneflower, Prairie Coneflower, Bergamot, Milkweed, Goldenrod, bunch grasses, hundreds of frogs, and other wildlife. See pictures. I have contacted you, the USF&WS, and the IDNR to ascertain when the most recent species inventory was done, and what species were listed. Although you have visited the site and performed a brief survey, neither you nor these agencies have cited any thorough, recent inventory of the site. Please request a formal consultation with the USF&WS, and obtain a thorough inventory as part of your review of this permit.
6. Hazardous Debris  There are several broken tanks on the site which may have released toxic materials into the soils. Disturbance of the soils could mobilize these materials, or further release them into our waters. This was not disclosed on the application, and we ask that you refer possible remedial action to the EPA. See pictures.
7. Pollution  This plant will annually release over 300 tons of regulated pollutants into the air we breathe. This includes 173 tons of smog forming NOX (nitrous oxides), 105 tons of poisonous CO (carbon monoxide), 20 tons of choking PM10 (particulate matter), and 10 tons of corrosive SO2 (sulfur dioxide). Although this plant would pollute less than the filthy coal plants in operation in Illinois, it would still release thousands of tons of CO2, responsible for global warming. Additional releases of ozone creating NOX of this magnitude, considering the fact that we live in an unhealthy ozone non-attainment area already, are irresponsible. There are better options: electricity conservation, efficiency, renewables. Please ask the EPA to review their decision.
8. Employment  The plant will be remotely operable, and provide only 2 on site jobs. We question whether this warrants destruction and damage to our local environment.

Pictures:

Tanks

First tank.

Arrow points to second tank, in this woodland swamp.

Plants & Animals

Thank you for your attention to this. Sincerely, Evan L. Craig Chair