116 Hamilton Place Vernon Hills, IL 60061-1041 February 20, 2004
	Sierra Club Woods & Wetlands Group

Dear Ms. Thomas:

Regarding the 35 acres at I94 and IL 176 (Baker Property) and proposed development.

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 2500 Sierra Club members in Lake and Northeastern Cook counties, with hundreds living in the Green Oaks area.

Sierra Club has viewed this site and reviewed the recent development proposals for it. While modest in appearance, we are please to learn that the site supports a vital population of native plants, as indicated by the mean C floristic indices of the wetlands there. We are troubled that adjacent wetlands have already been crowded into ponds by development, and write to encourage the Plan Commission of Green Oaks to respect the boundaries of the Baker wetlands to assure that their quality survives and is improved in the future. This will require careful attention to restore and maintain the function of the site’s hydric soils in preventing surface runoff pollution from reaching the wetlands.

Although silt fencing has been installed on the NW corner of the property, storage of construction materials there appears to be encroaching on the necessary buffer areas. We encourage the Green Oaks Enforcement Officer to monitor this closely and take corrective action.

We are pleased to learn that the Commission and village attorney Johnson have rejected the recent development proposals for this site. We would like to add these concerns supporting our opposition to that plan and for consideration of any future plan for this site:

• Avoidance should not be limited to a discussion of the property in question. Other properties in the area that are not largely comprised of wetlands would be more suitable for development. As long as there are any wetlands impacts proposed, the actual proposed use of the site should be specifically justified as part of the basis of any comparison of the viability of this site to alternative sites. Any change to the proposed type of development (retail vs. office) should re-justify whether sacrificing wetlands on this site is a necessity.
   
• Minimization of wetland impacts should not include excavation or filling, as in the previous proposal. Onsite minimization should focus on avoidance, and on measures to increase buffers and improve their ability to filter pollutants out of runoff. The previous plan converted the buffers to berms and sedimentation ponds. Instead, plans should include swales and Best Management Practices to minimize impervious surfaces and mitigate runoff.
   
• The site includes a number of wetlands, and although they have been individually assessed and divided by jurisdiction, we encourage the Commission to consider the site as a whole as the headwaters of the N Branch of the Chicago River when contemplating the viability and impacts of any development proposal. The soils of our region, and the deep-rooted native plants that create them, perform a crucial function in absorbing and cleansing runoff. The removal, compaction, and covering of these soils for development degrades the quality of our waters, and should be avoided and minimized.
   
• Sierra Club supports well conceived, environmentally responsible development that stands the test of time for itself and its neighbors. It has come to our attention that the applicant has a poor record of fulfilling the wetland mitigation commitments in previous projects. Since long term maintenance is critical to any mitigation strategy, we urge the Commission to deny ambitious proposals that rely on long term performance of this developer.

We note that the development proposal includes a request for a variance. We respectfully suggest to the Commission to consider the loss of valuable open space to the region when contemplating variances, and to encourage the developer to offer permanent protection of open space elsewhere to offset the loss to the community.

Thank you for the service your committee is providing to your village.

Sincerely, Evan L. Craig Group Chair

c: Elaine Palmer, Green Oaks Village Administrator
    Rezek, Henry, Meisenheimer & Gende
    Stormwater Management Commission