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Sample Comment Letter to U.S. Army Corps of Engineers
Regarding the Arrowhead-Weston Transmission Line

Robert J. Whiting
Chief, Regulatory Branch
St. Paul District, Corps of Engineers
190 Fifth Street East
St. Paul, Minnesota 55101-1638

REFER TO 03-04029-TJF       

Section 404 - Clean Water Act And  Section 10 - Rivers and Harbors Act of 1899

The proposed Arrowhead-Weston 345,000 volt bulk transfer line (AW-BTL)
would cause environmental damage throughout its 220 mile route across
northwestern Wisconsin. At this time this route is still not determined.
The single pole steel towers ranging between 125 to 180 feet in height
with poured cement bases up to 50 feet in circumference and 50 feet deep
pose a serious threat to northwestern Wisconsin's wetlands, streams and

Wisconsin DNR permits have not yet been applied for, nor have they been
granted approval.

It is known, however, that the Wisconsin DNR did cite the proposed
AW-BTL as being the "most environmentally damaging route" of all
alternatives presented during the initial CPCN permit hearings.

The Public Service Commission (PSC)granted the AW-BTL "certificate of
public convenience and necessity" (CPCN) based the decision on an
inadequate Environmental Impact Study (EIS). The EIS did not address any
"on-the ground" environmental impacts, because it was programmatic. The
exact number of wetlands and the extent of the wetlands proposed to be
filled, drained and damaged remains to be unknown at this time.
The U.S. Army Corps of Engineers was not provided adequate wetland,
stream and river information by the utilities proposing the AW-BTL.
The National Parks Service (NPS) is still reviewing the impacts on the
"Wild and Scenic" Namekagon River and has yet to make a decision or
issue a final EIS, arguably the Corps has a duty to factor that into an
EIS for what it does under NEPA.

Lastly, because of the extensive impacts on the many wetlands, rivers
and streams in northwestern Wisconsin the Army Corps of Engineers (the
Corps) must undertake a complete EIS for the full length of the project
and all the permits needed for each wetland crossing.  If not, the Corps
may be improperly segmenting the project under NEPA.

This proposed AW-BTL is the largest transmission project in the country.
Anything less than a full and complete EIS by the USACE on this bulk
transfer line will be inadequate.