Sample Comment Letter to U.S. Army Corps
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
would cause environmental damage throughout its 220 mile route across
northwestern Wisconsin. At this time this route is still not
The single pole steel towers ranging between 125 to 180 feet in
with poured cement bases up to 50 feet in circumference and 50 feet
pose a serious threat to northwestern Wisconsin's wetlands, streams
Wisconsin DNR permits have not yet been applied for, nor have they
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
"on-the ground" environmental impacts, because it was programmatic.
exact number of wetlands and the extent of the wetlands proposed to
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
1. The entire "Hauer Creek-Summit Lake wetland west of
Courte Oreilles Ojibwe reservation, Sawyer County was left completely
off the USACE permit map.
2. The extent and depth of the eight mile long bog in
County, commonly referred to as "Chittamo Bog", which serves as a
wetland for the Namekagon River has not been adequately addressed by
USACE. It should be further noted, for the record, that the Chittamo
is located completely within the Washburn County forest lands and has
access roads leading to it. Utility estimates of 20-30 trips per
pole would cause irreparable damage to the surrounding wetlands.
"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
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
Corps) must undertake a complete EIS for the full length of the
and all the permits needed for each wetland crossing. If not, the
may be improperly segmenting the project under NEPA.
This proposed AW-BTL is the largest transmission project in the
Anything less than a full and complete EIS by the USACE on this bulk
transfer line will be inadequate.