Sample Comment Letter to U.S. Army Corps of Engineers

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

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
rivers.

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.

1. The entire "Hauer Creek-Summit Lake wetland west of the Lac
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 Washburn
County, commonly referred to as "Chittamo Bog", which serves as a
wetland for the Namekagon River has not been adequately addressed by the
USACE. It should be further noted, for the record, that the Chittamo Bog
is located completely within the Washburn County forest lands and has no
access roads leading to it. Utility estimates of 20-30 trips per steel
pole would cause irreparable damage to the surrounding wetlands.

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.