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Colonel Roger Baldwin <br /> August 30, 1989 <br /> Page 2 <br /> corridor . Primary environmental corridors are continuous systems <br /> of environmentally sensitive land and resources that require special <br /> protection from disturbance and development . Joint EPA/Corps of <br /> Engineers guidelines issued November 6 , 1985 , state that : <br /> "The discharge . . . of fill material into the waters of <br /> the U.S . located within Primary Environmental Corridors . <br /> will fail to comply with secs . 230 . 10 (a) and ( c) of the <br /> ( Clean Water Act ) Guidelines , and all such waters should <br /> be considered as generally unsuitable for disposal site <br /> specification. " <br /> _Because the proposed fill area lies within a designated Primary <br /> Environmental Corridor , the permit should be denied. <br /> III . THE MITIGATION PROPOSAL SET OUT IN THE PUBLIC NOTICE IS <br /> INADEQUATE. <br /> As mitigation for filling approximately fifteen acres of <br /> wetland, the applicant proposes to set aside two acres for creation <br /> of a wildlife area, to include a shallow wildlife pond approximately <br /> one-half acre in size . The Wisconsin Public Intervenor is in <br /> agreement with U . S. Fish and Wildlife Service , Wisconsin Wetlands <br /> Association and the Bureau of Indian Affairs ( letter attached) that <br /> the proposed mitigation is inadequate in scope and in quality to <br /> replace the values that would be lost . The preservation of two <br /> acres of existing wetlands cannot be considered a valid substitute <br /> for the loss of a fifteen acre expanse of wetland . <br /> IV. DESTRUCTION 07 WETLANDS IS NOT IN THE PUBLIC INTEREST. <br /> The steady loss of wetlands is so harmful to the environment <br /> that both EPA and Corps of Engineers regulations make their <br /> preservation a national priority. 40 C .F.R. § 230 . 1 (d) states the <br /> following guideline for wetland preservation: <br /> From a national perspective , the degradation or <br /> destruction of special aquatic sites , such as filling <br /> operation in Wetlands is considered to be among the most <br /> severe environmental impacts covered by these Guidelines . <br /> The guiding principle should be that degradation or <br /> destruction of special sites may represent an irreversible <br /> loss of valuable aquatic resources . <br /> (Emphasis added. ) 33 C . F.R. 4 320 . 4 (b) ( 1 ) states a similar concern <br /> for wetland preservation: "Some wetlands are vital areas that <br /> constitute a productive and valuable public resource, the <br />