February 6

February 6, 2001

District Engineer

U.S. Army Corps of Engineers, Rock Island District

Clocktower Bldg. - P. O. Box 2004

Rock Island, IL  61204

attn:  Mr. Neal Johnson

<neal.j.johnson@usace.army.mil>

Iowa Department of Natural Resources

900 East Grand Ave.

Des Moines, Iowa  50319

attn:  Ms. Chris Schwake

<christine.schwake@dnr.state.ia.us>

Dear Mr. Johnson and Ms. Schwake:

In comments on the previous Joint Public Notice for the Eddyville Bypass,

the Iowa Prairie Network was concerned about three major aspects of the

project:  1) the EIS analysis of alternatives; 2) the wetland mitigation

proposal; and 3) the secondary and cumulative effects of the Near East

alternative.

1)  Apparently the IDOT still makes impact comparisons using a Far East

alternative that was intended to be a non-contender.

2)  The wetland mitigation proposal is much improved.

3)  The secondary and cumulative effects of the Near East alternative have

been greatly lessened by changes made to the project.

IPN requests that the 401 and 404 permits under consideration for the

Eddyville Bypass carry the following conditions:

1.  Temporary animal barriers around all construction zones and haul roads

in the Dunes.  Permanent animal barriers along the bypass mainline,

interchanges, and interchange access road in the Dunes prior to removal of

the temporary barriers.  This should include the Mahaska County area as well

as the Wapello County area.  Periodic checking and maintenance of barriers

should be conducted during and after construction by the IDOT.

2.  Temporary asphalt surfacing of 182nd St. may not widen the existing

road; no work in the foreslopes or backslopes of the ditches.  In the area

of W-25, the asphalt surface must be removed after construction.

3.  Permanent fencing at the Mahaska and Wapello County preservation sites

to discourage dumping of garbage and ATV use, yet allow for small animal

movement.

4.  Use of local ecotype seed for all restoration or enhancement work,

wetland buffers, and permanent IDOT right-of-ways.  The use of local-ecotype

seed is essential for the genetic protection of Eddyville natural areas.  We

ask that the IDOT fully comply with the County Conservation Boards' request

for local ecotype seed, meaning seed that has genetic origins in local

native natural areas as close to the Eddyville area as possible, and

excluding cultivars, naturalized species, and "native" species that are not

native to

the Eddyville area.

5.  IPN appreciates the IDOT's efforts to minimize the wetland impacts of

the project.  However, several nice wetlands will still be destroyed.  IPN

suggests that, as a last resort, the IDOT undertake salvage of any desirable

plant materials from these areas.  Wetland restoration sites might be

improved by the relocation of plant materials.  If successful, relocation

might preserve species diversity, genetic diversity, important soil

microorganisms, etc. that would otherwise be lost.

6. We request that the IDOT, after consulting with the County Conservation

Boards, include sufficient funds to ensure the success of the stated goals

to preserve and restore the wetlands and sand prairies being given to

Mahaska and Wapello counties.  This funding will benefit the public and

demonstrate the commitment of the IDOT to protect these important natural

areas.

7.  Follow-up mitigation monitoring to determine the actual success of the

mitigation plan, with a provision to require additional measures in the

event of only partial success or failure.

8.  Additional wetland mitigation should be included to meet the "no net

loss" criteria.

The Iowa Prairie Network commends the IDOT for recognizing the importance of

setting aside the wetlands and sand prairies of the right-of-way that had

been acquired for the original Near East alternative.  Places like these are

extremely rare in our state, and merit the consideration of "exceptional

circumstances" in order to preserve them.  Iowa has suffered tremendous

destruction and degradation of her natural landscape, and every effort made

toward preserving and restoring what little remains is worthwhile.  The Iowa

Prairie Network also appreciates the IDOT's efforts to protect the

preservation and  mitigation sites from secondary harm.  This greatly

enhances their value as places for future generations to learn about, and

enjoy, Iowa's prairie heritage.

The Iowa Prairie Network is a state-wide, non-profit volunteer organization

whose mission is to "learn about, teach about, enjoy and protect Iowa's

prairie heritage."  Thank you for the opportunity to comment.

Sincerely,

Dave Hansen, IPN President

CC:   Mr. Mark Wandro, Director, IDOT