EDDYVILLE DUNES A NATURAL HERITAGE OF THE STATE

COMMENTS NEEDED BY OCTOBER 26, 1998

The wind-blown sands of Eddyville Dunes were deposited 12-15,000 years ago
in a process very similar to the formation of Iowa's Loess Hills.  The sand
deposits of the "Dunes" are up to 60 feet thick and there are also numerous
open water wetlands and wet meadows in the 1200 acres.  The state
endangered pale-green or tubercled orchid and seven species of special
concern have been found there.

Dr. Jim Christiansen of Drake University performed a survey of the area in
1997, which showed ornate box turtle, a state threatened species,  and
Blanding's turtle, a marsh species of Federal special concern..  He wrote
that the Eddyville site represents "one of the most complete, although
fragile, prairie communities present in Iowa."

The Eddyville Dunes are the site of the proposed Highway 63 Bypass around
the town of Eddyville.  As a result of public and agency comments to their
original plan, the Iowa Department of Transportation (IDOT) has shifted the
south end of the selected "Near East Alternative" to the west.  The IDOT
has offered to "set-aside" a portion of the Dunes in the vicinity of 182nd
Street as mitigation for the project's impacts.

CONCERNS REMAIN

The IDOT should be more diligent about avoiding impacts in the design of
all of the alternatives, and be more thorough and fair in comparing those
alternatives.  Can the IDOT actually build the redesigned [west shift of
the] Near East Alternative without hydrological impacts to the Dunes and
the unique habitats there?  The realignment will impact sand prairie and
wetlands (some high-quality hillside seeps) west of the original alignment.


Does the "set-aside" area proposed offer adequate compensation for sand
prairie destruction and habitat fragmentation?  Will the set-aside land
sustain the existing biological community?  Is it large enough to be
sustainable?  Shouldn't there be better provisions for state-protected
species?  Does the creation of open-water wetland (as IDOT has suggested)
compensate for the values and functions of hillside seeps which support
unique species?

What about secondary and cumulative effects of the project – how will
future development impact the "set-aside" area?  Will development also
occur further east on 182nd Street, which would lead to pressure to widen
182nd Street through the "preserve"?  The secondary and cumulative effects
of the project require more attention.  What provisions are there for
management of the "set-aside" area?  What provisions are there for its
actual protection?

These issues are not adequately addressed in the Final Environmental Impact
Statement.

IOWA CODE REQUIREMENTS

Iowa Code requires that "Cities, counties, and the department [DOT] shall
to the extent practicable, preserve and protect the natural and historic
heritage of the state in the design, construction, reconstruction,
relocation, repair, or maintenance of roads, streets, or highways.
Destruction or damage to natural areas, including but not limited to prime
agricultural land, parks, preserves woodlands, wetlands, recreation areas,
greenbelts, historical sites, or archaeological sites shall be avoided, if
reasonable alternatives are available for the location of roads, streets,
or highways at no significantly greater cost.  In implementing this
section, cities, counties, and the department [DOT] shall make a diligent
effort to identify and examine the comparative cost of utilizing
alternative locations for roads, streets, or highways."

PRESERVE UNIQUE LANDFORMS AND NATURAL AREAS

The Eddyville Dunes represent a unique landform for the State of Iowa and
provide habitat for a variety of threatened and endangered species and
species of special concern.  The 182nd Street Property represents a
sandhill community that has disappeared from Iowa except for a few small
areas around the state.

Fragmentation of this unique environment will result in the destruction of
another irreplaceable ecosystem.  The delicacy of this unique ecosystem
makes mitigation possibilities risky, at best.  Attempting to relocate or
mitigate an ecosystem that has taken centuries to create is another attempt
to manage an environment that no man will ever fully understand.

If you are concerned about our few remaining unique natural areas in Iowa,
please consider writing to express your views to any or all of the
following people.  Write that you as a taxpayer want an adequate
Environmental  Impact Statement.  Tell them you want threatened and
endangered  species protected.  Tell them you don't want a "pre-determined"
route to take priority over state and federal laws.  Tell them this natural
area and these endangered pale-green orchids are an "irretrievable asset"
and constructing a road through the unique resources of the Dunes will have
"irreversible effects" on Iowa and our quality of life.

Send a letter to the DOT and the Federal Highway Administration and tell
them you want an impartial assessment of alternatives and a balanced
consideration of impacts:
COMMENTS NEEDED BY OCTOBER 26, 1998


Harry Budd
Director
Office of Project Planning
Iowa Department of Transportation
Ames, IA 50010

Bobby Blackmon
Iowa Division
Federal Highway Administration
105 Sixth Street
Ames, IA 50010

Remind the U.S. Army Corps of Engineers of its responsibility to seek the
least environmentally damaging practical alternative, and to require
adequate documentation of such:

Neal Johnson
U.S. Army Corps of Engineers
Clocktower Building, P.O. Box 2004
Rock Island, IL 61204-2004

SEND COPIES TO:
Mr. Allen Farris
IDNR Fish and Wildlife Bureau
Wallace State Office Building,
Des Moines, 50319-0034

Dr. Jake Joyce
US Environmental Protection Agency
Region VII
726 Minnesota Avenue
Kansas City, KS 66101

Senator Tom Harkin
531 Hart Senate Office Building
Washington, DC 20510

Senator Charles Grassley
135 Hart Senate Office Building
Washington, DC 20510

Congressman Leonard Boswell
1029 Longworth House Office Bldg.
Washington DC 20515-1503

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