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 ---------------------------------------------------------------------- To get off the IOWA-TOPICS list, send email to [log in to unmask] Make the message text (not the Subject): SIGNOFF IOWA-TOPICS