A garbage dump proposed next to a World Heritage Site (cont'd)

Dear Mr. Myers: I am responding to your electronic message sent to the Headquarters, U.S. Army Corps of Engineers, expressing your concerns regarding a Clean Water Act Section 404 permit application filed with the St. Louis District on April 6, 2005. The applicant is Waste Management of Illinois, Inc. The applicant is requesting to borrow fill material from a 222 acre parcel adjacent to its existing Milam Recycling and Disposal Facility (RDF) in St. Clair County, Illinois. The borrowed material would be used at the Milam RDF for daily cover activities and the 222 acre tract, currently referred to as North Milam, would subsequently be used as an extension of the Milam RDF when that facility reaches its capacity. The Milam RDF has been operating for the last 20 years and is expected to reach capacity within the next five years. Approximately 18 acres of wetlands would be impacted by the proposed activity and approximately 27 acres of wetlands would be avoided in the North Milam tract. In addition to the Federal 404 permit application, Waste Management has also applied for county and state permits and licenses to operate the RDF extension. The existing Milam and proposed North Milam RDFs are located approximately two miles from the Cahokia Mound Complex and Archeological Site. Cahokia is a National Historic Landmark and a World Heritage Site. Separate from the proposed activity's proximity to Cahokia, the applicant has conducted surveys within the North Milam tract pursuant to requirements of the National Historic Preservation Act and the National Environmental Policy Act. Historic properties have been discovered at several locations within the North Milam tract and the St. Louis District, the Illinois State Historic Preservation Office and the applicant are currently considering treatment/mitigation options for these historic properties. The St. Louis District Commander, his Regulatory Branch and the district archeological specialists appreciate and understand the importance of Cahokia, the heritage assets within the proposed project tract, the concerns of federally recognized Indian tribes and views expressed by concerned citizens. They have been, and will continue to, coordinate and consult with all parties that have an expressed or required interest in the Corps treatment of the cultural environment. Your continuing interest and/or involvement in the public interest review for this permit application will assure that St. Louis District considers and evaluates all factors prior to reaching a decision on the North Milam RDF proposal. Sincerely, Paul D. Rubenstein Deputy Federal Preservation Officer Office of the Chief of Engineers