August 21, 2001

David P. Boergers, Secretary,

Federal Energy Regulatory Commission,

888 First Street NE, Washington, DC 20426

Dear Mr. Boergers,

Audubon Missouri strongly opposes issuance of a preliminary permit for initial exploration for a pumped storage hydroelectric plant at Church Mountain in Reynolds County, Missouri. A resolution of the Audubon Missouri Board of Trustees is enclosed.

Audubon Missouri is the state office of the National Audubon Society, whose mission is to conserve and restore natural ecosystems, focusing on birds, other wildlife, and their habitats for the benefit of humanity and the earth’s biological diversity. There are approximately 9,000 members of the National Audubon Society in Missouri.

This project will have an unacceptable impact on the greater Taum Sauk area, which extends from Taum Sauk Mountain State Park on the east, through Johnson's Shut-ins State Park to Bell Mountain Wilderness Area on the west. We believe that the Taum Sauk area is a unique ecological and recreational resource for Missourians.

State and federal resource agencies have recognized this uniqueness by significant land acquisitions and special designations of lands in the area. The Missouri Department of Natural Resources has spent millions of dollars acquiring lands for Taum Sauk Mountain State Park and Johnson Shut-ins State Park. The interagency Missouri Natural Areas Committee has designated more than 7,000 acres of the highest quality land in this area as the St. Francois Mountains Natural Area, the largest natural area in the state. Virtually the entire Goggins Mountain addition to Johnson's Shut-Ins State Park was designated a State Wild Area (Missouri's largest) in 1995. The Missouri Clean Water Commission has designated the upper 5.5 miles of Taum Sauk Creek as a State Outstanding Resource Water. The Missouri Department of Conservation has also acquired more than 5,000 acres in the Ketcherside and Proffit Mountain Conservation areas. In 1980 the United States Congress designated the 9,000-acre Bell Mountain Wilderness Area in the Mark Twain National Forest. The Boy Scouts' Taum Sauk Trail, which has been an important resource for Boy Scout troops for decades, and the Ozark Trail, a long distance trail traversing the Missouri Ozarks, have been developed in the valley of Taum Sauk Creek.

There can be no question of the vast importance of the central "high peaks" region of the St. Francois Mountains, of which Church Mountain and Taum Sauk Creek are so integral a part. These ancient rounded mountains are so critical for their inherent natural history value, but they also have played an historical role of great importance; they are a time honored scenic treasure, and an enduring resource of wholesome recreation and spiritual inspiration. They are for many Missourians and visitors to Missouri the core of what remains of the oldest, wildest Ozark landscape. All of this has been reinforced through the latter twentieth century by a massive investment from the state of Missouri in the acquisition and protection of these lands.

Drilling of bore holes during geologic feasibility studies and blasting to level the top of the mountain and other construction activities would seriously disrupt recreation in the entire area for a period of years. The new dam and reservoir would be clearly visible in perpetuity from virtually every vantage point along trails in Taum Sauk State Park, especially from the most heavily visited areas, Taum Sauk lookout and Mina Sauk Falls, where Missourians have long sought the "wildest view in the state.

The proposed lower reservoir would flood approximately two miles of the Taum Sauk Creek State Outstanding Resource Water, most of which is included within the St. Francois Mountains Natural Area, obliterating its natural riparian zone and more than a mile of the Taum Sauk Boy Scout Trail. This would render the historic route along Taum Sauk Creek virtually unusable. The proposed project with its development and continued activity, including daily fluctuating water levels of perhaps fifteen feet, would result in major fragmentation and degradation of an ecosystem preserved at great investment by the public. Audubon Missouri is especially concerned about the ecological impact of major habitat fragmentation in the highest quality area that could be identified in Missouri in which to preserve a landscape-scale mosaic of the natural communities that make this part of the Ozarks a nationally significant area of biodiversity.

Finally, this project produces no net energy but requires about 3 kilowatts to pump the water uphill for every 2 kilowatts of hydroelectricity produced.

Audubon Missouri believes that Ameren Corporation officials should work with state and federal agencies as well as citizens' organizations to seek a resolution to the issue that is not only in the best public interest, but will eliminate any threats to the biological integrity of this area’s natural ecosystem. We are prepared to assist in seeking such a resolution.

In conclusion Audubon Missouri is opposed to the issuance of a preliminary permit for Project Number P-12049-000.

Sincerely yours,

Charles Burwick, President
Board of Trustees, Audubon Missouri

Roger Still, Executive Director
Audubon Missouri

Enclosure

Bob Holden, Governor
Charles W. Mueller, Chairman, President and CEO, Ameren Corporation
Dr. Susan Flader, President, Missouri Parks Association
Director, Division of Hydropower Administration and Compliance, FERC

AUDUBON MISSOURI

RESOLUTION ON CHURCH MOUNTAIN PUMPED STORAGE PROJECT

WHEREAS, The Audubon Missouri is the state office of the National Audubon Society whose mission is to conserve and restore natural ecosystems, focusing on birds, other wildlife, and their habitats for the benefit of humanity and the earth’s biological diversity; and,

WHEREAS, the approximately 9,000 Missouri members of the National Audubon Society are interested in conserving and restoring natural ecosystems, and,

WHEREAS, the Missouri Department of Natural Resources (DNR), Division of State Parks assembled more than 15,000 acres in Taum Sauk Mountain State Park and additions to Johnson’s Shut-Ins State Park from dozens of private landowners in the early 1990’s at a cost of nearly $3 million connecting to an equal acreage of high quality Conservation Department and U.S. Forest Service land running from Taum Sauk peak in the east to the Bell Mountain Wilderness in the west, for the purpose of protecting a representative sample of the high peaks region of the St. Francois Mountains at the geologic core of the Ozarks, maintaining and restoring biodiversity on a landscape scale, and providing wilderness-type recreation for the general public; and

WHEREAS, the interagency Missouri Natural Areas Committee has designated more than 7,000 acres of the highest quality land in this area as the St. Francois Mountains Natural Area, the largest natural area in the state, and the Missouri Clean Water Commission has designated the upper 5.5 miles of Taum Sauk Creek as a State Outstanding Resource Water; and

WHEREAS, the Ameren Development Company, a subsidiary of Ameren Corporation (parent of AmerenUE, formerly Union Electric), has filed an application for a preliminary permit with the Federal Energy Regulatory Commission (FERC) for the Church Mountain Pumped Storage Project, which would consist of a 130-acre reservoir ringed by a 12,350-foot-long 90-foot-high dam on top of Church Mountain, a 400-acre lower reservoir formed by a 1900-foot-long 100-foot-high dam on Taum Sauk Creek, and appurtenant facilities; and

WHEREAS, the proposed pumped storage project would consume more energy than it produces, requiring approximately three kilowatts of energy (likely from coal) to pump the water uphill for every two kilowatts of hydroelectricity it produces; and,

WHEREAS, the proposed lower reservoir would flood approximately two miles of the Taum Sauk Creek State Outstanding Resource Water, most of which is included within the St. Francois Mountains Natural Area, obliterating its natural riparian zone; and

WHEREAS, the proposed project with its development and continued activity, including daily fluctuating water levels of perhaps fifteen to twenty feet, would result in major fragmentation and degradation of an ecosystem preserved at great investment by the public specifically to prevent further fragmentation and degradation and to preserve a remnant of the wild St. Francois Mountain landscape; and

WHEREAS, Union Electric (now AmerenUE) has in the past shown public spirit and a willingness to cooperate with public agencies, notably in the granting of a 25-year lease to DNR for park trail development on its Church Mountain property adjacent to Taum Sauk State Park;

NOW THEREFORE, BE IT RESOLVED that Audubon Missouri strongly opposes the proposed Church Mountain Pumped Storage Project and calls on Missouri citizens and local, state, and federal officials to express their views to FERC, the governor, and Ameren on the natural, cultural and recreational values at stake in the Taum Sauk area; and

BE IT FURTHER RESOLVED that the Audubon Missouri communicate to Ameren officials its assessment of the values at stake in the Taum Sauk area and encourage them to reconsider their plans for a pumped storage facility on Church Mountain, offering to help seek a resolution to the issue that is not only in the best public interest, but will eliminate any threats to the biological integrity of this area’s natural ecosystem.

Adopted by the Board of Trustees on August 21, 2001.