1105 Pheasant Run
Columbia, Missouri 65201

August 26, 2001

David P. Boergers, Secretary,
Federal Energy Regulatory Commission,
888 First Street NE, Washington, DC 20426

Dear Mr. Boergers,

On behalf of the Columbia Audubon Society I wish to express opposition to the issuance of a preliminary permit for initial exploration for a pumped storage hydroelectric plant on Church Mountain and Taum Sauk Creek in Reynolds County, Missouri.

The Columbia Audubon Society is a chapter 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 500 members of the Columbia Audubon Society in central 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 displace wildlife, mar the scenic beauty and diminish the value of 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. The Columbia Audubon Society is especially concerned about the ecological impact of major habitat fragmentation. This is 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 does not produce a net gain in energy but requires about 3 kilowatts to pump the water uphill for every 2 kilowatts of hydroelectricity produced.

In conclusion, the Columbia Audubon Society opposes the issuance of a preliminary permit for Project Number P-12049-000. I believe 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.

Sincerely yours,

H. Denny Donnell, Jr., MD, MPH, President
Columbia Audubon Society

Enclosure

c:
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