Ghosts in the Soil

The railroad tracks from Chicago stop at the edge of a small town but the straight, level railbed goes miles further. There are no construction teams there. It’s not a new railroad being built; it’s all that remains of an old one. And it leads to something very strange. Down the line there’s a prairie preserve growing over an abandoned ammunitions plant, contaminated soil, and the bones of farm families from before World War II.

 

The Joliet Army Ammunitions Plant, circa 1953

Following the railbed, you pass a cluster of grain silos and make your way between farmhouses and cornfields. Then you reach a massive unkempt property bounded by a rusty barbed wire fence that stretches farther than you can see. Here the trail ducks under the fence and branches out, connecting to networks of other stripped railbeds that serve dozens of abandoned buildings. There are rows of grass-covered concrete bunkers with heavy steel doors. Some have been left open and you can see they’re completely empty. Not far away, there are vacant industrial buildings being reclaimed by nature. Tiles and asbestos hang from their ceilings. They smell like the animal waste that’s scattered on their floors. Most of their windows are broken and the wind has scattered papers left on desks or in open file cabinets. Dark algae-filmed water fills their basements to the tops of their stairways. Ivy creeps up their outside walls and tall grass grows in the buffer zones between them. Away from the buildings in the overgrowth, there’s a crumbled foundation that looks like it could have been a barn or a farmhouse. Under a stand of tall trees near the middle of the site, there’s a cemetery where all the headstones are dated before 1940. This place may have once been someone’s home, or a factory, or a depot. Whatever it was, it was abandoned quickly and long ago.

 

A stripped rail bed running along a row of JAAP’s “igloo” storage bunkers

But now you hear in the distance the rumble of diesel engines. South of you, backhoes are piling trash onto a small mountain of a landfill. To the northwest, in a rail yard where the tracks haven’t been stripped, trains are loading cargo from warehouses owned by Walmart and other companies. Surrounding the empty plot you’ve wandered into are two industrial parks, an oil refinery, and acres of farmland. Developed properties wedge against the rusty fence like they’re trying to get in. This is a valuable piece of real estate, but for some reason, it’s not for sale. What’s so special about these weedy fields and crumbling buildings?

 

During World War II, The Army kicked out a community of Illinois farmers and, while crops still stood in the fields, built the Joliet Army Ammunitions Plant.i The land would never be the same. This is the story of the bodies buried in the cemetery, the toxic chemicals buried in the landfill, and the values attached to both. This is, most of all, a story about those values, how they’ve changed, and how they’ve clashed on this piece of land since World War II.

 

A FAMILY HOME                        Before the War, the Leupold brothers lived on a few acres of farmland near Joliet, Illinois. In late 1940, they were told by the U.S. Ordnance Department to sell their home or else fight the federal government in court.ii The Leupolds were among hundreds of farmers asked to leave the area. The reason, they were told, was so that a massive munitions plant could be built on their land. One way or another, the Leupolds and their neighbors were gone within a few months. But in 1949, almost a decade later, the Leupolds would write to the War Department asking for their land back.iii They got on with their lives elsewhere for nine years, but they were still attached to the land they left behind. Farms like the Leupolds’ had sentimental value above the Ordnance Department’s asking price. That’s why, when they were told to leave, many Joliet area farmers put up a fight.

 

The American public of 1940 didn’t see the war as a struggle between good and evil. Hitler was murdering innocents in Europe but that wasn’t widely known in the U.S. The war, as many Americans saw it, had little to do with them. That’s why, until the Pearl Harbor attack, public opinion favored noninvolvement. Like many other Americans, Joliet farmers were rooting for the Allies, but they weren’t ready to sacrifice their homes for the cause. So they had a short-lived protest. They had at least one community meeting during which they pled their case to a sympathetic but unhelpful Army Colonel. The colonel promised construction would start in the next thirty days.iv Community members couldn’t stop the plant’s coming or their going, but their protest still left a mark on the landscape.

 

The farmers wanted their cemeteries left alone. Although the Ordnance Department may have planned to dig up and relocate the graves, they granted the Joliet community that one concession, and left three cemeteries sitting between sections of the plant.v The cemeteries are today the most tangible evidence of the multi-generational farm families from before the war. Their headstones recall both the people buried there and their children who moved away when the plant moved in.

 

THE ARSENAL OF DEMOCRACY                  For the federal Government, the land transfer was, predictably, a public relations disaster. But it was a difficult one to avoid. The U.S. needed military explosives as soon as World War II started – if not for itself, then for those defending its interests. The U.S. Ordnance Department built 77 munitions plants between 1940 and 1943. As in Joliet, many of the plants had to be built on land bought from unwilling midwestern farmers.

 

According to government specifications, to be safe from enemy invasion, each plant had to be between the Appalachian and Rocky Mountains and at least 200 miles from national borders. Each plant needed close-by waterways for production and waste disposal. And, to move the raw materials and finished products efficiently, each plant needed access to major railroad and highway arteries. Finally, because of the risks of manufacturing explosives, each plant site needed room for blast buffers. Plant buildings had to stand far enough apart so that an accidental explosion couldn’t cause explosions in adjacent buildings (This is why JAAP had to take up so much space and displace hundreds instead of dozens of farmers). The requirements meant that ordnance plants were most easily sited on rivers in the greater metropolitan areas of the mid- and near west, and that meant wherever the Ordnance Department went, chances were it had to kick someone out.

 

The site near Joliet was no exception. It was in the middle of the country, with thousands of acres to build on. It had easy access to Chicago’s transportation infrastructure and to the Illinois River watershed. In addition, it had access to the human resources it needed – an ample workforce and public support. The displaced farmers were dissatisfied by the plant’s establishment, but plenty of people in the region wanted the plant nearby for the cash it would bring. Construction workers came looking for jobs even before the project had begun.vi Ads sponsored by the State of Illinois flaunted Chicago’s infrastructure, asking industries to take advantage of the region’s railroads.vii The state government, job seekers, and Ordnance Department planners agreed that the chosen plot south of Joliet was an excellent place for a munitions plant. And yet as perfect for them as the site then was, it would soon become mostly useless.

 

After World War II, the U.S. would never again need such a massive bomb-making operation. There was still the Cold War, so JAAP was put on standby instead of shut down. It supplied U.S. forces in the Korean and Vietnam Wars. Then, in 1977, it closed for good. War as the U.S. knew it went away and was replaced by something else. Most American military campaigns after Vietnam were what international relations theorist Mary Kaldor calls “new wars” – low-intensity conflicts involving non-state belligerents like Al-Qaeda.viii The Air Force couldn’t carpet bomb a guerilla cell like it could Dresden, so it wouldn’t need so many bombs. Also, the military and its contractors developed new munitions technologies that made some of JAAP’s facilities obsolete.ix JAAP ran its course and became mostly useless to the military. But the land it left behind, and the condition it was left in would shape a new struggle in the coming decades.

 

AN OPEN MARKET                  A lot had changed by the time JAAP shut down so that new kinds of buyers had became interested in the plot. As the car’s popularity increased, so too did the number of car commuters who could afford to live dozens of miles from their workplaces downtown. Around the nation’s cities sprang up suburbs designed for those commuters and their cars – suburbs distinguishable by their curving non-grid street plans, the garages built into to every one of their houses, and, sometimes, their lack of sidewalks.x Since World War II, automobile suburbs had advanced from the edges of Chicago’s metropolis. In satellite images, you can see their curved plans densely covering land between twenty and thirty-five miles from the Chicago Loop. As the suburbs sprawled, they moved the edge of the metropolitan area closer to JAAP, making land increasingly scarce.

 

An example of post-World War II suburban sprawl near Oak Brook, Ill. The neat curving street plans are characteristic of mid-century suburban communities.

But it wasn’t just that land became scarce. A market developed that brought new interests to the JAAP site. As industries grew in the post-war decades, more companies became nationwide businesses and had to deal with economies of scale. A new corporation called Wal-Mart, for instance, had begun its rapid expansion and needed to coordinate its store network to increase profits. To successfully cut their costs, Wal-Mart needed enough transportation resources – warehouses, depots, trucks, barges, and trains – to make sure that opening a new store or factory didn’t mean cutting off the inventories of old ones. xi As companies like Wal-Mart grew, so too did demand for commercial shipping solutions. In this context, property developers recognized the dollar value of JAAP. The plot already had an industrial rail depot and access to railroads, highways, and rivers. It looked like an excellent investment. Developers eventually built an industrial park on the south side of the site and expand JAAP’s rail depot, making it into an intermodal shipping facility, where Walmart  (spelled without a dash since 2008) would buy space. But those projects only took up a fraction of the JAAP site and they didn’t start until years after JAAP’s shutdown. As in-demand as the real estate was, pieces of it weren’t sold for a long time, and most of it wasn’t sold at all, but repurposed. Something was still keeping the federal government from getting rid of it.

 

A HEALTH RISK                        In the ’90s, the Army hired contractors to perform a series of “ecological risk assessments” of JAAP’s soil. One risk assessment investigated a burning ground, where plant workers had regularly incinerated waste explosives. The risk assessors tested the soil by taking samples and putting cucumbers, earthworms, and bacteria in them. They expected soils with high concentrations of explosive residues to be significantly harmful to living matter, i.e., kill at least half of it. But, unexpectedly, even some soils not contaminated with explosives killed half of the cucumbers, earthworms, and bacteria.xii The assessors blamed other pollutants, like heavy metals, and encouraged the Army risk manager to conduct further studies to learn exactly what was wrong with the soil.xiii Years of different kinds of pollution left sections of JAAP so contaminated in so many ways that the Army didn’t even know what it had to clean up.

 

A diagram showing the creation of 2,4,6 useful TNT (top right) and the other isomers, useless in military grade explosives.

Pollution was inherent to the 1940s manufacturing process used in JAAP. Workers started with a batch of toluene and, three times, added nitrate molecules, which bonded to the toluene hub, yielding trinitrotoluene, or TNT. Effective military-grade TNT had to be nearly pure 2,4,6 TNT (The 2,4,6 represents the positions where the nitrate molecules should be bonded to the toluene hub.)xiv A problem with the TNT-making process in 1940 was that it yielded an impure mixture of usable 2,4,6 TNT and useless other kinds of TNT molecules. The useless molecules had to be extracted from the batch in a process called “washing.”xv Washing eliminated most of the useless – along with up to 5 percent of the useful – TNT so that the factory had two products: the almost-pure batch of useful powder, and a mixture of wastes called “red water.”xvi JAAP flushed its red water into nearby Prairie Creek, which fed the Kankakee, and in turn, the Illinois and Mississippi Rivers.xvii The red water went in the streams while the contaminants from the burning ground and other sites sank into the groundwater, where they might migrate to nearby communities’ well water.xviii

 

Before we put JAAP on trial, we should ask, why is this bad? The answer is we’re not entirely sure. TNT in the bloodstream can break down the walls of red blood cells, keeping them from delivering oxygen to the other cells in the body – what we call anemia.xix Otherwise, TNT can cause liver failure.xx It can kill a person if it’s absorbed in a high enough concentration. But we don’t fully understand what that concentration is or how it gets into the body. Even writers of recent medical studies complain of a lack of quantitative data on the medical effects of ingesting TNT.xxi Government officials in the ’40s knew even less. They didn’t understand the toxicokinetics well enough to save 22 workers dying from TNT exposure during World War II.xxii In obvious ways, the lack of information was terrible for the Army. In an indirect way, though, it was convenient. Knowing little about the potential effects of TNT in the environment, it was easy for the Army not to worry about the TNT it put into the streams and the soil.

 

Books like Rachel Carson’s best-seller Silent Spring (1962) made pollution much more of a controversy. Carson warned that the then-widely-used pesticide DDT would injure the environment and human health. At the time, those defending DDT (who were also those selling DDT) still had scientific credibility – that is, the jury was still out on Carson’s linking of DDT to environmental problems. But her book nonetheless convinced Americans to expect the worst of pollution so that, even if they didn’t fully understand its consequences (as they didn’t of TNT), they could still demand a cleanup.xxiii Instead of forgetting what chemicals were put into the environment, as anyone easily could, Americans became increasingly concerned about them. That’s why the use of pesticides declined. It’s partly why Congress and President Nixon created the Environmental Protection Agency, and partly why Congress passed the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (commonly known as Superfund), under which the Army was made liable for cleaning JAAP.xxiv Partly because of Carson the American public came to see pollution much more negatively than it had. EPA officials didn’t need to fully understand the risks of contamination to mandate a cleanup effort that would last until the late ’90s. No part of JAAP was to be sold or repurposed until it had been decontaminated to the EPA’s standards. But decontaminated to the EPA’s standards didn’t mean decontaminated. The Army would get out of their cleanup responsibility early. And, strangely enough, it would have something to do with the nature lovers.

 

A BUTTERFLY                        While the Army and its contractors were decontaminating parts of the site and developers were bargaining for pieces of it, a group of conservationists came to JAAP. Walking through the site, they probably saw fields dotted with burr oak and patches of waist-high grass and prairie flowers. They got the idea that this piece of land could go back to what it was before World War II and even before western settlement. With a human hand, the patchy ecosystem that had developed in JAAP could become a real prairie and a national park.

 

Shrubs and trees crowd parts of JAAP’s soil, keeping prairie grasses from spreading.

JAAP’s soil was heavily polluted in small areas around some plant buildings. But the buffer zones – those wide-open spaces included in the 1940 plan to prevent fire from spreading building to building – were open and uncontaminated. Having decades ago forced out the farmers and their crops, JAAP had unintentionally started the work of rebuilding a prairie. In the buffer zones, tall grasses had fewer competitors and plenty of room to grow. Native bird species, too, thrived in JAAP in a way they couldn’t in the surrounding landscape.xxv As writer Tony Hiss put it, JAAP was an “industrial brownfield… with a huge green difference.”xxvi It had unique potential to become a national park.

 

If it did, it would be unique among national parks – one of the only laid on land with such a heavily developed past. That’s partly why conservationists put a high romantic value on the would-be park. If they made it into a prairie, they argued, they’d be opening a resource for the common good. It could be a classroom and a recreational space for 100 million people within a day’s drive.xxvii Even better, the park would be a moral resource – a symbol of peace. By turning “bombs into blossoms,” the community would be making good from the evil of war.xxviii “Midewin,” the name they gave it, reflects that romanticism. It’s a word from the language of the long-gone Potawatomi that means “healing society.”xxix The prairie wouldn’t just serve the urban area; it would nourish it.xxx For Midewin’s supporters, the struggle for the JAAP property was one for ideal land use and ideal society.

 

They would eventually win, establishing Midewin National Park, which now occupies most of the acreage of the former JAAP site. The prairie is a work in progress. Since mature prairie soil can take a century to develop, parts of the park are still weedy, overgrown, or vacant-looking.xxxi Conservationists worked hard, but to make Midewin a reality, they needed the Army to hand JAAP over to them.

 

A CHORE                        The Army’s contractors used at least two methods of “remediating” JAAP’s contaminated soil. Partly because the Army didn’t know what kind of pollutants were in particular areas, they just disposed of most contaminated soil. They dug it up, piled it at the on-site landfill, and replaced it with soil from somewhere else.xxxii They moved hundreds of thousands of cubic yards of soil before the site was acceptable to the EPA.xxxiii The Army Environmental Command (USAEC) estimated the project could cost up to $200 million.xxxiv But the USDA and EPA allow a low decontamination standard for non-residential, non-industrial land use.xxxv Because Midewin National Park wouldn’t have permanent residents or many plumbing systems drawing from the polluted groundwater, the Army was able to tailor its cleanup operations and limit the project’s cost to around $20 million – a tenth of the high estimate.xxxvi As a U.S. Army publication would frame it in a section called “Defending Your Dollars,” the Army had resourcefully saved an unnecessary expense. xxxvii But it left to Midewin sections of contaminated soil and groundwater.xxxviii

 

It’s unclear who made the decision to leave the plot how it was. But the Army saved millions, and it seems Midewin benefitted, too. Had the Army spent the estimated $200 million to clean JAAP’s groundwater to the highest standard, then it would have been legal for the Army to divide and sell the JAAP plot to any number of eager private sector buyers. It’s unlikely that the preservationists would have been able to compete. The Midewin dream would have died. It would be interesting to find out whether the Army and the preservationists made a deal. In any case, Midewin is a compromise.

 

A SYMBOL                       The place is simultaneously a natural beauty, a desirable piece of real estate, and a health risk. Decades ago it was FDR’s “arsenal of democracy,” and before that, a group of family homes. The answer to the question “what is this place?” depends on who and when you’re asking. Since 1940, people have been struggling over how this land should be used. None of them ever got exactly what they wanted. Instead, their competing values made this place into one that could not exist anywhere or any when else.

 

A satellite image of the JAAP site (outlined) as it is today. Manhattan, Ill. is in the top right.

For all this struggle to start, the government had to coerce headstrong farmers like the Leupolds to give up their sentimental property. For the land to have become available after the war, it had to become useless to the Army. Global conflicts had to transform so that nations would no longer need a massive volume of explosives to fight in them. Once the land was available, businesses and developers moved in to the extent they could, but laws about contaminated soil mostly shut them out. For those laws to have existed in the first place, people had to become worried about the sometimes-vague connection between pollution and disease. For industries to have wanted the land in the first place, it had to have become an attractive commodity. That couldn’t have happened without the midcentury evolution of the car, the suburb, and the national corporation. For Midewin to be established, there had to be strong community support. For that to happen, people in the community had to have romantic ideals about nature preserves and the beauty of the American landscape. Most necessarily, there had to have been a World War II in the first place. Forces at work on the other side of the world that threatened the United States’ hegemony in its own hemisphere created the need for JAAP and, in turn, the opportunities for future land users. The landfill, the industrial buildings, the overgrown cemeteries, and the prairie blossoms, are all symbols of modern American history.

 

Maybe the most fitting symbol, though, is the first one you saw – the stripped railbed that led you here. Today the railbed and its branches are maintained as dirt trails. They no longer carry bombs but hiking nature enthusiasts who think of the place as a natural marvel rather than a piece of capital. Like the munitions plant, the railbeds are, essentially, the same thing they used to be. Yet the subtraction of two rails and the coming of a new era and new values have made them into something that is, in its relationship to people and the environment, entirely different. It’s an industrial ruin, a scenic view, and a history exhibit.

 

NOTES


i “U.S. Taking Arms Plant Site Now, Objectors Told,” Chicago Tribune, September 25, 1940, Proquest Historical Newspapers: Chicago Tribune (1849-1988). Accessed April 15th, 2012, http://www.proquest.com/.

ii  Ibid.

iii  Letter to Paul L. Mather from Leupold Brothers, December 26, 1949; Box 420, Elwood Ordnance Plant, Elwood, IL. Real Property Liquidation Files; Chicago Region, record group 270, National Archives Bldg, Chicago, IL.

iv “U.S. Taking Arms Plant Site Now, Objectors Told.”

v  Kane is uncertain whether it was Ordnance Department policy to move graves, but she says it did happen. Goc says that the Ordnance Dept. had planned to move graves at BAAP, but decided not to after a sharp public outcry. See Kimberly L. Kane, Historic Context for the World War II Ordnance Department’s Government-Owned Contractor-Operated (GOCO) Industrial Facilities, 1939-1945, (Plano, TX: Geo-Marine Inc., 1995) 191. See also: Goc, 111.

vi  “Defense Comes to Main Street,” BusinessWeek, November 2, 1940.

vii  Ad in BusinessWeek, November 2, 1940.

viii  Mary Kaldor, New and Old Wars, (Stanford, CA: Stanford University Press 2001) 1.

ix  The authors point out two big drawbacks to TNT production in plants like JAAP: inefficiency and pollution. The development they’re selling in this fact sheet solves both. See Mr. Anthony W. Arber, Javid Hamid, Dr. Robert M. Endsor, “Elimination of Redwater Formation from TNT Manufacture,” Strategic Environmental Research and Development Program WP-1408 fact sheet, December, 2007, accessed April 15, 2012, pdf can be downloaded here: http://www.serdp.org/Program-Areas/Weapons-Systems-and-Platforms/Energetic-Materials-and-Munitions/Explosives/WP-1408/WP-1408.

x  William Cronon, History, Environmental Studies, Geography 460, “American Environmental History,” lecture 19: “Environmentalism Triumphant?” Spring 2012.

xi  Economies of scale happen when a firm opens another factory or store. If resources aren’t coordinated, that expansion can diminish profits. Arthur O’Sullivan, Stephen M. Sheffrin and Stephen J. Perez, Microeconomics – 7th ed., (Boston: Prentice Hall, 2012) 192.

xii  “Evaluation of Soil Toxicity at Joliet Army Ammunition Plant,” Environmental Toxicology (April 1995): 629.

xiii  Ibid 630.

xiv  This study also gives a good overview of the TNT-manufacturing process. Arbor, Hamid and Endsor, 3.

xv  Ibid.

xvi  Ibid, 5.

xvii  Aerostar Environmental Services, Inc., “Second Five-Year Review Report Soils Operable Unit for Joliet Army Ammunition Plant (JOAAP) Wilmington, Illinois,” August 2009, accessed April 15, 2012, 33.

xviii  For more about the EPA’s concerns about pollution in JAAP, see Bruce K. Means, Memorandum to William E. Muno, “EPA Region 5 National Remedy Review Board Recommendations on the Joliet Superfund Site,” Accessed 4/23/13 http://www.epa.gov/superfund/programs/nrrb/pdfs/joliet.pdf

xix  “Toxicological Profile for 2,4,6-Trinitrotoluene,” Agency for Toxic Substances and Disease Registry, June 1995, accessed April 15, 2012, 29.

xx  “Toxic Jaundice” is one of the notable causes the author points to for factory deaths during World War II. Ibid, 17.

xxi  Ibid, 77.

xxii  McConnell WJ, Flinn RH, “Summary of twenty-two trinitrotoluene fatalities in World War II.” Journal of Industrial Hygiene and Toxicology 28:76-86 1946. As quoted in “Toxicological Profile,” 38. http://www.atsdr.cdc.gov/ToxProfiles/TP.asp?id=677&tid=125.

xxiii  At the end of the broadcast, Eric Sevareid implores viewers to find out more about just what risks come with DDT and other pesticides. Also, the program gives significant airtime to a scientist who insists Carson was stretching the truth. See “The Silent Spring of Rachel Carson,” CBS Reports, April 3, 1963.

xxiv  “Origins of the EPA,” The Guardian – EPA Historical Publication, Spring 1992. Accessed at epa.gov on April 15, http://www.epa.gov/aboutepa/history/publications/print/origins.html.

xxv Tony Hiss, “Bombs into Blossoms,” Preservation, July/August 1998, 78.

xxvi  Hiss, 76.

xxvii  Hiss, 78.

xxviii  The title of Hiss’s article in Preservation, Ibid.

xxix  Hiss, 78.

xxx  Hiss, 78.

xxxi  Hiss, 80.

xxxii  Using Google Earth’s historical imagery feature, you can see sites described in Aerostar’s five-year review being excavated as the Prairie View landfill gets bigger. Ibid. See also Google Earth, http://earth.google.com/.

xxxiii  Aerostar Environmental Services, 58, 74.

xxxiv  This is part of an interesting dialog between the Army, the EPA, and the USDA. I’d like to have found more documents like it. There’s juicy research yet to be done here. “Joliet Reduces Prairie Cleanup Costs,” Environmental Update, vol. 17, no. 4 (Fall 2005), accessed April 15, 2012, http://aec.army.mil/usaec/newsroom/update/fall05/fall05.html.

xxxv  The USDA refers to the cleanup plan implemented as below the “residential standard.” See Logan Lee, “Decision Notice & Finding of No Significant Impact Land and Resource Management Plan (Prairie Plan) Amendment #1 – Establishment of Management Area 3 and Designation of Utility Corridors into MA 2,” June 26, 2008, 1-2. Accessed April 15, 2012, http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5158006.pdf.

xxxvi  “Joliet Reduces Prairie Cleanup Costs,” Environmental Update, vol. 17, no. 4 (Fall 2005), accessed April 15, 2012, http://aec.army.mil/usaec/newsroom/update/fall05/fall05.html.

xxxvii “Joliet Reduces Prairie Cleanup Costs.” Midewin planners call the still-contaminated areas “soil restriction areas and groundwater management zones,” see also, Logan Lee, “Decision Notice & Finding of No Significant Impact Land and Resource Management Plan (Prairie Plan) Amendment #1 – Establishment of Management Area 3 and Designation of Utility Corridors into MA 2,” June 26, 2008, 1-2. Accessed April 15, 2012, http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5158006.pdf.

xxxviii  Midewin planners call the still-contaminated areas “soil restriction areas and groundwater management zones,” see Logan Lee, “Decision Notice & Finding of No Significant Impact Land and Resource Management Plan (Prairie Plan) Amendment #1 – Establishment of Management Area 3 and Designation of Utility Corridors into MA 2,” June 26, 2008, 1-2. Accessed April 15, 2012, http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5158006.pdf.