Precedent for DNR's pre-permit application EIS review of lakeside golf links?

[Updated from 7/5] People following the ideologically-forced decline of environmental protection in Wisconsin by Gov. Scott Walker and the private sector managers he installed atop the state Department of Natural Resources to speed along privatization  - - noted here, in depth - - are following the possible conversion by a major Walker donor of a 247-acre nature preserve south of Sheboygan into an 18-hole, high-end golf course.

Also worth noting - - the DNR has spent months, and presumably substantial resources, researching, drafting and publishing just days ago a draft Environmental Impact Statement - - link here - - assessing the environmental impacts that property conversion would have on the wetland/woodland/Native American artifact-rich site along Lake Michigan before the agency received a permit application from the property owner.

In other words - - the DNR is reviewing a project for which no permit to build has been applied. And is asking for public comment on the draft EIS for a project not yet formally submitted for permitting.

Cart before the horse?

And how does one qualify for such a publicly-paid benefit?

Here from the DNR is information about the EIS comment period - - for a project which has not formally sent the DNR a permit application - - and also information about a hearing schedule, too:

Public input opportunity: The public is invited to review and provide comments on the DNR's draft EIS [PDF] through August 1, 2016.

The DNR will also hold a public hearing on Wednesday, July 20, 2016, from 6 p.m. to 9 p.m. at the Sheboygan Falls High School Auditorium, 220 Amherst Ave., Sheboygan Falls, WI.

Comments may be sent by email or by US Mail to: Jay Schiefelbein, Wisconsin Department of Natural Resources, 2984 Shawano Avenue, Green Bay, WI 54313-6727.

All comments received during the comment period will be considered in the preparation of the DNR's final EIS. Written comments carry the same weight and will receive the same level of consideration as oral comments provided at the hearing.

I hope you noticed that a DNR official has said other projects have received such treatment: 

Mike Thompson, environmental analysis team supervisor, cautioned that the document is a draft and could be changed, based on comments from the public, and as other information becomes available. 

Thompson said there have been instances when the DNR has moved ahead with the environmental impact report before receiving a formal application. He said the company did not ask for the analysis to be done before it filed an application.

I can't remember such a sequence - - an EIS draft released before, not following, an application for a project's permit - - and several experts to whom I posed the question have said they do not recall this sequence, either.

So on July 5th I sent the DNR an Open Records request for links to, or citations for, such projects and their no-permit-application-first draft EIS.

The DNR responded on July 6th that my request was received and has been forwarded to the right people.

it will be interesting to see what, if anything, surfaces, and if there are prior examples which also rise to the level of controversy associated with the Kohler golf course.

I'll share the results of the request with blog readers when I receive a response.