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Former PA Forester On DCNR & Environmental Review

by Robert “Butch” Davey

Former district forester, Sproul State Forest

On DCNR and Public Comment

To the best of my knowledge the Department of Conservation and Natural Resources (DCNR) has yet to conduct a public meeting where statements are recorded under oath. However DCNR has conducted many public informational meetings.

The Bureau of Forestry (B of F) conducts public informational meetings when Forest Resource Plans are revised every 15 years. These type of meetings are done when policies and procedures within the Bureau of Forestry mandate are updated. Usually the attendees can ask questions and make statements. The main purpose of such meetings is informative rather than to seek input from citizens.

On the Environmental Review Process

The Environmental Review which DCNR B of F uses is not an environmental impact statement which examines various alternatives including no change. The environmental review is an internal document consisting of 20 or so items which are addressed as to the environmental effect, good or bad, of the proposed project. The environmental review can be prepared by Forest District personnel or a company requesting a project or activity occurring on State Forest land. The document is submitted to the central office of the B of F for review. Each of the division chiefs prepares comments or signs off on the review without comment. This is not a document of choices and alternatives but rather a document concerning a proposed project. Unless the procedure has changed the public is not involved. The environmental review should be available to the public.

On Protecting Threatened and Endangered Species

The Pennsylvania Natural Diversity Inventory (PNDI) is a historical compilation of data and locations of species of flora and fauna of special concern. When a project is being planned the PNDI records are searched in the Harrisburg Central office for the area where the project is proposed to determine if a species of concern will be affected. This is determined to be a “hit”. The information on the species being harmed is kept confidential. This is done to keep collectors from disturbing the species of concern.

For instance, in North Central Pennsylvania the Allegheny Wood Rat (Neotomia magister) is a species of concern. The habitat and population of this rodent has diminished. The Allegheny wood rat is listed as a threatened species and has been proposed as a candidate for the federal endangered species list. There are several web sites with more and better information on PNDI.

On Soil Erosion and Sedimentation Prevention

In Pennsylvania all earth-moving activities require a written accelerated soil erosion and sedimentation prevention plan (E&S). For most earth-moving activities the county Conservation District staff reviews the plans for completeness and adequacy to prevent accelerated soil erosion and sedimentation. A letter to this affect is sent to the earth mover by the Conservation District. The major exception to this procedure is the oil and gas industry. The Department of Environmental Protection ((DEP) Bureau of Oil and Gas has been tasked with the review for all gas drilling permits. This policy change was the result of oil and gas operators being slowed down in their zeal to have permit applications processed pronto. The average time DEP spends on reviewing an E&S for a gas well site is reported to be 25 minutes.

If 20 acres or more of earth disturbance is planned a full-scale earth disturbance permit is required. This is a much more detailed plan and requires more information and review.

From the information it appears that the watersheds in the Rock Run section of the Loyalsock State Forest are high quality and exceptional value. These are streams with the highest quality water and the least human and industrial activity and pollution.  It is crucial to protect these valuable water courses.    

Robert “Butch” Davey is a former district forester of Sproul State Forest and worked for the Bureau of Forestry for over 40 years. Davey is also on the board of directors of Keystone Trails Association.


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