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Fall colors in the Loyalsock
 by Ralph Kisberg and Morgan Myers
 
Although Responsible Drilling Alliance has been aware of Anadarko Petroleum Corporation's plans to develop gas rights in and around the Old Loggers Path, Rock Run, Pleasant Stream and other Lycoming and Loyalsock Creek headwater streams for some time now, the plans have yet to be revealed to the public. Apparently such information can be considered “proprietary” despite the fact that the development will take place on public land.
 
When will this information become public? The people of Pennsylvania deserve the right to offer input on the management of public land before  another insider deal is done. Why don't stakeholders other than the developer and an administration with huge campaign contributions from the gas industry have a seat at the table with the DCNR? A true gem of our public lands is on the chopping block, and no direct benefit to the public - in fact, only detriment - will accrue from shale gas development in this special place.
 
On September 7th, Responsible Drilling Alliance, the PA Forest Coalition, Citizens for Pennsylvania’s Future, the Keystone Trails Association and the Sierra Club sent a letter to DCNR Secretary Richard Allan asking for environmental impact studies, public meetings on development alternatives, and public comment periods on any proposed agreements between DCNR and Anadarko. We have yet to receive a response.
 
RDA President Ralph Kisberg and PA State Senate candidate Luana Cleveland spoke to a high level DCNR staff person in Harrisburg on Tuesday who denied any talks between DCNR and Anadarko about developing the Clarence Moore tracts.  On Monday, State Rep. Garth Everett told RDA that Anadarko and DCNR are "discussing development of the Clarence Moore tracts". On Wednesday, RDA found stakes for a "preliminary" pad site on a portion of Clarence Moore where maps tell us DCNR controls surface development. We also saw flagging for road widening and the placement of gas and water pipelines.
 
If Rep. Everett was mislead and there are no disucssions between DCNR and Anadarko, how would the latter be able out a portion of forest that the former has jurisdiction over? Something doesn’t add up.
 
The stakes and flagging RDA discovered Wednesday are in addition to those found on Crandall Town Trail last week. This new "preliminary" site is along John Merrell Road, about  0.4 miles west from Cascade Road on Burnett’s Ridge.
 
Well pads around here have typically been constructed following a loose southwest to northeast trend line, with each pad along that line ideally about 1/2 mile apart. By extrapolating this pattern you get a rough idea of Anadarko’s planned layout for the Clarence Moore 25,000 acres of mineral rights. In the case of other developments on large tracts of land, a trend line will emerge approximately every 2 miles to the north and south. The discovery of the sites planned for Burnett’s Ridge and Sullivan Mountain confirms this basic well pad layout pattern, although topographical and water features have modified it somewhat.
 
The length of some operators' laterals has approached 10,000 feet. By exercising its surface control of ¾ of the Clarence Moore tract, DCNR could force the company to push their trend lines farther apart. This would mitigate surface disturbance to the state forest by about half. If development were delayed for a longer period, hydraulic fracturing technology might evolve to the point where the surface need not be disturbed at all. If the administration were willing to include the public in its negotiations with Anadarko, perhaps this region's beauty, tranquility and decades of forest equity would not be thrown away so easily.

DCNR’s furtive behavior concerning its negotiations with Anadarko does not serve its mission or the interests of the people. Why are surface use plans on public land allowed to be considered proprietary? Why does DCNR deny negotiations with Anadarko when all evidence points to the contrary? Most of all, why is public land being developed without public input?

Photos From Clarence Moore

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Did you know that there's a blog entirely devoted to protecting the Loyalsock State Forest from industrialization? The Keep It Wild campaign focuses on preserving a parcel of land encompassing Rock Run, Old Loggers Path, and other wild wonders of the Loyalsock. To stay updated on the Keep It Wild campaign, visit our blog at www.keepitwildblog.blogspot.com, and check back often.

 

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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