Drill LoyalsockSF 20130404 Letter DCNR MS
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Transcript of Drill LoyalsockSF 20130404 Letter DCNR MS
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7/28/2019 Drill LoyalsockSF 20130404 Letter DCNR MS
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April 4, 2013
by hand-delivery & first-class mail
Richard J. Allan, Secretary
Department of Conservation and Natural ResourcesRachel Carson State Office BuildingP.O. Box 8767
400 Market Street
Harrisburg, PA 17105-8767
Re: Gas Development in the Loyalsock State Forest
Dear Secretary Allan:
The undersigned organizations, businesses, and elected officials write on behalf of
over 100,000 Pennsylvania citizens keenly interested in the conservation andenhancement of the Commonwealths State Forest lands for future generations. We
respectfully request that the Department to Conservation of Natural Resources (DCNR)
conduct a statewide public comment period on the far-reaching decisions that the DCNR
is poised to make concerning natural gas development in the Loyalsock State Forest.
The Loyalsock State Forest covers approximately 114,000 acres in Lycoming and
Sullivan Counties the heart of the Pennsylvania Wilds. In Lycoming County, there aresome 18,870 Forest acres where, due to an unusual provision in the Commonwealths
deed, DCNR owns the surface rights even though the oil and gas rights are owned by
Anadarko Exploration and Production Company, L.P. (Anadarko) and the International
Development Corporation. Known as the Clarence Moore Lands, these lands includesome of the most important ecological and recreational resources in Pennsylvanias State
Forest system, including Rock Run, an Exceptional Value stream widely hailed as the
most beautiful in Pennsylvania; the Old Loggers Path, a 27-mile hiking trail; the DevilsElbow Natural Area; and an National Audubon Society-designated Important Bird Area.
They are cherished by our members throughout the Commonwealth.
In 2011, hikers began to encounter seismic testing crews in the Loyalsock State
Forest. Documents recently obtained from the DCNR under Pennsylvanias Right to
Know Law show that the DCNR and Anadarko are currently negotiating a surface use
management agreement that would allow Anadarko to develop a network of gas wells,compressor stations, pipelines, roads, and impoundments on the Clarence Moore lands.
We find this news alarming for three reasons.
First, if the DCNR allows Anadarko to develop these lands, their wild characterand ecological and recreational integrity will be permanently lost. Second, any surface
management agreement executed by the DCNR would violate the spirit, if not the letter,
of the 2010 Executive Order imposing a moratorium on the leasing of any further DCNR-managed lands for oil and gas development. As you know, the basis of this order was a
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2010 study by DCNR itself titled Impacts of Leasing Additional State Forest for Natural
Gas Development; it concluded that there are zero State Forest Land acres suitable for
[additional] gas leasing involving surface disturbance. Third, to the extent that the
Commonwealth has received funding for the Clarence Moore lands under the FederalLand and Waters Conservation Act, Pennsylvania could suffer significant financial
penalties if these lands are converted to gas development.
Given these facts, it is clear that gas development in the Loyalsock State Forest is
a matter of statewide public importance. Yet to date, the DCNR has failed to seek any
public input on whether development should occur, and if so, on what conditions.
Under Article I, Section 27 of the Pennsylvania Constitution, the DCNR has a
legal duty to conserve, maintain, and enhance State Forest lands for the benefit of all
Pennsylvanians, including future generations. And under the Conservation and NaturalResources Act, the DCNR may not grant a right-of-way over State Forest lands unless the
DCNR determines that granting a right-of-way would be in the public interest. We
believe that in the case of the Clarence Moore lands, it is impossible for the DCNR tomake this determination without public input. Thus, we respectfully request that the
DCNR suspend its negotiations with Anadarko and open a public comment period on
whether gas development should be allowed in the Clarence Moore lands, including at
least one public hearing.
We look forward to hearing from you and would welcome the opportunity to
discuss this issue, answer any questions or provide any additional information.
Sincerely,
Mark Szybist
Citizens for Pennsylvanias Future(PennFuture)
Robbie Cross
Responsible Drilling Alliance
Curt Ashenfelter
Keystone Trails Association
Andrea Young
Muncy Creek Watershed Association
Josh McNeilConservation Voters of Pennsylvania
Melinda Hughes-Wert
Nature Abounds
Carol Kafer
Loyalsock Creek Watershed Association
Jeff Schmidt
Sierra Club Pennsylvania Chapter
Robert E. Hughes
Eastern PA Coalition for Abandoned Mine
Reclamation
Ryan Talbott
Allegheny Defense Project
Shannon Baker
Protect Eagles Mere Alliance
Beverly BravermanMountain Watershed Association, home of
the Youghiogheny Riverkeeper
Don Robertson
Izaak Walton League of America
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Liz G. Deardorff
American Rivers, Clean WaterPennsylvania
Barbara L. Stuck
Milton Garden Club
Myron Arnowitt
Clean Water Action
SIERRA CLUB:Jack D. Miller
Otzinachson Regional Group, Sierra Club
Donald W. Miles
Lehigh Valley Group, Sierra Club
Doug HellerNEA group, Sierra Club
Gary Thornbloom
Moshannon Group , Sierra Club
Peter Wray
Allegheny Group, Sierra Club
Thomas Y. Au
Governor Pinchot Group, Sierra Club
John Childe
Pennsylvania Environmental Defense
Foundation
John Dawes
Foundation for Pennsylvanias Watersheds
Maria Payan
Peach Bottom Concerned Citizens Group
AUDUBON SOCIETY:
Philip S. Wallis
Audubon Pennsylvania
Daniel L. Alters
Lycoming Audubon Society
Stan Kotala, M.D.
Juniata Valley Audubon Society