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Drill LoyalsockSF 20130404 Letter DCNR MS

Drill LoyalsockSF 20130404 Letter DCNR MS

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Published by Jan Jarrett
Letter hand delivered to DCNR Sec. Allen at invitation-only meeting on Loyalsock drilling
Letter hand delivered to DCNR Sec. Allen at invitation-only meeting on Loyalsock drilling

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Published by: Jan Jarrett on Apr 05, 2013
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12/13/2013

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April 4, 2013
by hand-delivery & first-class mail 
Richard J. Allan, SecretaryDepartment of Conservation and Natural ResourcesRachel Carson State Office BuildingP.O. Box 8767400 Market StreetHarrisburg, 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 Commonwealth’s State Forest lands for future generations. Werespectfully 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 andSullivan Counties – the heart of the Pennsylvania Wilds. In Lycoming County, there aresome 18,870 Forest acres where, due to an unusual provision in the Commonwealth’sdeed, DCNR owns the surface rights even though the oil and gas rights are owned byAnadarko Exploration and Production Company, L.P. (“Anadarko”) and the InternationalDevelopment Corporation. Known as the “Clarence Moore Lands,” these lands includesome of the most important ecological and recreational resources in Pennsylvania’s StateForest system, including Rock Run, an Exceptional Value stream widely hailed as themost beautiful in Pennsylvania; the Old Logger’s 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 StateForest. Documents recently obtained from the DCNR under Pennsylvania’s Right toKnow Law show that the DCNR and Anadarko are currently negotiating a surface usemanagement 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 character and ecological and recreational integrity will be permanently lost. Second, any surfacemanagement 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
 
2010 study by DCNR itself titled “Impacts of Leasing Additional State Forest for NaturalGas Development”; it concluded that “there are zero State Forest Land acres suitable for [additional] gas leasing involving surface disturbance.” Third, to the extent that theCommonwealth 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 isa 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 alegal duty to conserve, maintain, and enhance State Forest lands for the benefit of allPennsylvanians, including future generations. And under the Conservation and NaturalResources Act, the DCNR may not grant a right-of-way over State Forest lands unless theDCNR 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 theDCNR suspend its negotiations with Anadarko and open a public comment period onwhether gas development should be allowed in the Clarence Moore lands, including atleast one public hearing.We look forward to hearing from you and would welcome the opportunity todiscuss this issue, answer any questions or provide any additional information.Sincerely,
Mark Szybist
Citizens for Pennsylvania’s Future(PennFuture)
Robbie Cross
Responsible Drilling Alliance
Curt Ashenfelte
Keystone Trails Association
Andrea Young
Muncy Creek Watershed Association
Josh McNeil
Conservation 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 MineReclamation
Ryan Talbott
Allegheny Defense Project
 Shannon Baker 
Protect Eagles Mere Alliance
Beverly Braverman
Mountain Watershed Association, home of the Youghiogheny Riverkeeper
Don Robertson
Izaak Walton League of America

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