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April 4, 2013 by hand-delivery & first-class mail Richard J.

Allan, Secretary Department of Conservation and Natural Resources Rachel Carson State Office Building P.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 and enhancement 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 are some 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 include some 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 Devils Elbow 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 character and 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 DCNRmanaged 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 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 Federal Land 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 Natural Resources 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 to make 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 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 Mine Reclamation 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

Liz G. Deardorff American Rivers, Clean Water Pennsylvania 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 Heller NEA 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

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