The Hellbender Chronicles

December 31, 2003

District Ranger John Schultz
Bradford Ranger District
29 US Forest Service Drive
Bradford, PA 16701

Dear Ranger Schultz,
I am writing on behalf of the Allegheny Defense Project and our Supporters in order to provide public comment on the two notices relating to Special Use Permits in the Allegheny National Forest.

The two notices dated December 4, 2003, require that public comment be provided by December 31, 2003. However, federal rules on commenting require that the Forest Service provide for 30 days for public comment. As such we are writing to request that the Forest Service comply with the Forest Service’s regulations for notice and comment at 36 CFR § 215 by providing for notice and comment as required by law.

We’ll provide the following brief comments on the proposed special use permits:

Ziesenheim Oil & Gas Permit
The scope of this permit is inadequate. The Forest Service has not developed the required Environmental Assessment in allowing the oil & gas roads to be constructed in association with granting this permit. The NEPA requires that projects with direct, indirect, and cumulative effects (past, present, or future) which may be significant be detailed in an environmental impact statement. Projects which cannot be categorically excluded must be detailed in an environmental assessment. The Ziesenheim oil & gas development has involved the construction of a road network with multiple branches which cumulatively have a high potential for habitat fragmentation and stream degradation. Among other things these roads effect tributaries to Fork Run, the North Country National Scenic Trail, and an area proposed for old growth considerations. Because of the presence of these extenuating circumstances this project cannot have been or continue to be categorically excluded. To do so would be illegal.

Harnett Water Supply
We have no objections to this permit and support granting the special use permit.

Pa. Game Commission Access Roads
The Pennsylvania Game Commission has numerous access roads to State Game Lands No. 29. These access roads introduce traffic into the Game Lands through national forest lands. These roads have a multitude of effects on wildlife habitat and stream quality. An environmental assessment should be prepared that details the use of these roads, the anticipated effects, and alternative access routes that would meet the Game Commission’s needs with less significant impact on forest resources.

Thank you for this opportunity to comment. Please extend the public comment period as required by law.

Sincerely,

Jim Kleissler
Forest Watch Director