The Hellbender Chronicles

This fun (at times depressing), educational hike will occur rain or shine. Pack your own lunch and snacks and bring plenty of water, rain gear, and hiking boots! This is an all day event, so come prepared.

Pittsburgh and Erie Carpools
The Allegheny Defense Project is organizing a car pool from Erie and Pittsburgh.

Erie folks will be meeting at Mercyhurst College D'Angelo Performing Arts Center Parking Lot at 7am.

Pittsburgh folks will be meeting at the Paneras at 3401 Boulevard of the Allies in Oakland at 7am. Please RSVP for the carpool with Jim Kleissler at (412) 559-1364. Mapquest Directions

Allegheny National Forest meeting place
Those who wish to drive up separately should be at the Morrison Run Trailhead parking area at 9:30am. Following a brief introduction to the day's plans, we will embark on our journey at 10am sharp - so do not be late!

For more information or directions, contact the Allegheny Defense Project at (814) 223-4996.

Directions: The trailhead parking lot is located off SR 59, 16 miles east of Warren, PA and 17 miles from Bradford PA. (To get to SR 59 - From the NW (through Warren), take 6 E to 59 E. From the NE, take 219 S to 770 to 59 W. From the SE (through Kane), take 321 North to 59 W). The Morrison Run trail is located on the Longhouse National Scenic Byway, a 29 mile loop with abundant outdoor recreation sites and scenic vistas around the Allegheny Resevoir.

Download the Flyer and Spread the Word: jpeg file, 1.3MB

Posted by jkleissler at 09:39 AM | Comments (0)

June 11, 2006

ATVs and Old Growth - A Roaded Natural Oximoron

There are many ways in which the proposed Allegheny National Forest management plan makes little sense, or is an outright contradiction. One of these is how the proposed plan overlaps ATV use within the forest with habitat intended for wildlife and plant species that prefer old growth forest conditions. The map below Shows the proposed old growth corridors in green and the proposed ATV "Intensive Use Areas" in red. Note how the corridors actually lie within the ATV habitat. Double click on the map to zoom in:

Posted by jkleissler at 04:37 PM | Comments (0)

May 20, 2006

DRAFT Forest Plan Documents Posted On-Line

The DRAFT Forest Plan and Environmental Impact Statement can be downloaded at the US Forest Service website. There is also some propaganda there that you can check out if you want to scrape your eyes out.

Posted by jkleissler at 11:23 PM | Comments (0)

May 17, 2006

Allegheny Wild! - 2006

No, this isn't batman returns. That is, unless you mean, Indiana Bat Man!

The Forest Service today released the Draft Forest Plan as part of the revision of its forest management plan. The US Forest Service is required to have a forest management plan for every national forest. This document must be revised every 10 to 15 years. The current plan for the Allegheny National Forest was adopted in April, 1986. That plan clearly stated that the assumptions therein were null and void after 10 years of implementation. That plan has now been implemented for 20 years without significant updating for our increasing knowledge of forest science and economics. Therefore, its revision is a vital part of improving Allegheny National Forest conservation.

There are a lot of issues with the forest plan revision process being used. But the most important is the need for the American public to be involved. Overwhelming, the American public supports the original mission of the ALlegheny National Forest - watershed protection. Americans support Wilderness designation, wildlife habitat preservation, and smart, environmentally sensitive recreation. These are, after all, public lands. But the US Forest Service has a long history of managing for timber and oil production.

The situation is extremely dire. The Bush Administration has pushed so that oil & gas drilling will not be considered a significant issue in forest plan revision - despite the fact that the Allegheny hosts more oil & gas wells than the other 154 national forests combined. This is an urgent issue with nearly 700 oil & gas wells being drilled in 2005.

You can get involved today by reviewing the forest plan revision documents. Unfortunately, as of this time, the documents have not been posted. I will update this message when this happens.

Next, you can attend a public meeting and demand that public hearings be held. The public meeting schedule is as follows:

5/22 Bradford - University of Pittsburgh-Bradford in the University Room of the Frame-Westerberg Commons Building
5/23 Warren - Holiday Inn, off Business U.S. 6 west, 210 Ludlow Street
5/24 Marienville - Marienville Area Civic Association Building, off State Route 66 South, Pine Street
5/25 Ridgway - Office of North Central PA Regional Planning and Development Commission,
651 Montmorenci Road, State Route 948 North
5/31 State College - Ramada Inn of State College, 1450 Atherton Street
6/1 Harrisburg - Four Points Sheraton, 800 East Park Drive, Harrisburg, exit 48 off I-83
6/5 Mars (north of Pittsburgh) - Four Points Sheraton in Pittsburgh North, 910 Sheraton Drive, Mars, PA
6/6 Erie - Quality Inn and Suites at intersection of I-90 and State Route 97, 8040 Perry Highway

Posted by jkleissler at 10:40 AM | Comments (0)

November 18, 2004

Learn to Know the Forest

Congressman John Peterson often accuses the Allegheny Defense Project of not being knowledgeable enough to comment on Allegheny National Forest management. Of course, his criticism is absurd. Peterson himself knows next to nothing of the details of forest management or the forest itself.

This is evidenced by his own website, which among other claims, asserts that, "In the Allegheny National Forest you can hike under a canopy of virgin pines in Cook Forest State Park, one of the largest true primeval forests east of the Mississippi." We're not kidding. Look for yourself. Do you want to know what is wrong with this statement? Cook Forest State Park is NOT "In the Allegheny National Forest." Near, sure. But not in it.

The truth of it is that much of that text on Peterson's website is simply borrowed text from DCNR literature referencing the "Allegheny National Forest Region" which is a DCNR region that is not completely synonymous with the national forest. The fact that Peterson's staff doesn't know the difference is far from surprising. But it is unfortunate nonetheless.

Peterson could do himself a big favor by visiting the Allegheny National Forest with the ADP - you know, people who know the forest. He disgraces our region with his gross misrepresentations.

Update: It is hard to be 100% clear, but I believe that this photo on top of Peterson's website is a view from the Minister Creek overlook. This is part of the Minsiter Creek Roadless Area which would be protected if it weren't for the Congressman's outright objections to protecting America's roadless areas. Too bad the Congressman is such a hypocrit.

Posted by jkleissler at 06:11 PM | Comments (0)

November 04, 2004

Allegheny National Forest Meetups

What: Allegheny Defense Meetups

Where: Buffalo, NY
Erie, PA
Pittsburgh, PA

When: Wednesday, November 10, 7 pm

Four more years of the worst environmental President in US History. The Time to Defend our Allegheny National Forest is NOW! Make your voice heard over a cup of coffee or a beer!

Join an Allegheny Defense Meetup Near you!

Go here to e-mail friends

Posted by jkleissler at 02:32 PM | Comments (0)

September 23, 2004

Support the Seneca Indians

This year commemorates the 40th Anniversary of a watershed event that severely disrupted Seneca life and culture. The Kinzua Dam flooded native Seneca Indian lands resulting in a forced relocation. Tyler Heron graced the ADP with his presence at our Fall Gathering last Saturday.

Please return the favor by joining the Seneca Nation in a march to commemorate this unfortuante anniversary. Here is the announcement from the Seneca Nation.

Remember the Removal 2004
Saturday, September 25th, Salamanca, NY

(see schedule of events below)

ALLEGANY TERRITORY — Forty years ago, the majority of families living on the Allegany Indian Reservation were facing one of many historic challenges and threats to its traditions, culture and homeland: the forced removal from fertile, cherished homeland to smaller tracts of land and a new and strange way of life. After years of fighting the specter of a Dam which was to flood much of their settlement area of their people, with all legal avenues exhausted, these people (and non-Senecas) in the “take area” had to move. The traumatic impact on the Senecas continues to be felt today.”
(From: The Salamanca Press, August 11, 2004)

Schedule of Events

contact: Tribal Historic Preservation Office (716)945-9427 or Midge Stock (716)945-1281

Saturday, September 25th, Salamanca, NY

8:30 AM Old Red House Bridge—Jimtown Side

Opening Traditional Thanksgiving (Gan no:n yo:nk) Lehman “Dar” Dowdy

Opening Welcome and Address President Armstrong

Hymns in Seneca Seneca Hymn Singers

Honor those removed with Seneca Tribute and Wreath into the Allegany River

(wreath of pine and bittersweet) Lehman “Dar” Dowdy

Singers Lead Group and Flag Bearers on Walk to Jimmersontown

10:00 AM Haley Building (Cafeteria –Refreshments)

10:15 AM Haley Building Gymnasium

Opening: Purpose of Commemoration—Why is it important to remember?

Significance of Event on who we are and our future

Presenter: Ricky Armstrong: SNI President

10:20 AM Significance of 1794 Treaty and Historic Attempts at Removal

Including post-revolutionary Treaty Period, 1838 and 1842 treaties Kansas and Oklahoma attempts, Dawes Act

Presenter: Barry White

11:15 AM -12:00 PM  20th Century Challenges

Salamanca Lease, Flood Control Act, Evolution and Final execution of Kinzua Dam

12:00 PM – 1:00 PM Lunch

Social and Personal Impacts of Relocation

1:00 PM Fight for Compensation: Homes, Education and Social Welfare

Presenter: Former SNI President George Heron

1:40 PM Community and Personal Impact of Relocation/Removal

Presenters: Joy Bilharz and Panelists (George Heron, Duce Bowen, Rovena Abrams, Hazel Muehlenbruch, Steve Gordon, George Abrams)

2:45 PM Break

3:00 PM SNI Then and Now

Presenters: Barry Snyder, Tribal Councilor, Former President

3:20-4:00 PM Follow-Up: Community Healing, Education and its Importance

4:00-5:00 PM Exhibition Lacross Game—Peanuts vs. Masters

6:00 PM Social

8:00 PM Traditional Closing

For more information click here

Posted by jkleissler at 05:09 PM | Comments (0)

Another Fine Fall Gathering

This American Chestnut Watched Over Us

The Ancient Forest Roadshow

Going Primitive with Spear Throwing

Thanks to our Great Cook Darren!

Posted by jkleissler at 04:34 PM | Comments (1)

September 15, 2004

The Last Wilderness

"It was strangely like war. They attacked the forest as if it were an enemy to be pushed back from the beachheads, driven into the hills, broken into patches, and wiped out. Many operators thought they were not only making lumber but liberating the land from the trees."
- Murray Morgan, 1995, The Last Wilderness

Posted by jkleissler at 06:57 PM | Comments (0)

September 14, 2004

ADP's Tenth Annual Fall Gathering - This Weekend!

Join us for another fantastic time on the northern end of the proposed Tionesta Wilderness Area for the Allegheny Defense Project's 10th Annual Fall Gathering.

Keynote speakers

Lehman "Dar" Dowdy - Director, Seneca Indian Faith Keepers School.

Larry Beahan - Author of Allegany Hellbender Tales and North Country, Public Lands Advocate in Wester New York.

Slideshows: Allegheny Wild!, Zoar Valley's Ancient Forests (NY), and Pennsylvania Wildlands Project

Workshops: Wilderness, logging, fly fishing, spear throwing, sustainable forestry, wildlands, tree climbing, and non-violence.

Hikes and Field Tours: Tionesta old growth forest, North Country National Scenic Trail, clearcuts, and proposed Wilderness. Slideshows on Allegheny Wild!, Zoar Valley's ancient forest, and Pennsylvania Wildlands.

And this just in... The Ancient Forest Roadshow will be joining us!

Accomodations: Please come prepared to camp. The camp wil be primitive (no running water or electricity.) A very limited number of extra tents, sleeping bags, and such will be available. Please call or e-mail the ADP office as soon as possible if you will need to borrow equipment. For a list of nearby hotels and cabins, contact the ADP office.

Food: All meals are included in the registration donation. All meals are vegan/vegetarian. Call or e-mail the ADP office if you have special dietary needs.

Things to Bring: Tent, sleeping bag, water bottle, hiking boots, warm clothes, extra shoes and socks, rain gear, musical instruments, mug, bowl, and utensils. Be prepared for all types of weather!

Posted by jkleissler at 03:14 PM | Comments (0)

W is NOT for Wilderness

On September 4th, the Allegheny Defense Project held a successful rally in Erie, PA, to commemorate the 40th Anniversary of the Wilderness Act.

1. Despite public objections, the Bush Administration has decided to arbitrarily narrow the areas that would be considered for Wilderness designation in the Allegheny National Forest - and has failed to make public the complete analysis that this decision was based on.

2. Despite overwhelming public support for the designation of the Tionesta Wilderness Area in the Allegheny National Forest - the US Forest Service has approved logging as part of the Bush Administration's "Healthy Forests” Initiative and planned additional logging in timber sales such as the controversial Martin Run logging project.

3. Despite overwhelming support for the Roadless Area Protection Rule the Bush Administration has decided to scuttle those rules when they need to be expanded to protect smaller roadless areas in the eastern United States.

Posted by jkleissler at 03:07 PM | Comments (0)

August 19, 2004

Backpacking in the Tionesta Wilderness

This weekend we had a great trip to the Allegheny Defense Project's proposed Tionesta Wilderness Area. Here are a few photos we thought we'd share. Just click on each of the images to zoom.

Posted by jkleissler at 01:12 PM | Comments (1)

June 14, 2004

From Painter Run...

RJ was kind enough to share these two photos with us from Painter Run. As he says, this is a wild place! Click on each image to get a closeup look on our rattler friend!

Posted by jkleissler at 01:56 PM | Comments (2)

June 03, 2004

Public Meeting Revisited

Today, was the first of two public meetings scheduled for this week. It was an experience - they always are. If you can make it this Saturday (June 5th) - the Allegheny National Forest needs your voice. Click here for the details.

Posted by jkleissler at 07:19 PM | Comments (0)

June 02, 2004

Hearts Content Scenic Area

If you have never been to Hearts Content Scenic Area you haven't seen nothing. This old growth forest is tremendous. It has suffered from some mortality due to Beech Bark Disease and acid rain but remains a vibrant old growth forest with excellent regeneration. Here are a few photos from a stroll with my dog this afternoon. Click on each image for a full view.

Posted by jkleissler at 05:43 PM | Comments (1)

May 26, 2004

Tabling for Allegheny Wilderness

The Allegheny Defense Project reaching out to recreationists in the Pittsburgh area at the Venture Outdoors Festival at Heinz Field. It was a good day of climbing, racing, and fishing as ADP volunteers Karen Wood-Campbell and Rachel Martin joined Jim Kleissler and Ryan Talbott for a day under the bright sun. The day was a lot of fun and we met a lot of folks who know and love the Allegheny National Forest. As always, click on the picture to zoom in.

Posted by jkleissler at 06:38 PM | Comments (0)

May 24, 2004

Support the Call for Allegheny Wilderness!

This is a critical moment for the long-term future of the Allegheny National Forest. The US Forest Service is hosting a forest plan revision meeting on June 5th to accept public comment on long-term management of the Allegheny National Forest.

Help demand:

- More Wilderness, Natural, & Scenic Areas

- More hiking, bicycle, and horse trails

- An end to commercial logging

- A phase out of oil & gas drilling

- A moratorium on off-road vehicle trails

Join the Allegheny Defense and ask the Forest Service to adopt our Allegheny Wild! Alternative. This is the last chance to influence the range of alternatives considered in the Forest Plan Environmental Impact Statement (EIS).

The public meeting includes visits to parts of the forest so come dressed for all weather conditions. Click Here for Directions.

Can't Make the Meeting?

Send a letter to the Forest Service. Written letters are more valuable but you can also send an e-mail using our action center today.

Send written letters in support of the Allegheny Wild! Citizens' Alternative to:

Supervisor Kevin Elliott
Allegheny National Forest
PO Box 245
Warren, PA 16365

Send an E-mail!

Bring a Public Meeting to Your Area!

Are you fed up that the Forest Service will not hold public meetings in any of the major urban and suburban areas where most Allegheny National Forest users live? You are not alone!

Use the Allegheny Defense Project Action Center to send a letter to the Forest Service asking for a public meeting in your area. Act Now!

Second Meeting Planned for June 3rd

If you can't make the June 5th meeting you may be able to make a second public meeting scheduled for Thursday, June 3rd. The meeting begins at 9am at the Wolf Run Marina on the Allegheny Reservoir.

Check the Forest Service site for Updates

Posted by jkleissler at 06:26 PM | Comments (0)

May 19, 2004

Exploring Tionesta Wilderness

Among other things I spent part of today in the Tionesta Wilderness Area. I'll post more on this later but for now I thought I'd share these photos of the ADP's proposed wilderness. Click on each photo to zoom.

Posted by jkleissler at 10:43 PM | Comments (1)

November 19, 2003

All Quiet on the Allegheny Front

When its all quiet on the Allegheny front you should beware that a storm is brewing! And one most certainly is. While our silence on the weblog might be interpreted as calm it shouldn't be. We have been crazy busy these past few days. Here is a quick update on things that are brewing.

Last Friday Ryan attended a private forum in Pittsburgh. The bogus forum was stacked with pro-extraction voices with the obvious goal of attacking Allegheny Defense Project. Despite his refusal to hold a public meeting in Pittsburgh Allegheny National Forest Supervisor Kevin Elliott somehow found the time to attend this bogus private forum as a speaker. You can tell Kevin what you think by e-mail if you wish.

On Saturday, ADP folks attended a field tour for the Martin Run Timber Sale. This logging project is a disgrace to national forest management (and there is no polite way to put it). With hundreds of acres of logging immediately adjacent to the Tionesta Scenic and Research Natural Areas and logging along the North Country and Twin Lakes Trails this project is going to create a lot of controversy. We will have more details on this sale out some time soon. For now I put up this color coded map to show the location of logging units in relation to the old growth (remember the East Side sale had logging units adjacent to the southern and eastern boundaries). The key: darkest red(clearcuts), medium red(other even-aged cuts), light red(selection cuts), yellow (release cuts), light blue (herbicide, fencing, fertilizer, and/or site prep), dark green (old growth).

On Friday Ryan and I are meeting with Pennsylvania General Energy to discuss their proposal for three new oil and gas wells at Salmon Creek. Two are located within the Management Area 6.1 section that follows Salmon Creek and a third is located near the North Country Trail along Guiton Run. My understanding is that more wells are also proposed but will know more after our meeting on Friday. The meeting is being held as a result of our legal settlement .

There is an udpate on Allegheny Wild! coming soon as well. Some real BIG news.

Posted by jkleissler at 11:31 PM | Comments (7)

November 09, 2003

Review of Notice of Intent - Part III

"Other Revision Changes"

In Part II we discussed the four "Preliminary Issues" recognized in the Notice of Intent. We discussed how those four issues relied on an incorrect legal standard in order to avoid addressing significant issues such as watershed management and oil & gas management. Some of these issues, particularly watershed management and soils conservation, were relegated to the next section in the Notice of Intent titled "Other Revision Changes."

The statement in the Notice of Intent is that issues in the "Other Revision Changes" will only be addressed through "updates, corrections or modifications that will clarify or strengthen guidance provided in the plan." The implication is that only minimal adjustments will be made. In this part I will review the several issues listed and where appropriate discuss how they ought to be considered "significant issues".

Soil and Water Quality Monitoring
There will be some good adjustments made in this area such as the identification of a management area specifically for "riparian zones". However, with the designation of numerous forest streams as High Quality/Exceptional Value under the Clean Water Act and as Wilderness Trout Streams under state law and the wide variety of new information on aquatic habitats and biodiversity in the Allegheny National Forest it is hard to understand why the revision process would stop there. Millstone Creek was recommended for special designation by scientists due to its high biodiversity. It would foolish to think that management area prescriptions should be limited to the "riparian zone" while headwater areas remain within management areas where logging is emphasized.

It is odd (do I overuse this word?) that watershed management is not recognized as a significant issue. The Allegheny National Forest was founded with the purpose of protecting water quality. Adopting a management plan that reflects this original purpose is evidence of negligence at the hands of forest managers - particularly with the documented degradation of Salmon Creek and Grunder Run.

As for soils, the Forest Service totally fails to act responsibly here. There is no proposals for restoring soil health due to several decades of mismanagement combined with the degradation of soil health due to acid rain. With the decline of trees due to poor soil health driving most logging projects in the Allegheny National Forest it is inexcusable not to recognize soil conservation and restoration as a significant issue.

Heritage Resources
There are no designated Heritage areas. There are few management guidelines for protecting these areas. Management Area designations do not reflect Heritage Resources adequately. But the Forest Service will not consider "Heritage Resources" a significant issue. I can't say I understand this.

Scenery
The Forest Service is proposing a change to the way they protect visual quality. The current system simply comes down to protecting an occasional beauty strip to hide logging activities from drivers on the highways. What we've found with the current visual quality system is that it really does little, if anything, to protect scenic quality. If anything it ultimately contributes to scenic degradation by encouraging activities that degrade forest quality outside of the beauty strips.

From what the Notice of Intent says the Forest Service will use a new system that will change how scenic quality is "protected" without changing the emphasis of how it should be done.

What the "Scenery" item omits is actually adopting changes to the Forest Plan to actively manage for forest scenery. For example, as noted in Part II the Forest Service is not planning to adopt any new Scenic Areas even though there hasn't been a new Scenic Area in the Allegheny in over thirty years. Another important "Scenery" change to the plan would be a reorganization of management areas to emphasize management areas that protect the scenery throughout the forest and prevent areas of the Allegheny from having permanently scarred scenes. Another important aspect would be managing the forest to emphasize scenery (management of existing vistas, providing trails to natural vistas, providing interpretation of views including education about forest ecosystems). Again, this should be a significant issue that drives alternatives.

Transportation Systems
This has to do with forest roads. This is stunning. Nothing to address the overwhelming road densities in the Allegheny National Forest. There are 4,000 miles of roads and only 200 miles of non-motorized trails in the Allegheny. This represents an abusive management program. There are few issues in the Allegheny that are more significant. But there are no proposals for addressing the density of roads in the forest except to adjust limits in certain areas for future road construction. Nothing about removing unnecessary road. Nothing about protecting roadless habitats. Nothing about actually reducing road densities. This is what you might call "dodging the issue".

Monitoring
Monitoring in the Allegheny National Forest is a huge issue. The Forest Service monitoring and evaluation requirements are so vague that there is little requirement to ensure that monitoring is done in a fashion that produces data which is comparable from year to year. The result is that much of the monitoring in the Allegheny is useless in actually determining if there are new management problems developing in the forest. There is no place where this is a larger problem than in wildlife monitoring. The Forest Service is supposed to monitor population trends, but monitoring often uses different protocols from year to year and in many years monitoring is skipped altogether. Although monitoring is required for pesticides, impacts of logging and roads and water quality, and maintenance of viable populations of wildlife there is no clear protocol for how any of this monitoring is to be done and what thresholds of disturbance should be avoided. In short, monitoring methods are not scientifically sound, repeatable, or in some cases even measurable.

Management Areas
The "Management Areas" are the areas of zoning in the Allegheny National Forest. Today, for example, 2/3 of the Allegheny falls into the zoning area "Management Area 3.0" which calls for the use of even-aged logging techniques to increase concentrations of black cherry in the Allegheny National Forest. The distinctions between most management areas are what types of logging are allowed. But this is the poor basis for identifying management areas.

The Forest Service suggests that the emphasis in this area will be in revamping standards and guidelines for management areas instead of the distribution and types of management areas. This is inadequate. The Forest Service should be using data on watersheds, special area opportunities, wildlife habitats, recreational uses, roadless areas, soil and topographical typing, and other considerations in the identification of what kinds of management areas will exist and then distribute lands appropriately. This is exactly what ADP did in our Allegheny Wild! proposal and is much more consistent with what has been done on other national forests. A good example would be the designation of different management areas for the North Country Trail corridor or the Wild and Scenic River Corridors. Unfortunately we probably will not get past identifying and distributing management areas as a means of implementing a major timber program until commercial logging in the Allegheny National Forest is eliminated.

Economics
Here the Forest Service simply says that it will do a passive analysis on the impacts of forest management alternatives on regional economies. Of course, a good economic alternative would emphasize the sustainable economic industries which are most closely linked to the national forest, i.e. recreation and tourism. It doesn't appear that the Forest Sevrice is going to give economics proper consideration as a significant issue although they clearly should.

More on the Notice of Intent
Part I - Legal Issues
Part II - Preliminary Issues
Part III - Other Revision Changes
Part IV - Issues Not Addressed
Part V - Public Participation

Posted by jkleissler at 07:08 PM | Comments (0)

November 07, 2003

Action Alert!

Act Today for your Allegheny National Forest!

Considered one of the most at risk national forests in America, the Allegheny has been under siege from logging and oil interests for nearly two decades under a 1986 management plan. The next two decades of forest management are being decided now with the initial period for public comment closing on Monday, November 10th.

The Allegheny Defense Project has provided an alternative vision for forest management that would emphasize much needed Wilderness, Scenic Areas, watershed protection provisions, restoration management, expanded hiking and bicycle trails, and a phase out of the damaging practices of commercial timber and oil & gas drilling.

Please provide comments today:

1. Write to: Supervisor Kevin Elliott, PO Box 847, Warren, PA 16365 or e-mail him

You can also comment using our comment assistant

2. Endorse the Allegheny Defense Project's Allegheny Wild! Proposal

Posted by jkleissler at 04:50 PM | Comments (0)

November 06, 2003

ADP Testimony

Here is my testimony provided at the public hearing on forest plan revision in State College, PA, last night. I'll post later with more o the hearing.

James Kleissler, Forest Watch Director
November 5, 2003

Thank you for this opportunity to testify today on management of the Allegheny National Forest and the future of our communities in northwestern Pennsylvania. The right of every American citizen to share their thoughts and concerns in the management of our public forests is paramount and it is public events that help to preserve that right. And I wish that right had been properly preserved here today.

Today, I am providing testimony on behalf of the individual and organizational Supporters of the Allegheny Defense Project. I heard from a number of Supporters before I came here today and they asked me to send one message: hold a public hearing at a reasonable time and place with adequate and legally sufficient public notice they will be there. This means public hearings during the daytime and evening, during the week and on the weekends, where local residents can walk, bike, take public transport, or drive, and with adequate notice so that Americans can re-organize their schedules in a reasonable and timely manner if necessary. It may be easy to forget but most Americans are struggling for free time right now, they are working second jobs, longer hours at their primary job, and are doing it with less vacation and personal days available to them. The ability to comment on national forest management is not an ability, it is a right.

The decision to hold an additional hearing period this evening is an acknowledgement that the original plans for a daytime hearing were inadequate. While we applaud the addition, the failure of the Forest Service to provide legally sufficient notice of the date and time and hearing details with 30 days notice as required by the National Forest Management Act is inexcusable. And this if unfortunate because this hearing today is about our most treasured resource in the region – the Allegheny National Forest.

The Allegheny is a national treasure but it only can remain one if it is given the proper, delicate care that it deserves. The towering American beech and Eastern Hemlock, the rising Sugar Maple and Red Oak, and the swift flow and ripple of forest brooks. The quiet prowl of bobcat, the eager look of trail hikers, the swift swoosh of canoe paddles, and the light trickle of rain drops collected in canopy leaves. The Allegheny National Forest is home and hearth to millions of Americans and a vast array of wildlife and plants.

All is not well here. Over 90% of the Allegheny National Forest remains in management areas open to commercial logging and over 90% of this logging is done through the most damaging even-aged timbering practices which ultimately lead to clearcutting (regardless of the "removal" euphemisms the Forest Service tries to disguise them with). Even the U.S. Forest Service’s Need for Change document acknowledges that the extensive timber cutting and oil and gas drilling that dominate national forest management are infringing upon recreation and wildlife habitat and causing irreversible damage.

It isn’t simply these destructive practices that is the problem. The Allegheny National Forest management plan is an antique. The Forest Plan needs an overhaul, not a slight adjustment. The Allegheny has less than 2% of national forest lands in Wilderness, a miserable concentration when compared with other national forests. The Allegheny has less than 5% of its forest lands in total special area designations. Again, this is miserable in comparison to other national forests. The only way in which to remedy this deficit is a complete overhaul of special areas management in the Allegheny National Forest including:

• Recommendations to Congress for new Wilderness Areas
• Recommendation to Congress for 18,000 acres in new National Recreation Areas
• Adoption of the first Scenic Area in the Allegheny National Forest in over 30 years at Bogus Rocks;
• Adoption of 250 acres in new Research Natural Areas;
• Adoption of 3,670 acres in new forest Historic Areas;
• Adoption of 7,474 acres in new Natural Areas;
• Adoption of 30,376 acres in new forest Recreation Areas;
• Full adoption of the Forest Service’s proposed old growth corridor with some adjustments to make the plan more consistent with the best available science;
• Designation of a protective corridor along the national scenic North Country Trail; and
• Establishment of 200 miles of new hiking, bicycle, and horse trails.

• Restoration of streams degraded by timbering, oil & gas drilling, and ATVs;
• Management prescriptions which recognize riparian zones, wilderness trout stream watersheds, High Quality and Exceptional Value Streams;
• Special Area designation of new federally designated wild and scenic rivers;
• Recommendations for designation of streams as state designated wild and scenic rivers;
• Streams and watersheds of particular biological value;
• Recognition and management of water-based trails; and
• Management of wetlands, vernal pools, and other important habitats.

Now, while the Notice of Intent and Need for Change documents inadequately deal with the very real problems of timber management in the Allegheny National Forest, they entirely ignore many other key subjects:

Oil and Gas Drilling: The Need for Change document recognizes that oil and gas drilling is causing irreparable harm to the Allegheny National Forest by permanently changing forest areas from natural forest conditions to conditions incompatible with wildlife and recreation. We also know that oil and gas drilling has caused harm to the national scenic North Country Trail and has impaired watershed quality including that of Salmon Creek. The astonishing thing in the Notice of Intent is the decision NOT to consider oil and gas drilling a significant issue. There simply is not legal, moral, or scientific justification for this.

Additionally, the Need for Change document has all kinds of incorrect information on oil and gas in the Allegheny National Forest. The Forest Service has acknowledged in the past that they have not been making proactive attempts to purchase mineral rights underneath the Allegheny National Forest. The Need for Change document incorrectly assumes there is no interest in selling these mineral rights because attempts to buy them have been unsuccessful. But the Forest Service has not made many, if any, serious attempts to purchase mineral rights throughout the Allegheny National Forest. When serious attempts have been made in the past, while perhaps difficult, the Forest Service was able to purchase the rights in the end.

We filed a FOIA request two years ago which determined that in the seventeen years following the Pennsylvania Oil and Gas Act of 1984 the Forest Service had never utilized the "objection" provisions of that law to protect the Allegheny National Forest. This despite the fact that harm to "public forests" are a basis for objection in the law. In response the Forest Service claimed that oil & gas drilling was compatible with management of the Allegheny National Forest. However, the Need for Change documents reflects the fact that this was intentionally misleading information given out by the Forest Service. And the Need for Change document incorrectly cites the Pennsylvania law as dating to "2001" when in fact the relevant provisions were adopted seventeen years earlier. The manner in which these mistakes are made suggest that they were made intentionally to cover-up the negligent management supervision of leadership on the Allegheny National Forest.

Geology and Soils: The U.S. Forest Service has virtually no meaningful management direction for cave and formation management in the Allegheny. Nor does the Forest Service have any scientifically sound ideas for how to resolve the very serious soil health problems we are facing as a result of acid rain, logging, herbicide use, and the use of nitrogen-based fertilizers. The failure to identify these issues as significant issues is again inexcusable.

Herbicides: The current Forest Plan had no intention of allowing herbicide use past 1995. This is clear from reading the 1991 Environmental Impact Statement and Record of Decision on this subject. Since 1991 there has been a wealth of new information on herbicides documenting their very serious impacts on the forest ecosystem. More recent research shows that even at low doses the herbicide Roundup is astonishingly toxic to tadpole populations. Somehow, the Forest Service doesn’t think that the implications of herbicide applications are a concern despite the lack of monitoring and up to date environmental analysis.

The ability of the U.S. Forest Service to ignore these issues is directly related to the use of an incorrect legal stand for determining what issues will be assessed as part of forest plan revision. The Forest Service has arbitrarily decided that instead of studying "significant issues" in the environmental impact statement as required by law they will limit the issues of concern to those "identified as being most critically in need of change." This is an incorrect legal standard that has prejudiced this process from the start.

These are not the limits to our concerns. The damage caused over the past thirty years of mismanagement will only by reparable if a full-scale restoration program is put in place, More details about our recommendations are included in our Allegheny Wild! report available on our website at www.alleghenywild.org.

Posted by jkleissler at 03:12 PM | Comments (2)

November 04, 2003

Public Hearing Update!

A second evening session for public testimony has been added..

PUBLIC HEARING!

Wednesday, November 5
Toftrees Resort and Conference Center, 1 to 5pm & 6:30 to 9pm
State College, PA

Come and help protect the Allegheny National Forest from continued mis-management by the U.S. Forest Service. Clearcutting, oil & gas drilling, road building, pesticide usage, and ATVs all threaten important wildlife habitat, watershed quality, and potential Wilderness areas. The Allegheny needs your help today.

Make your voice heard for an Allegheny Wild! today.

Click here for directions

For more information click here

Posted by jkleissler at 02:14 PM | Comments (0)

October 17, 2003

Support Recreation in the Allegheny

The Forest Service has done nearly everything possible to suppress non-motorized recreation opportunities in the Allegheny. Make that everything imaginable. So when proposals like this one come along I believe that they should be supported:

Wesley Woods Christian Education Center has applied for a recreation special use permit on the Bradford Ranger District of the Allegheny National Forest. The purpose of this permit is to conduct outfitting and guiding services for youth trips from Center for rock climbing and rappelling at Rimrock and Minister Creek and for hiking on the North Country National Scenic Trail. Locations for both these activities are shown on the enclosed maps.

Proposed activities include:

Rappelling and a limited amount of rock climbing will occur on approximately 1-2 days per week from June 1 to August 30. it will include no more than 30 people at one time (guides and students). No permanent fixtuers will be used and Leave No Trace guidelines for rock climbing will be taught and used.

Hiking on the North Country National Scenic Trail will be one-week long, 96-mile hike. Termini will vary from year to year to give return students a different view and experience. Camping will occur on 5 nights at already established sites. No more than 10 people (guides and students) will be in the group at any one time. Leave No Trace hiking and camping techniques will be taught and used.

Posted by jkleissler at 01:58 PM | Comments (0)

October 16, 2003

Review of Notice of Intent - Part II

The Notice of Intent is the first step in the development of a Forest Plan. In Part II I'm going to discuss the "Preliminary Issues" identified in the Notice of Intent. Remember from Part I that all "significant" issues must be addressed in an environmental impact statement (EIS) and therefore you cannot prejudice the process by arbitrarily selecting a limited number of "Preliminary Issues" to narrow the scope of the EIS. Check out Part I for more on this.

Now as to the substance of the Preliminary issues identified, there is this to say. The Forest Service identifies four "preliminary" issues: Recreation, Habitat Diversity, and Special Areas Designations.

I'll discuss the full range of issues not mentioned further down. However, note at the outset that watershed management is not a key issue identified here. This is significant - the Allegheny National Forest was founded to conserve the navigable waters therein. You can view the original proclamation right here on our website.

Recreation
There can be no doubt that recreation is a significant issue for forest plan revision. The language in the notice of intent is sufficiently broad to allow for a wide array of recreation related issues to be discussed. If anything it is disappointing that the Notice of Intent doesn't do more to break down this issue as it does for other issues. That said, at this point the Forest Service is most definitely jumping the gun by getting too specific on the other issues.

Allegheny Wild! would fix this problem of course. When this five part series on the Notice of Intent is done we'll post an analysis of the mysterious recreation plan released without fanfare (or consistent with federal law for that matter) over the summer. We'll post it sooner if we get a chance.

Vegetation Management
The vegetative structure and composition of a natural forest is complex involving many flora species across an array of habitats (wetlands, uplands, old growth, opening) and within specific niches in each habitat (e.g. ground layer, shrub layer, mid-story, overstory). The Forest Service's Notice of Intent has reached new heights in oversimplifying the complex concept of vegetation management by equating vegetation management with timber production:

This issue involves maintaining healthy forest conditions capable of providing sustainable levels of forest products.

That really says it all. This apparently doesn't mean maintaining vegetative forest conditions to provide the habitats necessary to maintain viable populations of native species - even though this is clearly mandated by the National Forest Management Act (NFMA). And in case you were wondering the Notice of Intent clearly equates normal "forest products" with timber as it equates all non-timber "forest products" as "special forest products" as a sub-issue here.

Now the Forest Service wouldn't be expected to come out and say "We need to come up with ways to log unhealthy trees faster" but then they clearly do in the Notice of Intent: "There is also a need to develop guidelines for more timely and effective responses to insect and disease threats." This is verbatim of a typical timber sale projects purpose and need. It should be duly noted that the Notice of Intent surmises just before this section on "Forest health" that forest health threats are disproportionately affecting American beech and sugar maple. What we saw with the East Side Timber Sale and we are seeing with others in the pipeline is the notion that because American beech and sugar maple are susceptible to health problems they should be replaced with black cherry (we'll save the serious forest health problems of a black cherry dominated forest for another day). This is something to watch out for as this process proceeds.

The remaining subcategories are more of the same. The topics (with my shorthand on them in parentheses) are: Reforestation techniques (what kinds of herbicides, fertilizers, and fencing to use after clearcuts), timber production suitability (what kind of volume can be produced), and Silvicultural systems (how can even-aged logging be justified despite the NFMA's restrictions on its use). Most significant about all of this is the language was chosen carefully and reflects an unwillingness by the Forest Service to revisit its illegal black cherry tree farming in the Allegheny.

Habitat Diversity
I'll take one step back here because this is where this point belongs. In the previous section the Notice of Intent explains that "vegetation composition ... addresses the diversity of tree stands (particularly by species and age-class) on the Forest." That bold emphasis is my own. Chew on that sentence for a second. At first glance it may seem to make sense. Forest diversity is in many ways defined by the species of trees and various ages. However, here the Forest Service isn't talking about species and age within tree stands but rather between tree stands. How do I know this? Well, for one because it is consistent with how they treat the subject in other documents. But also because of their use of the phrase "tree stands" here compared to the use of the qualifiers of "species" and "age-class". This is entirely consistent with how the Forest Service functions, it just isn't consistent with the forest ecology perspective on biodiversity.

That was a long throw-back to the prior section. Within the habitat diversity section the Forest Service actually defines habitat diversity to include the maintenance of "desired non-native species" found on the forest. The maintenance of non-native species is unquestionably undesirable in nearly all cases here except where irradication of those species is not feasible and acceptance and adaptation are unavoidable. The major problem here is the equivalency given to certain non-native species which should never be the case. Even where non-native species might be maintained that should never be given equivalency to native species. But remember we are talking about a native forest that is supposed to be 86% Eastern hemlock-Northern Hardwoods but is now increasingly "Allegheny Hardwoods", i.e. black cherry.

There are several subsections here including threatened and endangered species, habitat for game species, habitat connectivity, and old growth habitat. Overall the descriptions of each specific subcategory are adequately broad to allow for appropriate measure to be adopted (within this already compromised framework, which isn't to say that would be sufficient). There are a few things I noticed however.

The most significant is where is the commitment to maintaining viable populations of native species? The Notice of Intent seems to limit concern to species already given protections such as Threatened, Endangered, or Sensitive ignoring the many species which are at risk but not listed (including untold invertebrates).

Another perhaps equally significant ommission is the failure to address aquatic habitats in any meaningful way. And this ties directly into the lack of a process for ensuring that both the quantity and quality of habitats are maintained. A lot of attention is paid from tree stand to tree stand but little attention seems to be given to maintaining quality habitats both across the forest and within specific forest stands. This probably reflects what I was talking about earlier with "tree stand" diversity across the forest instead of diversity within "tree stands."

Special Area Designations
As expected this section largely addresses Wilderness and Wild and Scenic Rivers. These are important issues and it is good that they are recognized here. However, this section is unnacceptably narrow.

National Recreation Areas, Research Natural Areas, Scenic Areas, and Heritage Special Areas are only mentioned in passing even though a new Scenic Area or Research Natural Area hasn't been designated in some 30 years. There are no identified Heritage Special Areas and apparently no attempts to identify Natural Areas or botanical areas. It is unclear to me what they mean by "Heritage" here: archeological or historical?

It is unclear what the Forest Service intends to do about other special designations such as state wild and scenic rivers, state wilderness trout streams, and stream designations under the Clean Water Act. In fact, the failure to give watershed management any serious consideration as a key preliminary issue is stunning. Not only is terrestrial "vegetative" management given its own prime position (why is management of animal life not given its own equal importance?) but aquatic management isn't given any mention that I can see in the habitat diversity section. The only mention here is the NFMA mandated issue of possibly designating Wild and Scenic Rivers. Now, in Part III you will see that watershed management is mentioned in the Notice of Intent but only in the section delegated to changes in the Forest Plan for "updates, corrections or modifications." That is hardly the pressing attention that I think President Coolidge might have expected when he signed the proclamation forming the Allegheny National Forest in 1923.

More on the Notice of Intent
Part I - Legal Issues
Part II - Preliminary Issues
Part III - Other Revision Changes
Part IV - Issues Not Addressed
Part V - Public Participation

Disclaimer: This is a quick review of the Notice of Intent to help folks understand the context better. Therefore, there may be significant pluses or minuses that are overlooked.

Posted by jkleissler at 12:19 AM | Comments (0)

October 15, 2003

On Wilderness

The Warren Times-Observer ran an article in yesterday's hardcopy edition on the Friends of Allegheny Wilderness Wilderness Proposal. You might have noticed this interesting characterization of ADP's proposal:

A group of multiple-use proponents has lobbied for no more wilderness on the Allegheny National Forest than the currently designated 9,000 acres. Another group, the Allegheny Defense Project, stands for what would be an entirely wild 513,000 acres.

Remember that as wide-ranging as Allegheny Wild! is we are still only proposing an additional 50,000 acres as Wilderness. The FAW proposal is similar in most regards. As far as I can tell here are the significant differences:

• FAW does not propose Minister Valley as Wilderness;
• ADP does not propose any of the existing National Recreation Areas as Wilderness (FAW proposes all of them);
• Although we propose several identical areas, the boundaries between proposals vary significantly with ADP's proposed areas being larger in general.

I think it's good that FAW finally got a proposal out there. We remain concerned about the reduction in National Recreation Area acerage at a time when current acreage in non-Wilderness Special Areas is already deficient. At least one version of the FAW plan did propose some new National Recreation Area acreage that would maintain but not increase the current acreage. ADP, of course proposes an increase in new and total National Recreation Area acreage.

P.S. Part 2 of my analysis on the Forest Plan Revision Notice of Intent will be posted late tonight.

Posted by jkleissler at 02:34 PM | Comments (1)

October 02, 2003

Review of Notice of Intent - Part I

The Notice of Intent to revise the Forest Plan deserves detailed attention. Therefore this is the first of a set of a 5 part series analyzing the Notice of Intent to revise the Allegheny National Forest "Forest Plan"

I talked some yesterday about the public involvement issues. I will continue that discussion as Part V of this review. Until then check out that post below.

The Legal Background
The Planning process must primarily comply with two principle environmental laws - the National Forest Management Act (NFMA) and the National Environmental Policy Act (NEPA).

The National Forest Management Act
First, the NFMA explains the revision process as involving the same process and requirements as in the development of a forest plan (16 USC 1604(f)(5)).

There are several indications in the Notice of Intent, as well as in earlier communications, that the Forest service intends to short-circuit this process. One of these is by limiting the number of significant issues that are actually address (which I will address below in relation to the NEPA). Another is in insinuating that "The Allegheny National Forest proposes to narrow the scope of revising the Forest Plan by focusing on issues identified as being most critically in need of change." (FR 68(186): 55364) On its face, this statement contradicts the very notion of the NFMA which provides that the revision process must comply with the same provisions that are required in the development of a new forest plan. When we get to the variad of issues in the next part of this series you will see how significant this is.

The Notice of Intent does list the five areas where Forest Plans make decisions, and except for the exclusion of administrative designations of special areas the list seems to be accurate. However, the list of issues is qualified by the questionable statement cited above which undermines the seemingly accurate list of issues.

The National Environmental Policy Act
The Notice of Intent is issued as part of what is called the "scoping" process (which lasts until after the public comment period is closed) under the NEPA which requires:

Determine the scope (§1508.25) and the significant issues... (40 CFR § 1501.7(2))

Identify and eliminate from detailed study the issues which are not significant... (40 CFR § 1501.7(3))

Scope consists of the range of actions, alternatives, and impacts to be considered in an environmenal impact state. (40 CFR § 1508.25)

Now there is more to it, but we can see two things here. Number one, is that the threshold for whether or not an issue gets discussed is whether or not that issue is significant. The more significant issues there are the more issues that need to be discussed in detail. This is why arbitrarily limiting the process to a specific number of issues (the Forest Service has indicated they will limit to 3 or 4 issues) is illegal. The next two parts in this will get into detail what issues the Forest Service plans to discuss and what significant issues are somehow left out.

Now I said that there are two issues here. The second one has to do with their intent to narrow the scope of revision to those most "critically in need of change." I should mention here that there is a lot of case law about this that makes it clear that the scope of an Environmental Impact Statement cannot be arbitrarily narrowed to ignore significant issues. Here the Forest Service appears to be intending to narrow the scope from "significant issues" (which is a much broader category) to issues "critically in need of change." The result would unquestionably be an environmental impact statement that doesn't adequately address the environmental impacts or a broad range of alternatives.

More on the Notice of Intent
Part I - Legal Issues
Part II - Preliminary Issues
Part III - Other Revision Changes
Part IV - Issues Not Addressed
Part V - Public Participation

Disclaimer: This is a quick review of the Notice of Intent to help folks understand the context better. Therefore, there may be significant pluses or minuses that are overlooked.

Posted by jkleissler at 01:15 PM | Comments (2)

October 01, 2003

Forest Plan Revision - MARK YOUR CALENDARS!

This is it. The Forest Service has started the official process for revising the forest plan. And they have once again minimize the public notice of meetings and FAIL to hold any in the three biggest cities that attract Allegheny National Forest users: Pittsburgh, Cleveland, and Buffalo. Instead the choice of locations is clearly selected to minimize dissenters to their cut it all down mantra. Note how they once again have REFUSED to hold a meeting south of the Allegheny near Clarion, PA. This is a pattern of manipulation that must cease immediately.

Here are the scheduled dates for public meetings:

October 27 - Warren, PA

October 28 - Erie, PA

November 5 - State College, PA (PUBLIC HEARING!)

Two relevant links:

The Forest Service Press Release

The Notice of Intent in the Federal Register

Look for detailed analysis on this early tomorrow. In the meantime use this thread to add your own thoughts!

Posted by jkleissler at 11:51 AM | Comments (2)