June 23, 2006
Photo Shoot
The following link will take you to a photo gallery of the oil and gas development being led by Minard Run Oil Company at Pigeon Run, just north of the Morrison Run roadless area, within the Allegheny National Forest. While this development is obliterating forest to the north of the roadless area (which ADP has proposed for Wilderness), East Resources is active causing its own damage to the southeast at Chappel Fork and its tributaries.
And please do not mind the photos facing the wrong direction. They'll be fixed on Monday when we have the time...
Posted by jkleissler at 07:01 PM | Comments (0)
July 22, 2004
ADP Testifies Before Citizen Advisory Council
Things are busy here but I thought we could at least share excerpts of our recent testimony before the Pennsylvania Department of Environmental Protection's Citizen Advisory Council. The testimony was written on short notice but comments and criticisms are welcome. There is a lot more that we could have said.
DEP Citizens Advisory Council Testimony
James Kleissler, Forest Watch Director
July 20, 2004This testimony is being provided tonight on behalf of the Allegheny Defense Project. We are a non-profit conservation organization with concern regarding oil & gas drilling on public lands within the northwest region. This testimony is based on our experience in reviewing thousands of well permits, monitoring of hundreds of oil & gas well sites in the Allegheny National Forest and on state lands, and our familiarity with the ecology of the upper Allegheny River watershed.
Oil & Gas Management
Northwestern Pennsylvania is the original oil region of North America. Because of this we have a 150 year legacy of oil and gas drilling accompanied with both the economic and ecological fallout of this boom and bust industry. While technologies have advanced, the impacts from oil & gas drilling have changed more than they have improved. The sensitivity of the forest environment to oil & gas drilling is of great import, however it appears to be little understood by both state and federal agencies alike. It is our hope that this Advisory Council can take the necessary steps to bring state review of oil & gas management into the 21st Century.eFacts, Electronic Permitting, PA*IRIS, and Other Business Services
Simply following oil & gas permitting processes can be a challenge. The entire permitting process is secretive until a permit is actually issued. In order to follow permit issuances effectively one must visit the Northwest Regional Office on a regular basis and review well plats posted in the file review room. This requires an appointment that must be scheduled at least one week in advance.Information posted on the citizen’s eFACTS website is either out of date or too vague to be useful. Often times, thousands of permits can exist for single townships and the names of well sites and farms are often too ambiguous to be useful. This is complicated by the constant shifting in ownership of wells, mineral rights, and other relevant facts.
The state has developed an internet based system on which well permit information is maintained. However, this information is not available to the public but only to wealthy private interests such as oil businesses who can write subscriptions off on their taxes. The public can apparently view the database in Pittsburgh with an appointment, but this hardly provides the same service that the state has provided industry.
“The Pennsylvania Internet Record Imaging System (PA*IRIS) (Figure 1) combines the Pennsylvania Geological Survey’s Wells Information System and Oil and Gas Base Map GIS system with scanned images of corresponding oil and gas documents. The unique characteristic of PA*IRIS is that it is available on the worldwide web 24 hours a day, 7 days a week.
PA*IRIS is a public/private partnership between the Pennsylvania Department of Conservation and Natural Resources (DCNR) and over 60 oil and gas companies throughout the United States and Canada. It provides Internet access to more than 600,000 pages of scanned documents covering current and historical location plats, well record and completion reports, and plugging certificates. Figures 2 and 3 provide examples of the PA*IRIS interface and documents that can be retrieved remotely through the system.”
It is incomprehensible to understand why this database and other permitting information is not made available to the public on a timely basis with the ease and convenience allowed to industry. Industry can afford to send staff to DEP offices to review well permitting details. The costs to conservation-minded citizens and organizations operating on shoe-string budgets are difficult to comprehend when this information is already available on the internet 24 hours per day, 7 days a week.
We are concerned as citizens that our rights to protect our interests in these matters are sacrificed by the lack of a public participation process in oil & gas well permitting and the lack of immediate access to details regarding issued permits. With no opportunity to comment, the public has only one avenue by which to redress grievances regarding proposed permits – appeals before the Environmental Hearing Board. However, Citizens only have 30 days to file such an appeal and rarely know when a given permit has been issued less than two weeks after it has already been posted. This process hurts both industry and the public by forcing a costly, timely appeals process where possible concerns may have otherwise been resolved.
National Forest Management
When myself and another citizen filed such an appeal before the EHB in 2001, the Department’s Oil & Gas Management Staff which had been approving well permits for years in the Allegheny National Forest knew absolutely nothing about forest management direction for the areas affected. Thus permits were approved for areas for which oil & gas drilling was intended to be a minor, if at all, presence in the national forest. No serious consideration was given to the impacts to this public resource although the Pennsylvania Oil & Gas Act requires these considerations.Our reviews suggest that little has changed in this regard. The permit applications now recognize the Management Area (a zoning system employed in national forests) within which proposed wells far but little more than that basic recognition. There is no analysis regarding how those proposed wells affect the integrity of the public resource regardless of its importance.
A classic case of this is the recent approval of oil & gas well management initiated by Catalyst Energy in Warrant 3773, Elk County. This development includes several dozen proposed and drilled oil & gas wells. This development occurs in an Exceptional Value Watershed and State Designated Wilderness Trout Stream. The development impacts a national forest roadless area and occurs immediately adjacent to a National Natural Landmark. This is also an area proposed for federal Wilderness designation by two conservation organizations. While we are still reviewing the documents related to approval of this development, significant issues appear to be entirely unaddressed in any kind of written review or analysis.
An ongoing difficulty with accessing Department review and approval of oil & gas proposals is the lack of any kind of written record clearly defining the rationale in approving such projects event when they are proposed in sensitive public lands areas. It is entirely unclear to the public how the Department is serving its Constitutional role of protecting our public resources.
The permitting process for oil & gas activity is plagued by some questionable public/private business relationships. The revolving door between important agency positions and the industries they are meant to regulate is a growing concern for oil & gas as it is for many other activities. This appearance is not helped by what primarily appears to be a rubber stamp permitting process geared more towards an easy application process for industry than an easy public review process for the citizens of Pennsylvania. Insult is added to injury by repeated slaps on the wrists of industry for serious infractions of environmental protection laws.
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Posted by jkleissler at 12:07 PM | Comments (3)
June 01, 2004
Oil & Gas Leasing on Federal Public Lands
This is an interesting article on federal oil & gas leasing:
WASHINGTON (AP) — Nearly three-fourths of the 40 million acres of public land currently leased for oil and gas development in the continental United States isn't producing any oil or gas, federal records show, even as the Bush administration pushes to open more environmentally sensitive public lands for oil and gas development.An Associated Press computer analysis of Bureau of Land Management records found that 80 percent of federal lands leased for oil and gas production in Wyoming are producing no oil or gas. Neither are 83 percent of the leased acres in Montana, 77 percent in Utah, 71 percent in Colorado, 36 percent in New Mexico and 99 percent in Nevada.
How much exploration has occurred on the nearly 30 million acres of non-producing public land leases is difficult to say. BLM officials could provide no details on the number of exploratory wells drilled on those leases, despite repeated requests for that information over the past two months.
But with so much public land already available for exploration, environmental groups and local landowners are questioning why the Bush administration is pushing to lease still more federal land to the oil and gas industry, particularly in areas that the groups and some lawmakers want protected as federal wilderness areas.
For an alternative take, the oil industry often argues that leasing of public lands is not a big deal because it doesn't mean a public lands area will be drilled. And while this is true it is also true that once leased it is very difficult to provide a public lands area with greater protections.
I don't have a link for the article itself but it was accompanied with these two neat charts:
• The top 100 oil and gas lease holders on federal lands by acres leased
Now you'll notice that for the most part that oil & gas activity in the Allegheny National Forest is not reflected here. This is because 93% of the minerals under the Allegheny National Forest are privately held. So while much of this acreage is under lease - little of it is under federal lease. The numbers for Pennsylvania are:
Acres Leased: 7,669 acres
Acres Non-Producing: 2,804 acres
Percent Non-Producing: 36.4%
Posted by jkleissler at 09:41 AM | Comments (3)
January 02, 2004
More Special Use Comments
I hope y'all are interested in these. Here are more comments on some oil & gas pipelines. Just click on the read more link to read them.
January 2, 2004
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 December 2nd Notice relating to Special Use Permits in the Allegheny National Forest.
The notice dated December 2, 2003, require that public comment be provided by December 29, 2003. However, federal rules on commenting require that the Forest Service provide for 30 days for public comment. When the 30th day is a holiday, as is the case with January 1, 2004, the next business day is the official deadline. 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. However, we would like to note that the scoping notice for these proposals is insufficient under 40 CFR § 1501.7. Due to the extremely limited information contained within the scoping notice it is difficult to provide more detailed comments at this time. Please provide a more detailed notice that complies both with the requirements of 36 CFR § 215 and 40 CFR § 1501.7.
Vertical Resources Transmission Line
The permit must be assessed within an Environmental Assessment as required by law. As described this proposal would require that a pipeline longer than one mile in length be constructed across national forest lands in order to transport oil and gas out of the Allegheny National Forest. There are no categorical exclusions providing for pipelines of this length. In addition, the Forest Service must consider the cumulative effects that would include the development of oil & gas wells on public lands and the potential for accidents/spills. This requires that this proposal be considered only after the development of an environmental assessment in accordance with federal laws.
This proposal also appears to infringe upon the proposed Fools Creek Natural Area. This proposal is outlined in the Allegheny Defense Project’s proposal Allegheny Wild! A Citizen Vision for the Allegheny National Forest. Fools Creek is known for its important wildlife habitat and geological history. Greater efforts must be made to conserve this forest area for future generations.
Catalyst Energy Pipeline
This proposal calls for the construction of a pipeline nearly two miles in length. This far exceeds the length of a pipeline that may be constructed on national forest lands through a Categorical Exclusion. This project must be detailed in an Environmental Assessment as required by federal law. Failure to do so would undermine the intent and purpose of the National Environmental Policy Act.
As part of the consideration as to whether or not to prepare an Environmental Assessment, the Forest Service must consider past, present, and future direct, indirect, and cumulative impacts. This pipeline is part of a larger oil & gas development with significant effects on the national forest lands contained therein. These effects include degradation of wildlife habitat, stream quality, and recreational/scenic values. This proposed permit must be evaluated in more detail consistent with federal laws.
Minard Run Pipeline
This proposal calls for the construction of an oil & gas pipeline in the Allegheny National Forest that would be approximately 1,400 feet in length. Due to the potential cumulative impacts that would be caused by the construction of this pipeline in association with related oil & gas development this project cannot be categorically excluded and must be detailed in an Environmental Assessment consistent with federal laws.
Thank you for this opportunity to comment. Please extend the public comment period as required by law.
Sincerely,
Jim Kleissler
Forest Watch Director
Posted by jkleissler at 04:20 PM | Comments (0)
Commenting on Special Use Permits
The Forest Service handles special use permits which involve the handling of applications to construct roads and pipelines across national forest lands (in order to access private holdings). For those who are interested I thought it might be useful to publish our comments when feasible. Sometimes our comments range from one page to 300 pages so this won't always be feasible. But if folks find this useful we'll continue to do it.
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
Posted by jkleissler at 02:38 PM | Comments (0)
October 16, 2003
Exploding Gas!
This is a very serious matter that often goes undiscussed. The idea of this kind of incident occuring near somebody's residence is appalling but not surprising. Most oil and gas accidents in the forest appear to go unreported.
The Bradford EraThursday, October 16, 2003
Officials trying to determine cause of gas explosionULYSSES (EC) - Gas company officials are still trying to determine the cause of a natural gas leak and explosion in Harrison Township Friday.
Apparently, a six-inch pipe leading from a gas well broke and the resulting explosion and fire damaged a nearby mobile home and several vehicles.
Trees along an approximately 100 yard stretch were also burned bare by the fire, which melted the siding on the home of Caramel Barker on Whitman Road.
Fire companies from Harrison Valley, Tri-town and Westfield responded to the alarm, but the fire was extinguished when the company shut off the gas flow.
Dominion, the company which owns the line, has sent a section of the pipe to a metallurgical lab for testing to try to determine what caused it to fail.
No injuries were reported.
It should be noted the Dominion has a significant presence on state forest lands in Pennsylvania.
Posted by jkleissler at 12:14 PM | Comments (0)
October 07, 2003
Oil & Gas Co. sues county for back taxes
This is unbelievable. Folks should remember this when thinking about how much extraction industries really care about local citizens. Oz Gas of Tidioute is suing Warren County, Warren County School District, and Triumph and Deerfield Townships for 3 years of back taxes based on a Pennsylvania Supreme Court ruling from last December claiming it unconstitutional for the state to tax oil and gas interests as real estate.
This shows how contradictory the oil and gas industry is: They claim they are private property owners when it comes to drilling and demand to be recognized as such, particularly on public land or small private landowners who don't want to allow surface occupancy -- but they don't want to be taxed as private property owners. Now they want to sue taxpayers for back taxes.
Does anyone have info on Oz Gas?? Contact or otherwise. If I was in Warren County, I would be outraged! I am anyway.
Ryan
Posted by Ryan at 01:00 PM | Comments (5)