May 20, 2002

Dear Secretary Oliver,

Over the past few years you have shepherded in some of the most controversial policies ever to be implemented in the Department of Conservation and Natural Resources. We are writing to ask that you put a rest to these controversial policies by immediately enacting a ban on commercial logging and oil and gas drilling in Pennsylvania's State Parks. We are submitting this request on behalf of the Allegheny Defense Project and its Supporters, Heartwood, Communities for Sustainable Forestry, Greenwatch and the Pennsylvania Environmental Network. We are submitting this letter as our public comments on the proposed 17 Pa. Code Chapter 11 regulations as requested in the Pennsylvania Bulletin.

Over the past two years, you opened one of our most precious state parks, the Ricketts Glen State Park in northeastern Pennsylvania, to large-scale "salvage" logging practices in order to profit off of the wind-blown black cherry trees. The Allegheny Defense Project (ADP) protested that logging program and received only a conclusory response from the Department dismissing the ADPÕs concerns. In fact, much of the information that the Department has distributed regarding this proposal was misleading. It was very clear that the Department prioritized short-term economic gains over the conservation of Ricketts Glen State Park. Since then the Department has notified members of the Pennsylvania Conservation Network that the logging at Ricketts Glen was seen as a "pilot" project which may in fact lead to further logging in our state parks. This concern fits closely with the fact that the logging program on Pennsylvania's state forests and state parks broke records in 2000 with 20,000 acres of our public lands being logged.

Most recently, concerns about the management of Pennsylvania's State Parks have been highlighted by the recent proposal to drill for oil and gas under numerous state parks. The Department has refused numerous requests to prepare an environmental impact statement on the effects of this proposal. The Department has also refused to provide binding documentation, such as a proposed lease agreement, that supports the Department's contentions that these areas will be protected from road construction, pipeline construction, seismic exploration, and other exploration activities. Even with the protections which the Department's publicity suggests these areas might receive, there has been no serious consideration of the likely cumulative effects of drilling sites in areas surrounding state parks. Indeed, some of these state parks have been unwisely damaged by these types of activities in the past.

There can be no doubt that the people of Pennsylvania overwhelmingly perceive their state parks as places which are deserving of the highest protections. This means that the people of Pennsylvania, who by our Constitution are the landowners of the state parks, demand an end to logging and oil and gas drilling in these areas.

Currently, the Department is reviewing the regulations which apply to the management of our state parks. The Department can back up its claims that state park areas will be protected by proposed drilling by incorporating a provision permanently protecting Pennsylvania State Parks from drilling and associated exploration activities. The Department would do well to take a step further towards meeting the public's demands that these areas receive permanent protections by adopting regulatory language immediately enacting a prohibition on these activities.

Both logging and oil and gas drilling have significant impacts on the environment. Logging fragments wildlife habitat, directly damages wildlife habitat for threatened, endangered, and rare species, causes sedimentation to run off into our watersheds, and damages biodiversity. Oil and gas drilling also seriously fragments wildlife habitat, also causes direct damage to wildlife habitat needed for threatened, endangered, and other rare species, and also causes sedimentation in our watersheds. The driving force behind both practices is short-term economic gain for extractive industries, but other industries such as tourism and recreation are harmed.

Pennsylvania's state parks comprise less than 3% of Pennsylvania's forest lands. They also serve as the jewels of Pennsylvania's vastly popular public lands system. The state parks play host to millions of visitors every year, bringing in many millions in revenue to local businesses. The regulatory framework for managing these lands should reflect their importance. We appeal to you to take these important steps today.

We ask that you re-write the regulations at 17 Pa. Code §11.211 on "Natural Resources" by adopting the following language:

§ 11.211. Natural resources.

(a) The following activities are prohibited without written permission of the Department.

...

(b) The following activities are prohibited and can not be allowed with or without the written permission of the Department.

(1) Live or dead trees or limbs shall not be cut or removed except for as provided below:

(i) Forest materials shall be left as biomass on the forest floor, lopped, scattered, and burned, if prescribed, or shall be left as species habitat in the form of downed woody debris in the project area.

(ii) If removal of forest material is necessary for ecological restoration or for other necessary circumstances, that material shall be used for recreation or maintenance projects in the same unit of State public land, such as trails, bridges, or facilities, or for restoration projects such as woody debris in streams, woody debris to provide species habitat, or for biomass to build soil in other areas of the same unit of State public land.

(iii) Any excess material not used in paragraph (ii) may only be used for public purposes, and not for private or public commercial gain. This material may be provided for personal non-commercial uses, such as firewood or other subsistence uses, or for other public noncommercial purposes. Other public purposes may include, but are not limited to, the processing of these forest materials for uses such as fuel for low-income households, or, in very limited circumstances, timber for low-income housing provided by a not for profit venture registered by the Department of Conservation and Natural Resources.

(2) Under no circumstances may any person drill or conduct drilling related exploration activities for oil and gas on or under state park lands. Exploration activities include but are not limited to the following:

(i) road construction;

(ii) pipeline construction;

(iii) seismic exploration activity;

(iv) construction or clearing for or the building or locating of compressor stations; or

(v) other exploration activities.

Thank you for this opportunity to comment on the regulations applicable to Pennsylvania's State Parks.

Sincerely,

Jim Kleissler, Forest Watch Director

Rachel Martin, Outreach Program Director

Ryan Talbott, Forest Watch Coordinator

Bill Belitskus, Communities for Sustainable Forestry

Bill Smedley, Executive Director, Greenwatch

Jim Bensman, Forest Watch Coordinator, Heartwood

Brian Laverty, President, Pennsylvania Environmental Network

Back to Press Release

HELP SUPPORT THE ALLEGHENY DEFENSE PROJECT!