DCNR has invited public comment (loyalsock@pa.gov)? Malarky…RA-loyalsock@pa.gov?

Acting Sec Ferretti stated in the Op-Ed linked that: “At Gov. Tom Corbett’s direction, DCNR has directly engaged…inviting public comment directly (loyalsock@pa.gov).”



I forwarded the following comment to the email address given. It came back undeliverable, so I sent it directly to Sec Allan. No reply from either:

From: Steve Todd
To: loyalsock@pa.gov
Subject: Loyalsock Drilling
Date: Sat, 4 May 2013 10:54:30 +0000

Thank you for requesting our (the owners’) input, Mr Secretary, in your LTE in PennLive today. I submit the following:

I attended and blogged two Senate hearings this week. Check out my takeaway.



Of particular note – and central to the entire decision to allow Anandarko to drill these pristine public lands – are statements by PA Rep Greg Vitali (D- Delaware) and by PennFuture’s Mark Szybist below. Their statements, conflict directly with DCNR spokeswoman Chris Novak’s statements on this issue, who told NPR’s StateImpact: “In the circumstance where the commonwealth does not own the mineral (subsurface) rights, we are required by law, by some legal decisions, to provide reasonable access to the owner, or to the person who leases those rights.” Vitali and Szybist seem to be backed up here: “the right of the mineral rights owner to access oil and gas from the surface was terminated after 50 years — in 1983.

”http://www.bayjournal.com/article/conservationists_fight_to_save_one_of_pas_gem_streams1 and on DCNR’s website –http://www.dcnr.state.pa.us/cs/groups/public/documents/document/dcnr_20026829.pdf

Here’s how We The People of PA (of which Allen is ONLY one) collectively feel about O&G activities:


Citing the April 19 MCall/Muhlenberg College poll commissioned by the Allentown Morning Call:

42% said hydraulic fracturing poses major or moderate environmental risks; 9% said it posed no risk at all.

52% said fracking is harmful to the water supply; 20% said it is not and 28% are not sure.

71% said the state should enact stronger regulations on fracking; 13% said it should not, and 16% were not sure.

Too many of us have legitimate concerns, which are not being addressed. According to MarcellusGas.Org Permit Information Updated April 13th, 2013, 12,082 Unconventional wells are permitted in PA. Given those fact, the currently permitted capacity is more than a fair and reasonable enough exposure to ask us to risk. Why also give up our State Forest? When is our sacrifice enough for The Political Class?
Steve Todd, PE, LEED AP
Executive Director/Principal, Todd Engineering, LLC
(full contact followed)
From: postmaster@mail.hotmail.com
To: me
Date: Sat, 4 May 2013 03:54:38 -0700
Subject: Delivery Status Notification (Failure)

This is an automatically generated Delivery Status Notification.

Delivery to the following recipients failed.


Steve Todd 5/04/13
To: rjallan@pa.gov

This didn’t got through to the email you gave on PennLive.

Steve Todd, PE, LEED AP
Executive Director/Principal, Todd Engineering, LLC


Today, I received the following. I don’t know which comments it is in response to, as I have sent several attempts. But it appears, you have to put an ‘RA-‘ in front of ‘loyalsock@pa.gov’, but I don’t know. There was only this:

> From: RA-loyalsock@pa.gov
> To: Me
> Date: Tue, 13 Aug 2013 12:31:00 -0400
> Subject: Loyalsock Comments Received
> Thank you for submitting comments related to the possible gas development in the Loyalsock State Forest.
> DCNR Bureau of Forestry


About steventodd

Both parties are broken by big money...what to do? I'm a dad, husband, son, taxpayer, voter, civil engineer, reporter, blogger, rabble-rouser and honest guy.
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One Response to DCNR has invited public comment (loyalsock@pa.gov)? Malarky…RA-loyalsock@pa.gov?

  1. Steve Szoke says:

    Public Hearing with Representative Rick Marabito on the Loyalsock State Forest

    Loyalsock Creek Watershed Association
    Steve Szoke, Vice President

    “Anadarko’s plan if enacted would destroy the wild character of the state forest” – Rep Greg Vitali, Democratic Chairman of the House Environmental Resources and Energy Committee – Press Conference on 4/23.

    The Loyalsock Creek Watershed Association is deeply concerned about the possible industrial development of the Clarence Moore tracts in the Loyalsock State Forest. An extremely important portion of the Loyalsock Creek Watershed is in this pristine forest.

    The current threat of the development related to the Marcellus gas extraction is the impact on the Commonwealth’s forest and aquatic resources from well pad and right of way development, migrating noise from compressor stations, improper erosion and sedimentation control, habitat fragmentation, increased impervious surfaces, water withdrawals, and the possibility of ground water contamination.

    The Loyalsock, its tributary streams, and wetlands are classified as Exceptional Value (EV) by the Department of Environmental Protection.

    The Importance of Wetlands in the Ecosystem

    Many watersheds have a beginning source as wetlands. The U.S. Environmental Protection Agency defines wetlands as “lands where saturation with water is the dominant factor determining the nature of soil development and the types of plant and animal communities living in the soil and on its surface.” Beyond definitions, wetlands are essential ecological features in any landscape. They are primary habitat for hundreds of species of waterfowl as well as many other birds, fish, mammals and insects.

    Wetlands naturally filter and recharge the water that later comes out of our faucets downstream. They act like giant sponges, slowing the flow of surface water and reducing the impact of flooding. Wetlands also prevent soil erosion, and they buffer water bodies from potentially damaging land use activities such as industrial development.

    So you can see how important wetlands are to the watershed.

    The single largest wetland in the entire Clarence Moore tracts is surrounded by proposed industrial development which would include two impervious well pads (like Walmart parking lots) directly uphill with connecting pipelines and access roads, a compressor station downstream where Old Logger’s path crosses Hillsgrove Road, and a large water impoundment west of this wetland. This wetland is the headwaters of the west branch of Mill Creek.

    Another wetland at the head of the middle branch of Mill Creek also has two proposed well pads, pipelines and access roads above it.

    And the wetland near the Devils Elbow Natural Area at the headwaters of Rock Run hlso has two well pads, access roads and pipelines proposed.

    Exceptional Value Streams

    All three branches of Mill Creek were assessed for water quality, macroinvertibrates and fish population in 2011 and are now listed as protected wild trout waters. We helped the Fish and Boat Commission stock the main stem of Mill Creek with brook trout on April 25.

    Wallis Run and Plunketts Creek are also protected wild trout waters. Noon Branch, a Plunketts Creek tributary, is a Class A “best of the best” wild trout stream.

    And now we get to “the best of the best of the best”.

    A special classification by the Fish and Boat Commission is a “Wilderness Wild Trout Stream”. Wilderness trout stream management is based upon the provision of a wild trout fishing experience in a remote, natural and unspoiled environment where man’s disruptive activities are minimized. Established in 1969, this option was designed to protect and promote native (brook trout) fisheries and the ecological requirements necessary for natural reproduction of trout and wilderness aesthetics. The superior quality of these watersheds is considered an important part of the overall angling experience on wilderness trout streams. Engle Run and Wolf Run are two of less than 100 in the entire state with this classification. Their headwaters start in the Clarence Moore tracts and are tributaries to Plunkett’s Creek.

    In the headwaters of Wallis Run and Plunketts Creek, there are 4 proposed well pads, pipelines and access roads. The proposed main access road is Cascade Road which runs through those drainages. Heavy truck traffic into the deep woods also accelerates road and bridge damage and disturbs storm water drainage channels that would result in increased erosion and sediment deposition and capacity overload into local streams.

    The other watersheds in these Clarence Moore tracts are Rock Run and Pleasant Stream. When we stocked these streams with brook and brown trout on April 18 there were approximately 75 fishermen on Rock Run and 50 on Pleasant Stream. The upper reaches of both streams have native brook and brown trout. Hawk Run, a major tributary to Rock Run, is a Class A wild trout stream and two other tributaries are listed as natural reproducing wild trout waters. Other tributaries to Rock Run are scheduled to be assessed in 2013. Pleasant Stream has 16 tributaries listed as natural reproducing wild trout waters. Potash Hollow Run and Pleasant Stream above North Pleasant Stream are both Class A wild trout streams. There are well pads, pipelines, access roads, compressor stations and water impoundments proposed in these two sub-watersheds.

    It would be a tragedy if even one of these streams would be negatively impacted by gas development.

    And Now like “The Canary in the Mine Shaft” – The Native Brook Trout

    Strong wild brook trout populations demonstrate that a coldwater stream ecosystem is healthy and water quality is excellent. Brook trout, our official state fish, are a prized sport fish and provide anglers with many hours of recreational opportunities.

    Canopy cover is critically important in maintaining shade for stream temperature control and in providing woody debris to the stream. Water temperature is an important factor in fish growth and reproductive success. Sedimentation build up from poorly designed or maintained roads can affect feeding and reproduction for brook trout and also negatively impacts aquatic macroinvertebrates, which are their main food source and destroys good spawning habitat. Additionally, brook trout are sight feeders so an increase in turbidity from sedimentation can make feeding more difficult. Well vegetated and stable stream banks are important in the formation and protection of in-stream conditions found along undercut banks and under logs or large rock ledges used for resting, feeding, escape cover and over wintering habitat.

    Industrial development fragments the forested landscape. Fragmentation equals forest edge effects, light penetration, temperature increase, species shifts, invasive species and more erosion and sedimentation. Use of limestone for pads and access roads would also foster growth of invasive species.

    Nothing should be allowed that would jeopardize this species. We have to protect these brook trout.

    State Agencies

    Several regulatory authorities including the Department of Environmental Protection (DEP), Pennsylvania Fish and Boat Commission (PFBC), and Department of Conservation and Natural Resources (DCNR) determine the special protection designations of waters in Pennsylvania. Wild trout streams are also protected, at a minimum, under the Cold Water Fishes (CWF) designation in 25 Pa. Code Chapter 93 because of their ability to support or maintain a population of wild trout.

    Special Places as designated by official classifications such as Exceptional Value or High Quality Waters or High Conservation Value Forests or Scenic Viewsheds or Wild Areas or Natural Areas are endangered by pipeline crossings and drill pads or even the migrating noise from compressor stations.

    The Loyalsock Creek Watershed Association believes these agencies and the developers must be mandated to use peer reviewed research that clearly supports the mission that gas development will not impair our high quality streams.

    The Loyalsock Creek Watershed has endured the development by man, the stripping of the forests by loggers and the poisoning of the waters from the coal mines and it will survive the next onslaught of industrial development. But at what cost? At what degradation!


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