The US Forest Service is calling for comments on a draft Supplementary Environmental Impact Statement (dSEIS) designed to address the problem of oil and gas drilling on the Allegheny NF.

The full text of the dSEIS is available on the US Forest Service website. The topics in the dSEIS include such things as Soil Erosion, Water Quality, Forest Vegetation, Animal Habitat and Visual Resources.

Comments must be submitted BY 5 PM, WEDNESDAY, OCTOBER 28 and should be sent to:

Lois DeMarco
Allegheny National Forest
4 Farm Colony Drive
Warren, PA 16365
OR   comments-eastern-allegheny at fs dot fed dot us

The following Talking Points are based on material kindly provided by Ryan Talbott of the Allegheny Defense Project:

1. Standards and guidelines are too weakThe Forest Service is required to develop and enforce specific regulations (i.e., “standards and guidelines”) for oil and gas development on the Allegheny NF. Unfortunately, many of the standards and guidelines the Forest Service has proposed are not legally enforceable because they contain language such as “may” or “should” rather than “must” or “shall.” Without specific mandatory standards and guidelines to regulate the oil and gas industry, the Forest Service cannot fulfill its legal obligation to ensure that the surface resources of Pennsylvania’s only national forest are protected.
2. The dEIS relies on outdated information to make assumptions about future development.The Forest Service is relying on road figures from 2003 and oil and gas well figures from 2005. These figures do not account for thousands of new oil and gas wells and at least 800 miles of new road construction. As a result, the public has incomplete information and cannot possibly provide accurate and informed comments. The Forest Service must disclose to the public the most recent data it has for the number of current oil and gas wells and mileage of roads so that the public has a full appreciation of the current surface impacts on the Allegheny National Forest.
3. The impact on air quality needs to be re-visited in light of recent EPA regulations.The EPA recently announced the reversal of a Bush administration policy that limited regulation of pollution emissions from oil and gas drilling operations. Now, EPA plans to aggregate emissions from oil and gas development sites. Aggregation provides an opportunity to determine whether individually small sources of air pollution should be aggregated together as larger sources. In other words, companies that own and operate large oil and gas developments with hundreds of well sites, storage tanks and other equipment could be grouped together as a single large source and regulated under the EPA’s Prevention of Significant Deterioration (PSD) and Title V programs of the federal Clean Air Act. This is new information that requires the Forest Service to revisit its air quality analysis in the dSEIS.
4. Range of Alternative actions is inadequate.The Forest Service has not developed a broad range of alternatives. For instance, none of the alternatives actually maintains species viability at current levels. The Forest Service is not considering an alternative that would offset the impacts of oil and gas drilling by reducing other Forest Service activities elsewhere. Nor is the Forest Service considering a comprehensive restoration program to address the decades of virtually unregulated oil and gas development. The Forest Service must consider at least one alternative that seeks to offset the impacts of oil and gas development, protects and restores watersheds that have been severely altered by oil and gas development and maintains species viability.
5. Deep drilling for Marcellus Shale gas is neglected.The Forest Service eliminated Marcellus Shale gas drilling as a significant issue to be addressed in the dSEIS. The Forest Service claims that it does not have enough information about Marcellus Shale and is uncertain that this kind of drilling, which requires much larger roads, well sites and water withdrawals, will occur on the Allegheny. However, a recent article in a Cameron County newspaper stated that “managers of the Allegheny National Forest are preparing for a flurry of activity by energy companies seeking to drill in the forest for natural gas deposits found deep underground in the Marcellus shale.”