Tell the U.S. Forest Service to Protect the Millstone Creek Watershed!

Send the letter below to protect the Millstone Creek and Clarion River Watershed

The Millsteck Project, located in the southern part of the Allegheny National Forest (ANF) near the Clarion River, proposes actions including over 6,700 acres of serial clear-cuts, almost 7 miles of road construction, 15 acres of stone pit expansion and new pit excavation, over 3,000 acres of herbicide application, over 3,000 acres of fencing, over 1,700 acres of prescribed burning, as well as other “treatments.” This project is part of an annual ANF projects total in the last year of over 20,000 acres of serial clear-cuts, and 10,000 acres of herbicide application, which includes Millsteck, Morrison Run, Coalbed Run, Pine Bear, De Young, and Sothwest Reservoir (see vegetative projects).
Send the letter below to protect the Millstone Creek and Clarion River Watershed

Subject: Millsteck Project Scoping Comments

Your Letter:

Robert Fallon,
USDA, Forest Service, 
Marienville Ranger District,
131 Smokey Lane, 
Marienville, PA 16239
comments-eastern-allegheny-marienville@fs.fed.us

Via Electronic Mail

Re: Millsteck Project Scoping Comments.

Dear District Ranger Fallon:
I am submitting the comments below in response to the Forest Service’s January 25, 2011 notice for the Millsteck Project, with comment due date of February 28, 2011 as noted in the scoping notice.

The Millsteck Project represents the sixth logging project this year on the Allegheny National Forest (ANF), including Southwest Reservoir, Coalbed Run, De Young, Pine Bear, and Morrison Run Projects. These projects collectively represent over 20,000 acres of serial clear-cuts, and 10,000 acres of herbicide application, in addition to on-going logging and “treatments” on other previously approved projects. The Millsteck Project calls for over 6,700 acres of serial clear-cuts, almost 7 miles of road construction, 15 acres of stone pit expansion and new pit excavation, over 3,000 acres of herbicide application, over 3,000 acres of fencing, over 1,700 acres of prescribed burning, as well as other “treatments.”

A large portion of this project occurs in Management area 2.2, Late Structural Linkages which should be managed for  “…older, late-structural forests that link relatively large areas of older forests (core areas) across the landscape....Wildlife management emphasizes species with viability concerns, remote and interior species with high sensitivity to disturbance, and protection of unique micro and macro habitats (e.g. rock/boulder outcroppings and seasonal nesting and cover habitat). This management area provides a variety of opportunities for recreation in a roaded natural setting. Most existing roads are closed in this management area, and new Forest Service roads will be limited and restricted to existing road corridors....Special emphasis should be given to identifying and implementing measures to reduce adverse impacts on the resource objectives of this management area.”1

The Millsteck Project conflicts with the management objectives of M.A. 2.2. Further, the area provides wilderness characteristics, trails, popular public scenic and recreation areas, and high-quality, cold-water streams and naturally reproducing trout streams.

The Forest Service must prepare an Environmental Impact Statement (EIS) for the Millsteck Project because the context and intensity of the proposed action meet the requirements of significance as outlined in 40 CFR 1508.27. The context of the proposed action includes the huge impact that oil and gas drilling (including Marcellus Shale gas extraction) has had, and likely will have, in the project area and on the Allegheny National Forest including the massive impacts to water quality and quantity, air quality, the impact from noise (e.g., from compressor stations, trucks, and generators), and forest fragmentation.

The intensity factors involved in the proposed Millsteck Project include the following: 
1) The unique characteristics of the area including (40 CFR 1508.27 (b) 3), Loleta Campground, Buzzard Swamp, the Proposed Clarion Wild and Scenic River Corridor, and is adjacent to the Clarion River Wilderness Area proposed in Allegheny Wild! and subsequently by the PA Wilderness Coalition. 
2) The unknown consequences of the proposed actions (40 CFR 1508.27 (b) 5). The effects of "treatments" like that proposed in the Millsteck Project have never been studied on forest mycelium on the ANF. Also the “white papers” that the Forest Service has relied on in other logging projects have out-dated or incorrect data, and the data is not NEPA compliant. 
3) The breaking up of projects in the same watershed, including Pine Bear and Millsteck (40CFR 1508.27 (b) 7).
4) The cumulative effect that the proposed action will have on the continued fragmentation of the ANF, which will certainly threaten habitat for species like the Goshawk, Cerulean Warbler, and others which need large areas of un-fragmented forested habitat. The project will also add to the cumulative impact on the 78 species with potential viability concerns on the ANF (five are threatened or endangered with two candidate species, 61 are RFSS with two candidate species) (USDA-FS 2007b). The current 2007 Forest Plan developed does not halt the decline of species viability for numerous species on the forest (40CFR 1508.27 (b) 9). 
5) For all of the reasons listed above this project is controversial (40 CFR 1508.27 (b) 4).

Further, the 2007 Forest Plan on which the Millsteck logging project is based never considered (as a significant, primary issue) the impacts of oil and gas drilling (including Marcellus Shale gas) in the development of its management areas and its vegetative management plan.  Analysis of these impacts is not reflected in the decision for the proposed actions in the project area including site-specific treatment areas (defined in the scoping notice for the Millsteck Project in Tables 1through 7, and on Maps 1 through 4). Therefore, this project cannot reflect management that is in the best interest of ecosystem health because it is not based on NEPA compliant analyses that consider the huge impact of oil and gas drilling on the Allegheny National Forest ecosystem.

The Forest Service must prepare an EIS for this project that analyzes the impacts of oil and gas drilling, including the cumulative effects on local and regional air quality in the context of climate change, and the cumulative effects of noise. Analysis for this project must not rely on analysis that is not NEPA compliant such as the white-papers that the Forest Service has been referencing for other logging projects this year (i.e., Coalbed Run, De Young, and Southwest Reservoir).

The Forest Service must prepare an EIS for this project to study its presumed need for prescribed fire as a management tool, the need to create early and late structural habitat, and to conduct an actual site-specific level of analysis that focuses on the specific conditions of treatment areas that includes data such as stand composition, species surveys in the site-specific treatment areas (e.g., entomological, and mycological surveys, and surveys for the existence of wetlands, vernal pools, forested bogs, springs, etc). In an EIS the Forest Service must develop a broad range of alternatives including an alternative that does not use even-aged management practices, expansion of stone pits, herbicide application, fencing, prescribed burning, and the construction or reconstruction of roads.

Thank you,

1 USFS ANF 2007 FEIS, at 2.39

Ranger Robert Fallon, Marienville District

USDA Forest Service, Allegheny National Forest
131 Smokey Lane
Marienville, PA 16239
US

Tell the U.S. Forest Service to Protect the Millstone Creek Watershed!

Ranger Robert Fallon, Marienville District

Marienville District Comments USFS