On December 16, 2010 a Forest Watch Team traveled down FR 267 in the Allegheny National Forest to explore the proposed Morrison Run Logging Project.
We learned about the project from a public notice the Forest Service posted in the Kane Republican, and from information packets about the project that the Forest Service mails to "interested parties" such as ADP (to become an interested party contact email@example.com). After the public notice is posted on Forest Service projects, the public has 30 days to provide comment on the proposed project to the agency. In this case the public had 30 days for the whole project, and 60 days to comment on proposed clearcut areas within the project that are over 40 acres each. Comments submitted by ADP are available here. A short version of our comments are available here in a letter that you can send to the Forest Service to show your support of the issues we have identified.
On our field survey of the project area, we stopped first at the Bradford District Ranger Station to pick up a CD of data, which the USFS had referred to in previous logging project analysis as "white papers" on the Supplemental Environmental Impact Statement (SEIS) and the Transition Environmental Impact Statement (TEIS), both currently on hold. The information was referenced and "tiered-to" in the Forest Service analysis, but was effectively unavailable to the general public, specifically because the SEIS and TEIS are truncated public processes. The information was never provided to the public in a completed NEPA process (or even posted on their website).
While at the Ranger Station, we reiterated a request we had previously made to access the stands in the Morrison Run Project area where the Forest Service proposed treatments (e.g., clear-cuts, and herbicide applications). We were denied, even after offering to apply for a special-use permit to access these areas, which are on gated roads. We also registered our concern about the fact that the Forest Service was effectively blocking access to the proposed treatment areas by scoping the project in December when there was likely to be, and in fact was, deep snow and frigid temperatures. To view all of the treatment areas on foot, as we were required, would have necessitated 20 miles of hiking.
We pushed forward to survey the project regardless of these set-backs, beginning our tour on FR 267. We were familiar with the area generally because ADP proposed the area as the Chappel Fork Wilderness in Allegheny Wild!, and the Pennsylvania Wilderness Coalition has subsequently proposed the area as the Morrison Run Wilderness.
However, the scoping documents provided no detail on the areas identified for "treatments" (e.g., clearcutting and herbicide applications) other than location, size, and the type of treatment or action proposed. There were no details provided on stand composition, wetlands, or other habitat characteristics.
The image above (right click for larger view) shows the Morrison Run Project area outlined in red. The Chappel Fork proposed wilderness is in green outline. The PA Wilderness Coalition proposal is same as Chappel Fork except smaller, with the blue line running north-south through the area showing its eastern most boundary. The red arrows show proposed road construction/reconstruction, The brown rectangles are areas with clearcuts over 40 acres (as defined by the Forest Service). The yellow line is the North Country Scenic Trail.
In the areas we had access to by car and by short hikes down gated roads, we found significant oil and gas activity, roads, tank batteries, equipment, generators, stone pits, truck traffic, etc.
The Forest Service never considered the impact of all of this activity as a significant issue when the USFS developed the vegetative management plan (i.e., the 2007 Forest Plan) that allows the USFS to propose logging plans like the Morrison Run Project. When ADP appealed the 2007 Forest Plan because of this failure, the Forest Service Chief directed ANF staff to prepare the SEIS for Oil and Gas (see reference above). However, the SEIS (now on hold) is simply an amended analysis that was not part of the planning process as a whole. Because the vegetative management aspects of the 2007 FEIS did not include oil and gas drilling as a significant, primary issue during development of the plan, the vegetative aspects of the plan are invalid. Please see the image below to aid the conceptualization of this issue.
The results of this purposeful lack of stewardship are already in evidence in the Morrison Run Project area where previous clearcuts are pocked by pumpjacks (see image below).
The map section below shows the existing condition of the area as of 2009 with black dots representing existing wells, and purple outlined areas and yellow dots representing areas that are predicted to be in "full-mine-out" in the reasonably foreseeable future.
Unfortunately the Forest Service will continue to pursue aggressive logging projects that further fragment the forest, poison and deplete the ecosystem while ignoring whole Kingdoms and Phyla (e.g., Fungi and Arthropoda) of organisms, which they apparently do not feel are necessary to achieve their desire to grow and harvest high value timber species at the expense of all other forms of life in the Allegheny.
For the Morrison Run Logging Project the next step will be when the Forest Service releases an Environmental Analysis (EA) for the project. At that time the public will again be given notice of the EA and will again have 30 days to respond with comments. Stay tuned.