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April 4, 2013

by hand-delivery & first-class mail

Richard J. Allan, Secretary

Department of Conservation and Natural ResourcesRachel Carson State Office BuildingP.O. Box 8767

400 Market Street

Harrisburg, PA 17105-8767

Re: Gas Development in the Loyalsock State Forest

Dear Secretary Allan:

The undersigned organizations, businesses, and elected officials write on behalf of

over 100,000 Pennsylvania citizens keenly interested in the conservation andenhancement of the Commonwealths State Forest lands for future generations. We

respectfully request that the Department to Conservation of Natural Resources (DCNR)

conduct a statewide public comment period on the far-reaching decisions that the DCNR

is poised to make concerning natural gas development in the Loyalsock State Forest.

The Loyalsock State Forest covers approximately 114,000 acres in Lycoming and

Sullivan Counties the heart of the Pennsylvania Wilds. In Lycoming County, there aresome 18,870 Forest acres where, due to an unusual provision in the Commonwealths

deed, DCNR owns the surface rights even though the oil and gas rights are owned by

Anadarko Exploration and Production Company, L.P. (Anadarko) and the International

Development Corporation. Known as the Clarence Moore Lands, these lands includesome of the most important ecological and recreational resources in Pennsylvanias State

Forest system, including Rock Run, an Exceptional Value stream widely hailed as the

most beautiful in Pennsylvania; the Old Loggers Path, a 27-mile hiking trail; the DevilsElbow Natural Area; and an National Audubon Society-designated Important Bird Area.

They are cherished by our members throughout the Commonwealth.

In 2011, hikers began to encounter seismic testing crews in the Loyalsock State

Forest. Documents recently obtained from the DCNR under Pennsylvanias Right to

Know Law show that the DCNR and Anadarko are currently negotiating a surface use

management agreement that would allow Anadarko to develop a network of gas wells,compressor stations, pipelines, roads, and impoundments on the Clarence Moore lands.

We find this news alarming for three reasons.

First, if the DCNR allows Anadarko to develop these lands, their wild characterand ecological and recreational integrity will be permanently lost. Second, any surface

management agreement executed by the DCNR would violate the spirit, if not the letter,

of the 2010 Executive Order imposing a moratorium on the leasing of any further DCNR-managed lands for oil and gas development. As you know, the basis of this order was a

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2010 study by DCNR itself titled Impacts of Leasing Additional State Forest for Natural

Gas Development; it concluded that there are zero State Forest Land acres suitable for

[additional] gas leasing involving surface disturbance. Third, to the extent that the

Commonwealth has received funding for the Clarence Moore lands under the FederalLand and Waters Conservation Act, Pennsylvania could suffer significant financial

penalties if these lands are converted to gas development.

Given these facts, it is clear that gas development in the Loyalsock State Forest is

a matter of statewide public importance. Yet to date, the DCNR has failed to seek any

public input on whether development should occur, and if so, on what conditions.

Under Article I, Section 27 of the Pennsylvania Constitution, the DCNR has a

legal duty to conserve, maintain, and enhance State Forest lands for the benefit of all

Pennsylvanians, including future generations. And under the Conservation and NaturalResources Act, the DCNR may not grant a right-of-way over State Forest lands unless the

DCNR determines that granting a right-of-way would be in the public interest. We

believe that in the case of the Clarence Moore lands, it is impossible for the DCNR tomake this determination without public input. Thus, we respectfully request that the

DCNR suspend its negotiations with Anadarko and open a public comment period on

whether gas development should be allowed in the Clarence Moore lands, including at

least one public hearing.

We look forward to hearing from you and would welcome the opportunity to

discuss this issue, answer any questions or provide any additional information.

Sincerely,

Mark Szybist

Citizens for Pennsylvanias Future(PennFuture)

Robbie Cross

Responsible Drilling Alliance

Curt Ashenfelter

Keystone Trails Association

Andrea Young

Muncy Creek Watershed Association

Josh McNeilConservation Voters of Pennsylvania

Melinda Hughes-Wert

Nature Abounds

Carol Kafer

Loyalsock Creek Watershed Association

Jeff Schmidt

Sierra Club Pennsylvania Chapter

Robert E. Hughes

Eastern PA Coalition for Abandoned Mine

Reclamation

Ryan Talbott

Allegheny Defense Project

Shannon Baker

Protect Eagles Mere Alliance

Beverly BravermanMountain Watershed Association, home of

the Youghiogheny Riverkeeper

Don Robertson

Izaak Walton League of America

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Liz G. Deardorff

American Rivers, Clean WaterPennsylvania

Barbara L. Stuck

Milton Garden Club

Myron Arnowitt

Clean Water Action

SIERRA CLUB:Jack D. Miller

Otzinachson Regional Group, Sierra Club

Donald W. Miles

Lehigh Valley Group, Sierra Club

Doug HellerNEA group, Sierra Club

Gary Thornbloom

Moshannon Group , Sierra Club

Peter Wray

Allegheny Group, Sierra Club

Thomas Y. Au

Governor Pinchot Group, Sierra Club

John Childe

Pennsylvania Environmental Defense

Foundation

John Dawes

Foundation for Pennsylvanias Watersheds

Maria Payan

Peach Bottom Concerned Citizens Group

AUDUBON SOCIETY:

Philip S. Wallis

Audubon Pennsylvania

Daniel L. Alters

Lycoming Audubon Society

Stan Kotala, M.D.

Juniata Valley Audubon Society