Big Mill Creek Remediation Project Comments Submitted October 17, 2009


17 October 2009

Robert T. Fallon
Marienville District Ranger
131 Smokey Lane
Marienville, PA 16239
rfallon@fs.fed.us

Via Electronic Mail

Re: Big Mill Creek Remediation Project

Dear District Ranger Fallon:

Although ADP is not opposed to the Big Mill Creek Remediation Project, the proposed project should be subject to an Environmental Analysis (EA) and subsequent Environmental Impact Statement (EIS) given that the USFS has not determined through analysis why Big Mill Creek, Cherry Run, and Ellithorpe Run have become acidified. The fact that the lower reaches of Big Mill Creek become acidified “…during high stream flows with the most severe conditions occurring in late winter and early spring….” suggests that runoff plays a role in the acidification of the watershed. Further, the USFS has not determined through analysis the health of the riparian corridors on these watersheds. Without an EA and subsequent EIS the USFS will not be able to determine if riparian corridor restoration is also needed to remediate the acidification of Big Mill Creek. An EA and subsequent EIS will help the USFS determine if current riparian corridor management practices in the ANF are sufficient to protect the forest’s aquatic resources.

It is highly likely that the unregulated, unanalyzed oil and gas development on the ANF, which has resulted in extensive environmental degradation, plays a role in the acidification of Big Mill Creek, Cherry Run, and Ellithorpe Run. Currently, the cumulative impacts of oil and gas development on the forest are unknown. The lack of data on cumulative impacts of oil and gas development necessitates at least an EA in the Big Mill Creek watershed.

Thank you,
Cathy Pedler
Allegheny Defense Project, Forest Watch
cpedler@alleghenydefense.org
(814) 454-7523