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Factors the dGEIS should assess


July 28, 2011

The Multi Municipal Task Force (MMTF) developed a road use law and road use program (RUP) to protect towns from the financial burdens caused by damage to the roads by large-scale industrial developers. The intent of the MMTF draft Generic Environmental Impact Statement (dGEIS) is to assess the potential adverse impacts of the law, and to identify realistic and viable mitigations of the impact. The July 14 editorial incorrectly assumes that the RUP will not change the volume of truck traffic related to high-intensity industrial activities and, therefore, concludes that the dGEIS does not need to consider the impact of this traffic.

The MMTF Road Use Law will permit paving and widening of roads that would not otherwise support high-volume high weight truck traffic. These alterations will not only industrialize our rural roads but will clearly increase high-volume, high-weight truck traffic. In addition, concentration of such traffic on certain roads will exacerbate the impact of this traffic in certain areas of the town. Since this traffic volume and concentration is the result of the RUP, their impacts reasonably fall within the scope of the dGEIS.

One of the more likely industrial activities to fall within the purview of the RUP is gas drilling and its associated truck traffic. To not identify the impacts specifically related to gas drilling truck traffic is disingenuous. The impacts of gas drilling truck traffic are qualitatively and quantitatively more significant than any other high-intensity industrial activity that would likely occur in our towns. To be clear, what the dGEIS should consider are the impacts related to road use, i.e. the noise, the air pollution, the vibrations etc. of 2,000 truck trips on roads that have been altered to specifically allow this traffic. This is not an assessment of the impacts of the industrial development itself but an assessment of the impacts of the high-volume, high-weight truck traffic resulting from the RUP.

Finally, there is no acknowledgement of the effects that widening and/or paving of rural roads would have on the rural character of the community. The use of the word “upgrade” in the road use law connotes improvement but these “improvements” to roads are often the foundation for the industrialization of a rural community, a transformation with more negative connotations. Without a doubt, such changes in our roads will permanently alter the quality of life in our towns—a significant impact of the RUP.

Pa state roads need no protection.

They are little more than cart paths already. The damage is done, without gas drilling. The state needs to implement a plan to repair its infrastructure and gas company monies could really help that. Rather than telling business and industry to not use the roads, let's make them of a quality that supports commerce. Roads like that exist in Harrisburg and Philly, so we know it can be done. We are not the red headed step children, or are we?

Unfortunately....

We are the red headed step child, the rented mule, the sacrificial lamb and the scape goat all rolled into one.