October 25, 2001

"The Draft Environmental Impact Statement is deficient and development of the Coal Township Site (Brush Valley) will potentially cause significant environmental harm."

This statement is from a report written by Pennsylvania Department of Environmental Protection (PA DEP) and the Pennsylvania Department of Conservation and Natural Resources (PA DCNR) and sent to officials of the Federal Bureau of Prisons in Washington. PA DEP and PA DCNR forwarded a copy of this report to the Brush Valley Preservation Association.

The Brush Valley Preservation Association (BVPA) has reported many times over the last year and a half that alternate sites should be vigorously explored for a prison complex and for governing officials to make sound land use plans. BVPA has spent considerable time researching lands in eastern Northumberland County free of past mining activity. Governor Ridge's $650 million dollar Growing Smarter environmental initiative was referenced on many occasions. PA DEP and PA DCNR have virtually the same opinion. The report states, "As written, the Draft Environmental Impact Statement (DEIS) is deficient in the evaluation of identified alternatives on previously mined lands and the document lacks any rigorous analysis of these sites. The utilization of these sites, when possible and practicable, are the goals of Pennsylvania's 21st Century Environment Commission, the Growing Smarter Initiative and PA DEP's Land Recycling Program all of which are intended to promote sound land decisions".

BVPA has since its inception stated that the destruction of the natural resources in Brush Valley is not an option, especially when a satisfactory alternate site of considerable size is available near Natalie. Also, BVPA feels that the preservation of these water resources is in the best interests of the residents living here now and for future generations. This report supports BVPA by saying, "The Coal Township Site (Brush Valley) will impact essentially undisturbed land that contains valuable water resources, Exceptional Value (EV) wetlands, and mature, diverse forested lands. Therefore at this time it appears that the development of this site will result in some level of permanent, and potentially significant adverse impacts to these natural resources. Accordingly, we believe that alternative sites should continue to be considered and evaluated."

BVPA, through several news articles, has stressed the importance of the woodlands in the valley and how rare they are considering how the land around this valley has been destroyed by past mining activity. Brush Valley is a jewel amongst this mining destruction with its large lake, sand springs and woodlands. DEP and DCNR officials seem to agree by saying, "Development of the project on the Coal Township Site has the potential to cause direct and indirect impacts on one of the largest contiguous forests in Northumberland County. Brush Valley and adjacent lands to the east are relatively undisturbed, and contain wild trout streams exhibiting outstanding water quality. This area constitutes a major conservation asset in a region that has been extensively impacted by mining. The extensive system of spring seeps, vernal pools, and wetlands provide important habitat for a diversity of species including breeding habitat."

BVPA has reported publicly that the DEIS, as published in August, is inadequate and misleading and needs to be re-done. It (DEIS) does not fully and accurately analyze how the construction project will impact the lands within the Coal Township Site and surrounding environs, now, and into the future. DEP and DCNR report, "The DEIS fails to provide an adequate analysis of the potential impacts resulting from this development and further study is required. This is particularly critical since the valley is zoned Conservation Zone that reflects the special significance of this area regarding local land use decisions."

BVPA has submitted about 200 comments to the Federal Bureau of Prisons pointing out the inadequacies of the DEIS produced in August along with the facts of the irreversible environmental damage that will be done to this valley if it is destroyed for any reason. BVPA has, since its inception, always adhered to the policy of protecting and preserving this natural valley and to find an alternate site for this prison complex. The PA DEP and PA DCNR agree, "In summary, there is the potential for significant environmental harm at the proposed preferred site in Coal Township. These concerns are associated with the proposed project as well as related development that will occur from extending existing sewage service into the valley. These impacts point to the need for a more detailed analysis of alternatives including the need to explore the possibility of other viable sites in the county".

BVPA has found more than adequate land in the Natalie area that is perfectly useable for the construction of this prison complex. This acreage doesn't have any recoverable coal under the land, has not been strip-mined or deep mined. The prison can be placed on land at Natalie and Brush Valley can be preserved for its valuable water resources and recreation possibilities for future generations.

The BVPA has in recent weeks been in close contact with the PA DEP and PA DCNR, in addition to other government agencies and officials. Along with voicing our continued concerns about the Brush Valley matter we have also provided much information to these agencies and officials. We modestly believe that our efforts, as well as the public opinion in general, have had a hand in this announcement by the state. It appears that common sense, good environmental science and the will of the people may yet decide the outcome of this issue.

At the presentation of a state grant to preserve open space in Bucks County, then Lt. Governor Schweiker, now Governor Schweiker said, "Governor Ridge and I have always been supportive of new business and economic growth. But some land is too special to lose. We don't get second chances with open space. Once developed, the land is lost forever. This is one of those areas that cried out for protection. I commend all that worked for its preservation. Our children and grandchildren will thank you. Protection of property like this and sound land-use planning are perhaps our biggest environmental challenges of the 21st century."

Governor Schweiker, you've described Brush Valley perfectly with that statement!

Joseph F. Rebar, Treasurer
Brush Valley Preservation Association