Beren Argetsinger 3774 Carpenter Rd. Burdett, NY 14818 USDA Forest Service Finger Lakes National Forest 5218 State Route 414 Hector, NY 14841 Re: Finger Lakes National Forest Oil and Gas Leasing Draft Environmental Impact Statement Dear Mr. Brewster: I am writing to express my objection to the Forest Service proposal to lease the Finger Lakes National Forest (FLNF) for oil and gas development. I am 22 years young and I have lived in Hector New York for 18 full years and then lived in Syracuse New York for 4 years. I have returned home upon completing my undergraduate degree at the College of Environmental Science and Forestry in Syracuse. Upon hearing that the FLNF was proposed for oil and gas development I was very interested. Upon reviewing the DEIS I became very concerned. Page 5-93 of the DEIS discusses some of the socioeconomic impacts that may be experienced by local communities. I quote "Successful development of natural gas resources in the two counties would ultimately expand the local tax base due as a result of increased property taxes, income from fees and permits, and shared receipts. However, the time interval between the need for funds and the availability of new project-related revenues may result in short-run cash flow problems, especially if local governments are unable to borrow funds to offset revenue shortfalls (Leistritz, 1994). A degree of uncertainty about the outcome of a proposed project may also discourage local officials from incurring new financial obligations." It is not the responsibility of local governments to borrow money to subsidize the development of mineral resources by private corporations on Federal lands. Indeed it is not the responsibility of government to subsidize private corporations period. I am conc! erned that my local community will have to go into debt to service and upkeep our road infrastructure due to heavily increased use from the development of the subsurface minerals. At least until the very minimal revenues due to local governments come through from the government through the payments to states program. This brings up another economic issue of concern. The DEIS states that private corporations will receive 87.5% of the revenues, and "government will receive the remaining 12.5%. Of that remaining 12.5% local governments receive 25%. Based on the payments to states program discussed on page 4-74 of the DEIS, the Forest Service determines "each county?s payment based on national forest acreage in the County". Based on this, because Schuyler County has two-third?s of the FLNF within its boundaries, it would receive 2/3 of the approximately 2% of the entire revenue pie, and Seneca County would receive the approximate other 1%. The 2001 Schuyler County budget shows that the County appropriated $25,299,384 to be spent in fiscal year 2001. Page 5-93 of the DEIS states that local governments would receive between $12,318.75 to $45,625 per well per year. However, because this has to be split between the Counties of Seneca and Schuyler according to the payments to states program, Schuyler County would receive about two-thirds of this-approximately $8,212.49 to 30,416.36 per well per year. According to the DEIS page 5-92, the maximum number of wells drilled in any given year is between 3 and 6. Well let?s assume that we have 6 wells producing each year at their maximum estimated production. Schuyler County would receive $182,498.18. If we get the worst-case scenario with 6 wells producing each year Schuyler County would receive $49,279.94. That is from .19% and .7% of the total appropriations in the 2001 Schuyler County budget. We don?t need and we don?t want the money that might come from developm! ent of oil and gas in the FLNF. The very minimal fiscal returns that local governments may receive from the successful development of oil and gas in the FLNF is not enough and never could be enough to recompense the effect it would have on the quality of life in our community and the undisturbed nature of the FLNF. Our local community has a vision for where it wants to see itself. We want to continue to develop within the bounds of our natural environment. We have been blessed with the spirit of the Finger Lakes, excellent soils and climatic conditions for growing grapes and other agricultural crops. Our tourism industry has recently become the leading industry in Schuyler County. The FLNF has largely contributed to this. The DEIS states that the FLNF attracts over 40,000 visitors every year and on page 5-93 it states that "However, the area?s economy is also supported by the recreation and tourism industry, which in turn depends largely on the undeveloped and natural character of the area. Additionally, ! a number of local businesses, such as the growing winery industry, depend on the scenic quality of the area to attract visitors. Although it is difficult to estimate the potential effect on tourism or other local industries that depend on visitors to the area for at least a portion of their income from a decline in tourist and seasonal residential use of the area could occur as a result of oil and gas development in the Finger Lakes National Forest." There has been over 500 oil and gas leases in the Schuyler County alone this year (Schuyler County Clerk?s Office, Watkins Glen, NY). Operations on private land tend to be of much smaller scale than those proposed on the FLNF and the individual landowners have the opportunity to negotiate with private firms for better revenue sharing arrangements than those set by law for the Federal Government. Oil and gas development on the FLNF is unnecessary and unwanted by the local communities, as has been spoken for by the towns of Hector and Lodi boards, the Counties of Schuyler and Seneca legislators, the Governor of New York, Congressmen Maurice Hinchey and Amory Houghton, and Senators Charles Schumer and Hillary Clinton. The people of New York do not want to see the second smallest national forest in the United States desecrated by oil and gas leasing and development. I am concerned that the DEIS does not properly and adequately discuss the issue of a pipeline. According to NEPA regulations, an agency must consider corresponding and cumulative actions in the EIS. The issue of a pipeline to transport gas is certainly a corresponding a cumulative action. I ask that the Forest Service provide reasonable scenarios and alternatives for the construction of a pipeline in the Final EIS. Also of concern to me is the amendment to the Land Resources Management Plan (LRMP) for the FLNF that opened the grazing lands to the possibility of oil and gas leasing. Through communications with you about this issue Mr. Brewster, I have learned that the required 15-year revision of the LRMP, as mandated by congress had to be abandoned due to lack of funding. Under this revision a public comment period is required. However, I believe you told me that in 1998 an amendment was attached to the LRMP, after funding was cut off for the full revision that opened the grazing lands to oil and gas leasing. This amendment did not provide for any public comment period. Page 3-16 of the DEIS states "The decision regarding lands available for oil and gas leasing made in the LRMP will be validated. New information or changed conditions will be incorporated and considered in this EIS. For the availability decision, the requirements as disclosed under FOOGLRA will be met. If the analysis ! indicates the need for modifying the availability decision made in the LRMP, the issued ROD will contain a Forest Plan amendment". The decision to exclude the public from the decision making process and the subsequent decision to open the grazing lands to oil and gas leasing, consequently the majority of the lands under Alternative 2, the "preferred alternative" are the grazing lands, is a violation of the democratic rights of the people of this community, state, and nation. I ask that the forest service postpone its decision on whether to lease the FLNF for oil and gas development until the LRMP has been revised and the public has had the opportunity to exercise their democratic rights. Lastly, I ask and encourage the Forest Service to take a long hard look at the facts of this case. If you do this, you will quickly come to the conclusion that the "people" have come to. The FLNF is not suitable for oil and gas leasing and development and the only reasonable alternative is Alternative 4 as listed in the DEIS. Thank you. Sincerely, Beren Argetsinger bsa