March 19, 2023
Dean Ball, PE
PennDOT District 2-0
70 PennDOT Drive
Clearfield, PA 16830
Dear Mr. Ball:
Pennsylvania Farm Bureau (PFB) is pleased to offer its comments on the draft Planning and Environmental Linkages (PEL) study of the State College Area Connector (SCAC), specifically as it relates to the SCAC’s potential effects on agricultural land within the proposed study area. PFB is the Commonwealth’s largest general farm organization, representing over 30,000 members engaged in all manner of agricultural activities, including the production and processing of crops; the production and processing of animals; the production and processing of forestry products; landscaping and horticultural services; agriculture-related support services; and food manufacturing.
A reliable, efficient, and affordable transportation system is critical to Pennsylvania agriculture, and indeed to the Commonwealth’s overall economy. The SCAC has the potential to provide tremendous improvement in each of those areas for the greater State College/Centre County region. At the same time, there are several concerns we believe must be addressed to protect agricultural operations (and more specifically, prime farmland) in the area as the project progresses, while recognizing the multiple, often competing factors that must be evaluated.
Specifically in reference to the immediately preceding, PFB is concerned about how the environmental impacts identified during the study process are tabulated and weighted. During the October 2022 Open House Public Meeting on the project, PennDOT staff response was that these resources were each identified independently, and that weighting would occur during a balancing in the subsequent National Environmental Policy Act (NEPA) review. PFB’s concern is that, in observing the project maps, some areas were counted both as wetlands and as agricultural land. It is critical to know how each of those resources are weighted in such a case (especially considering the possibility of double counting). We will continue to engage with elected officials and agency staff on this point as the process moves forward.
On a related note, for PFB and its farmer members so impacted by the proposed (remaining) three routing proposals, a shift of the project off their prime farmland onto marginal land that is often wet would preserve more of their farms. PFB raised this issue at the aforementioned October 2022 meeting, asking how such a shift could occur and whether it was possible for compensating wetlands to be built elsewhere. This has been done during other highway construction projects, such as the I-99 initiative. The response we received indicated that such evaluation would happen during the subsequent NEPA review. PFB has a strong interest in participating in any such evaluation, in order to promote and expand options that protect prime farmland while mitigating impacts that must occur elsewhere.
Finally, PFB continues to have concerns about the potential use of eminent domain as part of the SCAC project. PFB supports strengthening the highway condemnation standard for land in an agricultural security area and for active farmland, as well as eliminating the condemnation exception for activities relating to existing highways.
Given the significant impact possible in the study corridor, as well as the influence of this project on similar undertakings elsewhere in Pennsylvania, PFB urges officials to focus their attention on alternatives that minimize this course of action. For example, PFB has been made aware that there are landowners proximate to the proposed project area that are interested in selling their property. Such alternatives should be considered early in the evaluation of proposed routings.
On behalf of PFB and its members, I thank you for this opportunity to provide comments on this important project. Our members will remain actively engaged in the process and continue to educate elected officials, agency personnel, other stakeholders, and the general public about the benefits of Pennsylvania agriculture and its reliance on a strong, smoothly functioning transportation network that protects prime agricultural land.
Grant R. Gulibon
Regulatory Affairs Specialist