August 23, 2024
Julia Moore
Senior Environmental Specialist
Federal Highway Administration, Pennsylvania Division
30 North Third Street, Suite 700
Harrisburg, PA 17101
Dear Ms. Moore:
Pennsylvania Farm Bureau (PFB) is pleased to offer its comments on the Notice of Intent (NOI) (Docket #FHWA-2024-0056) regarding the Environmental Impact Statement (EIS) that will be prepared to study potential improvements to U. S. Route 322 (also known as the State College Area Connector (SCAC) Project) from Potters Mills, PA to Boalsburg, PA.
PFB is the Commonwealth’s largest general farm organization, representing over 27,000 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, but 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. Pennsylvania Department of Transportation (PennDOT) staff have previously indicated 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 maps of the project have previously identified some areas as both wetlands and 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).
On a related note, for PFB and its farmer members so impacted by the proposed (remaining) routing proposals, a shift of the project off their prime farmland onto marginal land that is often wet would preserve more of their farms. We believe that there are strategies available that can accomplish this goal while protecting important environmental features in the project area. PFB has previously raised this issue with PennDOT, asking how such a shift could occur and whether it was possible for compensating wetlands to be built elsewhere, as has been done with similar highway projects, most notably the development of the I-99 corridor in central Pennsylvania. 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 in an alternative fashion.
PFB also 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, perhaps by giving serious consideration to utilizing land parcels currently for sale as part of the project routing. We also believe that agricultural property owners affected by the SCAC should receive compensation not only for the loss of their land, but also to mitigate the entire cost of adjusting their operations as a result of that loss.
Finally, PFB recommends that attention be given to two other agriculture-specific issues that are likely to arise from any routing choice for the SCAC. The first is the issue of access to “stranded fields” that may be severed from direct attachment to other land owned by a given agricultural operator, while the other is the noise impact to animal agriculture operations (given the sensitivity of livestock to the loud and persistent noise of the type associated with a busy highway). Again, PFB stands ready to work with all parties to provide guidance and insight on alternatives that can minimize each of these concerns.
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 to the greatest possible extent.
Sincerely,
Grant R. Gulibon, Regulatory Affairs Specialist