If you want to stop hydrofracking in New York, this is your opportunity to make a difference. Please take the time to comment on the draft Supplemental Generic Environmental Impact Statement (dSGEIS) on high volume horizontal hydraulic fracturing. Every letter helps. Comments will be accepted until December 12.
Read the dSGEIS on horizontal hydrofracking at: http://www.dec .ny.gov/energy/75370.html
Submit comments in two ways:
1. Use the DEC webform: http://www.dec.ny.gov/energy/76838.html
2. Mail hard copy: Paper submission mailed or delivered to:
Attn: dSGEIS Comments
NYS DEC
625 Broadway
Albany, NY 12233-6510
Please consider these central themes in your comments:
- dSGEIS contains no comprehensive analysis of cumulative impacts.
DEC needs to conduct full build- out modeling to understand the impact of the thousands of projected wells on our air, water, ecosystems and communities. The sole focus from DEC, at this point, has been on the impact of the individual well pad.
- dSGEIS contains no public health risk assessments. DEC must project the number of illnesses and deaths anticipated by drilling activity and commit to studying the health effects from drilling's unavoidable exposure pathways.
- The ban on fracking in NYC and Syracuse watersheds is a declaration of unacceptable risk. The dSGEIS provides no clear scientific rationale why one unfiltered water source deserves more protection than another. Protection of water resources should be held to one consistent standard.
- DEC proposes to permit drilling before regulations are in place. SEQRA was designed to identify and mitigate environmental impact- not serve as a regulatory program. Drilling without regulations in place will insulate the DEC from lawsuits if they choose to make exceptions or bend the rules at the drill site.
- DEC learned little from PA. DEC did not report on the number of violations and contamination instances- look at air quality data, forest fragmentation studies or public health issues in the PA study, which amount to five scant pages (section 10).
- DEC does not address staffing or resources. The best regulations in the world are worth nothing if they can't be enforced.
- DEC still refuses to study impacts of pipelines and compressor stations. Natural gas development cannot happen without the construction of a supporting delivery and pressurization infrastructure that, in some cases, has worse long-term air emissions than the gas wells themselves.
-DEC will not make new regulations consistent for all drilling. Vertical oil and gas wells using less than 300,000 gallons of water will remain grand-fathered under outdated permitting conditions and will be allowed to use inferior casing standards, open waste pits, and a regulatory framework that dates back to the 1970s. Demand that all oil and gas activity should fall under one set of rules.
- Disposal of fracking waste in municipal waste water treatment facilities should be banned. The dSGEIS fails to illustrate the sheer lack of capacity NYS has for the disposal of the anticipated millions of gallons of drilling waste. Instead of banning disposal in our already crumbling municipal infrastructure, the DEC sets parameters that in most situations cannot be met by the plant. Setting up the possibility of disposal when the risks of failure and lack of enforcement are so great is unacceptable.
- Local ordinances and land-use laws should come before drilling. The dSGEIS can clarify once and for all that municipalities have the right to enforce land-use ordinances, such as zoning, over oil and gas interests. Instead, the DEC says that it will require that a gas well certify it complies with local land-use laws, but will issue a drilling permit if a conflict cannot be resolved.
- Hazardous chemicals in fracking solutions should be banned. DEC has the power to prohibit dangerous chemicals from the drilling process but has yet to do so. DEC should also revisit its hazardous waste regulations. Current regulations state that no matter what the chemical make-up, drilling wastes can never be considered hazardous. This loophole should be closed.
For more analysis of the dSGEIS, please visit: http://tinyurl.com/2011SGEISFlaws.