The dialogue on the future of gas drilling in New York State utilizing hydrofracking has gone far beyond being an issue of personal beliefs, political expediency or environmental principle as scores of scientists have made expert commentary on the dSGEIS. To make it easy for all parties to access the thrust of these valuable comments Catskill Mountainkeeper has compiled the following digest of what a broad range of experts have said, so you have the information at your fingertips. We believe that you will agree that this body of scientific evidence aggregates up to one unavoidable conclusion – the dSGEIS should not go ahead as proposed and that the DEC, to meet its obligation to the people of New York, must withdraw it and at a minimum issue a revised document taking all these findings into account. We are prepared to discuss any aspect of this document with you.

 

 

 

“EPA believes that the analysis and discussion of cumulative and indirect impacts in the dSGEIS need to be significantly expanded. Even with its generic format, the dSGEIS should discuss the impacts that may result from past, present, and reasonably foreseeable future projects as well as those impacts associated with gas drilling and hydrofracturing that may occur later in time or at a distance from the immediate project site.”

 

“It is possible to generate reasonable estimates of annual and ultimate build out of wells based on development of similar resources in other shale plays in other states; such estimates should have been included in the dSGEIS. By focusing only on the impacts of single well development, the dSGEIS does not fully disclose the potential adverse environmental impacts that could result from the proposed action.”

 

“(The dSGEIS) fails to undertake any analysis whatsoever of the many other potential cumulative impacts:

- Water quality impacts due to substantial volumes of industrial wastewater that may be treated and discharged to surface waters from POTWs or disposed of on roads;

- The overall lack of sufficient industrial water treatment and disposal capacity within the state and larger region based on the significant volumes of wastewater produced at each well;

- Impacts from chemical spills based on the probability of trucking accidents, given the reasonably anticipated number of truck trips;

- The air impacts from the likely long-distance hauling of produced and flowback water;

- Groundwater contamination resulting from the potential subsurface migration of chemicals into potable aquifers from dozens, hundreds, or thousands of wells;

- Public health impacts due to exposure of cumulative volumes of radioactive material brought to the surface;

- Potential induced seismicity from injection wells needed to dispose of drilling and fracturing wastewater;

- Increases in solid waste production from contaminated drill cuttings and other solid wastes that must be disposed of in an approved facility; and

- Increases in population and induced growth related to natural gas development. Such serious omissions violate SEQRA.”

 

 

 “…a greater emphasis needs to be placed on the potential health impacts that may be associated with gas drilling and hydrofracturing……. we have concerns regarding potential impacts to human health and the environment that we believe warrant further scientific and regulatory analysis. Of particular concern to EPA are issues involving water supply, water quality, wastewater treatment operations, local and regional air quality, management of naturally occurring radioactive materials disturbed during drilling, cumulative environmental impacts, and the New York City watershed. EPA recommends that these concerns be addressed and essential environmental protection measures established prior to the completion of the SEQRA process.”

 

“The dSGEIS raises serious concerns that NORM could pose a risk to public health or the environment. However, NYSDEC released the dSGEIS without completing the NORM

evaluation and included vague and contradictory language that does not provide adequate guidance on mitigating potential adverse impacts.”

 

 

“EPA is particularly concerned about the potential risks associated with gas drilling activities in the New York City watershed and the reservoirs that collect drinking water for nine million people…To address this concern, EPA recommends a very cautious approach in all watershed areas so that NYSDEC can gain experience with, as well as ensure it has the resource capacity for regulating, high volume hydraulic fracturing activities…”

 

“If gas drilling, however, adversely impacts water quality in the watershed, the city of New York would likely be required to build a filtration treatment system at an expenditure of $10 billion in capital costs and $100 million in annual operating costs.”

 

“While protecting the New York City watershed is important because of the millions of New Yorkers who rely on this drinking water supply, we also have concerns about water quality impacts throughout the state. Just because fewer people rely on upstate water sources does not imply that these supplies are not also worthy of protection.”

 

 “The dSGEIS generally ignores the potential for serious adverse impacts to water quality as a result of surface spills…The groundwater impact analysis is inadequate and ignores documented incidents of contamination in other areas where this type of drilling is currently active and ignores the probability of subsurface migration through fractures and unplugged well bores.”

 

“Data collected on spills from the Colorado Oil and Gas Conservation Commission’s (COGCC) Colorado Oil and Gas Information Service (COGIS) revealed that over the last three years oil and gas drilling spills in Colorado resulted in nearly 1,000 accidental spills/releases and that approximately 18 percent of incidents were classified as impacting ground water and eight percent of incidents were classified as impacting surface water.”

 

“Given the large volume of heavy truck traffic required to develop the Marcellus shale and the proximity of major regional highways to all Catskill/Delaware reservoirs, it is not unreasonable to assume that at some point a chemical spill would result in direct contamination of a reservoir.”

 

“It is also reasonable to expect that some spills will go undetected due to negligence, human error, or intentional misconduct, or that even if spills are detected, circumstances will prevent full recovery of the contaminants. This is exemplified by the recent incident in Dimock, PA in which 8,000 gallons of fracture fluids were released into a stream resulting in a fish kill. The carcinogenic chemical (Halliburton LGC-35BM) is extremely soluble, so once released to the stream it could not be recovered.”

 

 

 “The dSGEIS does not provide a thorough evaluation of waste disposal issues, and instead describes existing permitting requirements. Without a thorough evaluation of waste disposal issues, including cumulative impacts and disposal capacity, NYSDEC would be allowing a significant waste-generating activity without ensuring that adequate treatment and disposal capacity exists. New facilities may need to be created to handle this waste, or upgrades to existing facilities may need to be made which will also entail environmental impacts that are not analyzed in the dSGEIS.”

 

 

“The discussion of rare, threatened or endangered species in both the GEIS and SGEIS is inadequate. A protocol for identifying the presence or potential presence of listed species in an area to be disturbed should be detailed in the SGEIS along with potential mitigation measures to be taken to minimize risk.”

 

 

In its comments on the dSGEIS, New York City said, “we strongly urge NYSDEC to withdraw this dSGEIS and conduct a new, comprehensive environmental review that is more in line with the dictates of the SEQRA process, that more adequately identifies and provides mitigation for the impacts related to hydraulic fracturing…”

 

The Steward Council of Division 169 of the Public Employees Federation, PEF/Encon representing nearly 2,000 professional, scientific and technical staff within the New York Department of Environmental Conservation has asked Gov. David Paterson to hold off on allowing natural gas drilling in the Marcellus Shale for at least another year while state and federal regulators conduct more study on the environmental impact of unconventional drilling. In a letter to the Governor they said, “Although the Marcellus Shale natural gas formation is a valuable resource, public safety and the protection of all of our natural/environmental resources demand that NYSDEC take the time to do a complete evaluation and adequate planning before allowing its use….(New York’s history) is full of examples where better analysis and fact-gathering could have avoided damages to our fisheries, air quality, agricultural, wildlife and water resources.”

 

On January 25, 2010, Mayor Bloomberg spoke out personally in his most forceful statement to date opposing natural gas drilling in the city’s upstate watershed. Bloomberg told reporters, "The consequences are so severe that it is not a risk that I think we should run. I do not think that we should allow fractured drilling anywhere near our water supply."