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Urgent Action Alert/New York's Shale Fracking Prohibition Challenged by Gelled Propane Fracking Permit Applications For Tioga County
PLEASE BECOME A SIGNATORY TO AN URGENT NEW COALITION LETTER. It requests that Governor Cuomo immediately prohibit the use of "gelled propane," Liquified Petroleum Gas (LPG) and all other "'environmentally friendly' or 'green' alternatives" shale fracking methods excluded from New York's definition of "high-volume hydraulic fracturing:"
Please call Governor Cuomo at 518 474 8390 during business hours. Respectfully request that Governor Cuomo immediately prohibit the use of "gelled propane," Liquified Petroleum Gas (LPG) and all other "'environmentally friendly' or 'green' alternatives" shale fracking methods excluded from New York's definition of "high-volume hydraulic fracturing."
Greetings,
I write to alert you that New York's landmark shale fracking prohibition is already facing its first major challenge. There undoubtedly will be many more attacks to come.
Ever since December 17, 2014, I have repeatedly warned that the scope of New York's shale fracking prohibition would not be known until a Final SGEIS (Supplemental Generic Environmental Impact Statement) Findings Statement was issued. I underscored that "the devil will be in the details."
I also declared that pro-frackers in our state would never give up. I also decried one-word environmental solutions that can mean almost anything in politics.
In a nutshell, that is the overall scenario which we are now confronted with.
First and foremost, New York's much ballyhooed shale fracking "BAN" has a big loophole that pro-frackers are already seeking to exploit.
Unless this loophole is closed, shale fracking using gelled propane, or LPG, could be permitted because New York's definition of high-volume hydraulic fracturing is limited to "300,000 gallons or more of water."
In addition, believe it or not, DEC actually considers flammable and explosive gelled propane, or LPG, to be "'environmentally friendly' or 'green' alternatives..." to shale fracking using water.
Against this background, please sign a new coalition letter which requests that Governor Cuomo immediately prohibit the use of "gelled propane," Liquified Petroleum Gas and all other "'environmentally friendly' or 'green' alternatives" shale fracking methods excluded from New York's definition of "high-volume hydraulic fracturing."
Gelled Propane Fracking Proposed in Tioga County
A week ago (7/9/15), the Ithaca Journal ran a huge front-page headline, "Propane Fracking in Tioga County." The story was about two well permit applications to frack Marcellus and Utica shale in Barton, NY using "gelled propane" (aka LPG) instead of water.
This piece ran statewide and nationwide. See below and: http://www.toxicstargeting.com/MS/news/2015-07-13/front-page/IJ/fracking-propane-proposed-tioga-county-ny
Proponents of the propane fracking project argue that only "high-volume hydraulic fracturing" using water has been prohibited in New York. Since propane is not water, they believe it is not prohibited by the Final SGEIS Findings Statement.
No final decision has yet been made to grant these permits, but it is imperative that we take immediate action.
So-Called "'Environmentally Friendly' or 'Green' Alternatives" Shale Fracking Methods
Propane fracking was addressed in the Final SGEIS under Section 9.3 'Green (emphasis added)' or Non-Chemical Fracturing Technologies and Additives." DEC reports that LPG "consisting primarily of propane" has been used as a "hydraulic fracking fluid."
LPG is often used in arid areas where water is scarce. It is highly flammable as well as explosive and does not eliminate the public health and environmental hazards of shale fracking using water.
See Final SGEIS LPG summary: http://www.toxicstargeting.com/MS/2015-07-16/FSGEIS/Chapter-9/LPG
Other "'environmentally friendly' or 'green' alternatives" shale fracking methods identified in the Final SGEIS include liquid carbon dioxide and nitrogen-based foam. These hydraulic fluids involve gases that are compressed until they become liquids.
DEC concluded, "It is important to note that use of 'environmentally friendly' or 'green' alternatives may reduce, but not entirely eliminate, adverse environmental impacts."
New York's Hydraulic Fracturing Prohibition
The "environmentally-friendly chemical approach" was specifically rejected when the Final SGEIS Findings Statement was issued:
"Based on unavoidable adverse environmental impacts and uncertainty regarding the science surrounding high-volume hydraulic fracturing and its potential impacts to public health and the environment, the Department finds that the best course of action is to select the No Action alternative. Selection of the No Action alternative means that the Department will not establish a high-volume hydraulic fracturing permitting program; that no individual or site-specific permit applications for wells using high-volume hydraulic fracturing will be processed; and that high-volume hydraulic fracturing will be prohibited in New York State (emphasis added).
The Department rejects the other available alternatives (the 'phased-permitting approach,' the 'environmentally-friendly chemical approach,' and the 'Special Places' alternative) because they all fail to limit unavoidable adverse environmental impacts and fail to address the risks and uncertainties of high-volume hydraulic fracturing (emphasis added)."
DEC's Definition of "High-Volume Hydraulic Fracturing" Limited to "300,000 Gallons or More of Water"
Nevertheless, gelled propane, LPG and other "'environmentally friendly' or 'green' alternatives" shale fracking methods are excluded from DEC's definition of high-volume hydraulic fracturing. That definition is limited to 300,000 gallons or more of water:
"1 High-volume hydraulic fracturing is defined as the stimulation of a well using 300,000 or more gallons of water (emphasis added) as the base fluid for hydraulic fracturing for all stages in a well completion, regardless of whether the well is vertical or directional, including horizontal. The 300,000-gallon threshold is the sum of all water (emphasis added), fresh and recycled, used for all stages in a well completion. Well stimulation requiring less than 300,000 gallons of water (emphasis added) as the base fluid for hydraulic fracturing for all stages in a well completion is not considered high-volume, and will continue to be reviewed and permitted pursuant to the 1992 GEIS, and 1992 and 1993 Findings Statements."
Conclusion
Gelled propane, LPG and a wide variety of "'environmentally friendly' or 'green' alternatives" fracking methods have not been meaningfully investigated as part of either the SGEIS or the GEIS proceedings.
Unless and until gelled propane, LPG and all other non-water "'environmentally friendly' or 'green' alternatives" fracking methods are the subject of an environmental impact analysis conducted pursuant to the State Environmental Quality Review Act, their use must not be permitted in New York for the same reasons that high-volume hydraulic fracturing using water has been prohibited statewide.
Please sign the coalition letter that aims to achieve this critically important goal:
http://www.toxicstargeting.com/MarcellusShale//letters/2015/7/16/coalition-letter-cuomo-prohibit-green-alternative-shale-fracking-methods
Please call Governor Cuomo at 518 474 8390 during business hours. Respectfully request that Governor Cuomo immediately prohibit the use of "gelled propane," Liquified Petroleum Gas (LPG) and all other "'environmentally friendly' or 'green' alternatives" shale fracking methods excluded from New York's definition of "high-volume hydraulic fracturing."
Thanks for your on-going assistance.
Very best regards,
Walter
Thank you for contributing to Toxics Targeting's on-going research, advocacy and organizing campaign to keep shale fracking out of New York: http://toxicstargeting.com/MarcellusShale/donate
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DEC’s Unplugged Abandoned Wells Database & Overview Map
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