Honorable Andrew M. Cuomo
Governor of New York
The State Capitol
Albany, NY 12224

Dear Governor Cuomo:

I write to request that you immediately require an environmental impact statement pursuant to the New York State Environmental Quality Review Act (SEQR) regarding the proposed use of Liquid Petroleum Gas (LPG) to hydraulically fracture Marcellus Shale in New York.

SEQR Review Requirements

New York's SEQR requires that:

"All agencies (or applicants as hereinafter provided) shall prepare, or cause to be prepared by contract or otherwise an environmental impact statement on any action (emphasis added) they propose or approve which may have a significant effect on the environment (emphasis added)." (Section 8-0109 of the New York Code of Rules and Regulations).

Proposed LPG Hydraulic Fracturing

A proposal was recently announced to lease approximately 135,000 acres in Tioga County for natural gas extraction utilizing horizontal drilling and high-volume hydraulic fracturing using LPG. That proposal is reportedly intended to skirt New York's moratorium on horizontal hydrofracturing and could result in the establishment of more than 3,300 shale gas wells.

Hydraulically fracturing those wells could require the use of billions of gallons of LPG and could cause irreparable harm to water, air and land resources as well as to the health of local residents. LPG is highly toxic as well as flammable and poses extraordinary explosion hazards.

Environmental Impact of LPG Hydraulic Fracturing Not Assessed by NYS

LPG hydraulic fracturing has neither been addressed by a) New York's 1992 Generic Environmental Impact Statement (GEIS) on Oil, Gas and Solution Mining nor b) the 2011 Revised Draft Supplemental Generic Environmental Impact Statement On The Oil, Gas and Solution Mining Regulatory Program (RD SGEIS) nor c) any other SEQR EIS review whatsoever.

As a result, New York has totally failed to assess or mitigate the potentially significant impact on the environment associated with using LPG to extract natural gas from New York's tight shale formations.

Request for Action

I request that horizontal LPG fracturing be subject to the current moratorium on horizontal high-volume hydraulic fracturing in Marcellus Shale. I also request that the RD SGEIS be immediately withdrawn and its scope expanded to address this proposed practice. Until that request is fulfilled, I request that all horizontal LPG hydraulic fracturing well permit applications must require individual EIS review.

Thank you for your attention. I look forward to your prompt reply.

Very truly yours,

Walter Hang