Honorable Alexander Grannis
Commissioner
New York State Department of Environmental Conservation
625 Broadway
Albany, New York 12233-0001
Dear Commissioner Grannis:
I write respectfully to request you to withdraw the Marcellus Shale draft Supplemental Generic Environmental Impact Statement due to its unacceptable shortcomings.
While I appreciate all the hard work you and your colleagues have put into this effort, the draft SGEIS is fatally flawed and has been the subject of extreme criticism by the U. S. Environmental Protection Agency Region 2, New York City drinking water protection authorities, dozens of local government agencies, hundreds of local, state and national environmental groups and nearly 10,000 concerned citizens who signed a coalition letter spelling out its problems.
The draft SGEIS cannot simply be revised because the scope of the regulatory proceeding is insufficient. First, it assumed that existing gas drilling regulations are adequate. That has been extensively documented to be untrue. Second, only three main issues were addressed (effects of extended time at the drill pads; effects of increased water use; and protection of New York City's reservoir watershed). There is widespread consensus that DEC must "go back to the drawing board" and start over with a revised scope that addresses many critical issues that were excluded from the "Supplemental" GEIS proceeding.
For many decades you have been recognized as an environmental leader. Please heed the request for withdrawal submitted by so many elected officials, environmentalists and citizens who you have worked with for so many years. In particular, EPA's summary of the draft SGEIS's inadequacies could hardly be more blunt. See: http://www.toxicstargeting.com/sites/default/files/pdfs/3ppEPA-Dec09-Letter-HL2.pdf.
Thank you for considering my request and for your public service. I look forward to your prompt response.
Very truly yours,
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