You are here

Coalition Letter Which Requests That Governor Cuomo Prohibit the Use of Gelled Propane, LPG and All Other "'Environmentally Friendly' or 'Green' Alternatives" Shale Fracking Methods Pending SEQR Review

We, the undersigned, respectfully write to request that you immediately require your Department of Environmental Conservation (DEC) to prohibit the use of "gelled propane," Liquified Petroleum Gas (LPG) and all other so-called "'environmentally friendly' or 'green' alternatives" hydraulic fracturing methods that have never been the subject of an Environmental Impact Analysis conducted pursuant to the State Environmental Quality Review Act (SEQR).

The use of propane, LPG and other hydraulic fracturing methods that do not involve water is referenced, but not comprehensively analyzed, in Section 9.3 of the Final SGEIS (Supplemental Generic Environmental Impact Statement): “'Green' or Non-Chemical Fracturing Technologies and Additives."

See: http://www.toxicstargeting.com/MS/2015-07-16/FSGEIS/Chapter-9/LPG

DEC concluded in its Final SGEIS:

"It is important to note that use of 'environmentally friendly' or 'green' alternatives may reduce, but not entirely eliminate, adverse environmental impacts."

DEC's Final SGEIS Findings Statement specifically rejects the use of an "environmentally-friendly chemical approach" for the same reasons that water-based high-volume hydraulic fracturing has been prohibited on a statewide basis:

"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 (emphasis added),' 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)."

Nevertheless, DEC inexplicably failed to include gelled propane, LPG and all other "'environmentally friendly' or 'green' alternatives" within the definition of high-volume hydraulic fracturing adopted by the Final SGEIS Findings Statement.

DEC's high-volume hydraulic fracturing definition is limited only 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

We request that you immediately require your DEC to prohibit the use of gelled propane, LPG and all other "'environmentally friendly' or 'green' alternatives" hydraulic fracturing methods that have never been the subject of an environmental impact analysis conducted pursuant to SEQR.

In addition, we request that New York adopt a high-volume hydraulic fracturing prohibition definition that includes all available "'environmentally friendly' or 'green' alternatives" for the same reasons that high-volume hydraulic fracturing using water has been barred on a statewide basis.

Finally, unless and until gelled propane, LPG and all other available "'environmentally friendly' or 'green' alternatives" non-water fracking methods are the subject of an environmental impact analysis conducted pursuant to SEQR, we request that their use not be permitted in New York either for conventional vertical gas or oil extraction wells or horizontal wells involving high-volume hydraulic fracturing.

We trust that you will find our request self-explanatory, but please do not hesitate to contact us if you have any questions that we might be able to address.

Thank you for your consideration.

Always respectfully,

Total Signatory Count: 968

Walter Hang
215 N. Cayuga St
Ithaca, NY
Erin Heaton Meyer
Vice Chair
Chenango Community Action for Renewable Energy
510 County Road 31
Norwich, New York
James-Henry Holland
Associate Professor
Hobart and William Smith Colleges (for identification only)
65 Jay Street
Geneva, NY
Jeff Dembowski
335 State Street
Albany, NY
Sam Sebren
PO Box 131
Athens, NY
Terezka Korinek
378 Thomas Rd.
Ithaca, NY
Katie Fittipaldi
3 Sugarbush LN
Pittsford , NY
Beth Mielbrecht
53 Enfield Main Road
Ithaca, New York
Dennis Turechek
392 Hathaway Road
Otego, New York
Fran Littin
1359 Taughannock Blvd
Ithaca, NY
susan gateley
lakeshore env action
12025 delling
wolcott, ny
Helen Cotton
317 Savage Farm Drive
Ithaca, NY
John Dennis
Manager
Chris Dennis Environment Fund
893 Cayuga Heights Road
Ithaca, NY
Kenneth Bird
131 Aragon Avenue
Rochester, NY
Rita Bergen
Ms.
West End Ave.
New York, NY
Bruce MacInnes
PO Box 1338
Sheffield, Massachusetts
Jacquelyn Clinton
1109 N. Cayuga Street
Ithaca, NY
Thomas McGlinchey
Job Title:
255-22 61st Avenue
Little Neck, New York
Richard G. Driscoll
self
114 Bank Street
Newfield, NY
Judith Hyman
Member
Enfield Neighbors for Safe Air and Water
632 Bostwick Road
Ithaca, NY
Harrison Shore
1118 Rock City Rd
Rock City Falls, NY
J Laverty
115 Lawrence St
Saratoga Springs , NY
Elizabeth Watts
16 Starks Place
Lynbrook, NY
Wendell F Perks Jr
6035 Turnpike Road
Trumansburg, NY
Karen K Smith
Ms.
68 Mary St.
Ithaca, NY
Laura Hurst
Mrs.
Southern Oregon Blue Skies Project
2020 Hwy 99 N #35
Ashland, OR
thomas warner
12033
2513 brookview road
castleton, new york
Elisa Evett
298 Bald Hill Rd.
Brooktondale, New York
Steven saperstein
320 Milltown road
Brewster, NY
Charleen Heidt
Research & Design
107 West Falls Street
Ithaca, NY
Lisa Ripperton
337 Rachel Carson Trail
ithaca, NY
John Bijarney
Founding Member
Concerned Citizens of Rural Broome
101 South Street
Chenango Forks, NY
Richard Grover
2 Railroad Ave
Canton, NY
William McKnight Sr.
President & Chief Operating Officer
Energy Conservation Specialists, LLC
60 Holland Drive
West Hurley, New York
Scott MacDonald
5 Sherman Street
New hartford, NY
Terry Cuddy
Cayuga Anti-Fracking Alliance
133 S. Hoopes Ave.
Auburn, New York
Mitchell Lavine
Dryden Resource Awareness Coalition
719 Ringwood Rd
Ithaca, NY
Marena Gonz
26 Frederick Road
Binghamton, New York
Lee Bhattacharji
685 Kelly Road
Arkville, NY
Diane Stein
40 Harrison St., Apt. 15A
New York, NY
Lou Priem
MD
276 Van Yahres Rd
Cooperstown, NY
Lesley Adams
6200 Mount Rd.
Trumansburg, NY
Elizabeth Adam
Ms.
127 West 82nd Street
NYC, NY
William Gonz
26 Frederick Road
Binghamton, New York
Duane Diviney
230 Valley Road
Ithaca, NY
Joe Holdner
109 Grassy Ridge Road
Olivebridge, New York
Nancy Lee
6003 SR 26
Whitney Point, NY
Holly Hutchinson
328 Pennsylvania St
Buffalo, NY
Lorraine Gudas
Professor
431 E 85th St
New York, New York
Noreen Stevenson
Mrs.
16 Elm Street
Chester, NY

Pages