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Coalition Letter requests that NYSDEC issue a Supplemental Findings Statement to prohibit all types of High-Volume Hydraulic Fracturing

We, the undersigned, write respectfully to request that your Department of Environmental Conservation issue a Supplemental Findings Statement to revise its definition of high-volume hydraulic fracturing (HVHF) to prohibit all forms of shale fracking in New York, not just HVHF based on "300,000 or more gallons of water."

Our request is critically important because DEC received a gas well permit application on April 24, 2015 to frack Marcellus shale using gelled propane instead of water in Tioga County. Since then, there have been many exchanges between DEC and the applicant.

See: http://www.toxicstargeting.com/MarcellusShale/documents/2015-09-23/propane-fracking-proposed-tioga-co

Your administration clearly knew that its HVHF definition was inadequate to implement the No-Action decision in the Findings Statement issued on June 29, 2015.

Given that shortcoming, we request that you take immediate action to fulfill the shale fracking prohibition specified in the Findings Statement:

"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)."

See PDF page 42 at: http://www.dec.ny.gov/docs/materials_minerals_pdf/findingstatehvhf62015.pdf

DEC's No-Action decision reflects a determination that non-water HVHF associated with the “environmentally-friendly chemical approach," including "Liquid CO2," "Nitrogen-based foam" and " Liquefied Petroleum Gas (LPG)," "all fail to limit unavoidable adverse environmental impacts and fail to address the risks and uncertainties of high-volume hydraulic fracturing."

Yet, the Findings Statement's HVHF definition excludes those fracking methods because it is limited to:

"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."

We request that the definition of HVHF prohibit the use of gelled propane proposed in Tioga County by specifically barring the use of "water or any other substances" as the base fluid for hydraulic fracking proposed for Marcellus Shale in New York.

We also request that the definition of "high-volume" hydraulic fracking be revised from 300,000 or more gallons for all stages of a well completion to 5,000 or more gallons for any stage of a well completion.

Given those concerns, New York's definition of HVHF should be:

"High-volume hydraulic fracturing is defined as the stimulation of a well using 5,000 [300,000] or more gallons of water or any other substances as the base fluid for hydraulic fracturing for any [all] stage[s]in a well completion, regardless of whether the well is vertical or directional, including horizontal, in Marcellus Shale and other low-permeability gas reservoirs. The 5,000 [300,000]-gallon threshold is the sum of all water or any other substances, fresh and recycled, used for any [all] stage[s] in a well completion. Well stimulation requiring less than 5,000 [300,000] gallons of water or any other substances as the base fluid for hydraulic fracturing for any [all] stage[s] 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, but not for Marcellus Shale and other low-permeability gas reservoirs."

Adopting this revised definition is critical to implementing your administration's final conclusion regarding HVHF:

"Consistent with the social, economic and other essential considerations from among the reasonable alternatives available, the No-Action alternative avoids adverse environmental impacts to the maximum extent practicable; including impacts disclosed in the supplemental environmental impact statement..."

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 answer.

Thank you very much for your consideration.

Very respectfully yours,

Total Signatory Count: 1456

Nancy Pluta
4012 217th Street
Bayide, New York
Kristin Lovelace-Ross
Ms
56 Waterburg Road
Trumansburg, New York
Kristina Turechek
392 Hathaway Road
Otego, NY
Douglas Vitarius
74 Audubon Avenue
Binghamton, New York
Ian Rosenstein
6971 Reservoir Road
Clinton, NY
Richard Ross
Mr
56 Waterburg Road
Trumansburg, New York
Claudia Reese
3 Pheasant Lane
Ithaca, NY
Lonnie Chu
179 Nichols Ave
Syracuse, NY
John McClelland
139 School St. Millerton PA 16936
Ames, PA
Pam Jenkins
Ms
4023 Collegeview Drive
Cortland, NY
Mark Kuebel
402 W. 148th St #42
New York, NY
E. Chen
150 E 42
N.Y., N.Y.
Margaret Goodman
51 Broomall Lane
Glen Mills, PA
Stuart Anderson
Concerned Citizens of Otego
238 Main Street
Otego, New York
Alton Dunn
Teacher
Laurens Central School
12 Susquehanna Ave.
Cooperstown, NY
Sarah Sweeny
peter sweeny architects
28 stonybrook road
Tivoli, New York
Greg Wooster
9 Townline Rd
Ithaca 14850, NY
Pamela Moss
593 Pollard Hill Rd.
Johnson City, NY
thomas warner
2513 brookview road
castleton, new york
Kara Emmons
30 East Mayer Drive
Montebello, NY
Josephine Girardin
27 Reilly Street
West Islip, New York
Susan Sullivan
7878 State Rt 52
Narrowsburg, NY
Sarah Sweeny
peter sweeny architects
28 stonybrook road
Tivoli, New York
Theresa & Thomas Emmons
30 East Mayer Drive
Juliette Corazon
306 Rachel Carson Trail #4D
Ithaca, NY
Mike Millow
1316 Caton Rd
Corning, NY
Abigail Cohn
309 The Parkway
Ithaca, New York
Jennifer (Emmons) Parsons
618 Vendola Drive
San Rafael, CA
Mary McKeon
270 Searles Rd
Margaretville, NY
Dan Page
200 Central Park S
New York, NY
Martha Scoppa
32 Cold Spring Road
Liberty, NY
gloria b
6414 s lima rd
livonia, ny
Tom Geilfuss
8700 N. Point Dr.
Milwaukee, WI
Terezka Korinek
378 Thomas Rd.
Ithaca, NY
james spica
broadcaster
WVKR radio
152 Bloomer Road
Lagrangeville , NY
Karen Stamm
366 Broadway
New York, New York
Frederick Bauman
106 Rupp Rd
Monticello, NY
Jacob Garniez
New York, New York
Duane Diviney
230 Valley Road
Ithaca, New York
Nancy Sharpe
216 6th St.
Liverpool, NY
Laura Neiman
60 Seaman Ave 5g
New York, New York
Gary Meffe
Professor, retired
246 Van Cortland Rd.
Brandon, VT
Mary Graham
4021 McIntyre Rd
Trumansburg, NY
Linda Blossom
8387 Knight St
Interlaken, NY
Carolyn Fellman
15 Park St.
Moravia, New York
Suzanne Kates
130 Rachel Carson Way
Ithaca, NY
sally freund
po box 306
oak harbor , wa
Marilyn Schambach
Mrs.
713 Oak Hill Road
Afton, NY
Susan Andrews
15 Park St.
Moravia, New York
Alice Artzt
51 Hawthorne Ave.
Princeton, NJ

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