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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

Alicia Wittink
512 Highland Rd
Ithaca, NY
Joel Gagnon
2353 Spencer Road
West Danby, New York
Chris Saia
12 McGuinness Blvd. South
Brooklyn, NY
Harry Levine
President
Advocates for Springfield
PO Box 25
Springfield, New York
Leslie Allee
14 Dug Rd
Lansing, NY
James Hodges
Mr.
117 Rachel Carson Way
Ithaca, NY
Betsy Bonsignore RN LMT
Ms.
815 sturdevant rd
gillett, Pennsylvania
Brian Greeson
71 Willis
S. Wales, NY
Jacquelyn Clinton
1109 N. Cayuga Street
Ithaca, NY
Kalika Stern
75 Timberhill Lane
S.Fallsburg, NY
Stephanie McMahon
Associate Professor
6405 Palmiter rd.
Alfred Station, NY
Nan Kotmel
Danby
Ithaca, NY
Philip Lewis
Dr.
(retired)
242 Cedar Cove Road
Lansing, New York
daniel bock
5111 old bald hill rd
hemlock, ny
John Fry
Director
Beaver Dam Sanctuary
Katonah, NY
Nicholas Cohen
Prof. Emeritus of Microbiology & Immunology
University of Rochester School of Medicine & Dentistry
7289 Ludlow Drive
Canandaigua, NY
june Fisher
3796 state route 364
Canandaigua, NY
Barbara Harrison
143 Westview Lane
Ithaca, NY
Steven Foster
Mr.
3906 Chatham lane
Canandaigua, New york
Janice Pfaff
642 Coddington Rd
Ithaca, NY
Tom Seaney
Owner
Dewitt Park Inn
67 Marsh Rd
Ithaca , NY
Dan Taylor
Founding member
Concerned Residents of Oxford
450 Basswood Rd
Oxford, NY
Jerry Ravnitzky
124 Hill Street
Mahopac, NY
Judith Fletcher
MUSE (Musicisans United to Save the Environment)
525 W. 238th St. Apt. A1
Bronx, New York
Alice Saltonstall
409 Hanshaw Rd
Ithaca, NY
Lee Bailey
Associate Professor
Ithaca College (Retired)
700 Warren
Ithaca, NY
Jeff Dembowski
335 State Street
Albany , New York
Abbe Lyons
154 Westhaven Road
Ithaca, NY
Tom McClelland
2644 Hunt Street apartment 9
Ames, IA
Sharon Ziegler
525 North Aurora St
Ithaca, NY
Sandy Wraight
9 Redwood Ln
Ithaca, NY
Peter Davies
755 Snyder Hill Road
Ithaca, NY
Thomas Shelley
Chair, Board of Directors
Sustainable Tompkins
118 E. Court St.
Ithaca, NY
Peter Favant
552 Riverside Dr
New York, NY
Robert Cutler
PO Box 83
Garrison, NY
David Ritchie
160 Crescent Pl
Ithaca, NY
susan deane
Kathleen Chase
250 Red House Hill Road
Cooperstown, NY
Lesley Adams
6200 Mount Rd
Trumansburg, NY
Candace Mingins
141 Albee Hill Road
Van Etten, NY
Eileen Driscoll
125 valley view
Steven Handwerker
Psychologist
Steven E Handwerker PhD, Ddiv
50 ShultiS FARM RD
BearsVILLE, NY
Bernard HANDLER
Bridget Reynolds
6936 Twin Valley Terrace
Almond, NY
Barbara Usher
144 Besemer Hill Rd
Ithaca, NY
Ronaldo Gonzalez
56 Sterling Street
Beacon, NY
E. W. Browne
206 Eddy St.
Ithaca, NY 14850
Linda Roach
1373 Taughannock Blvd.
Ithaca, New York
Elizabeth Sanders
Professor of Government
Cornell University
16 The Byway
Ithaca, NY
John Coleman
75 Turkey Hill Road
Ithaca, NY

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