You are here

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

Mary I Arlin
623 Utica St
Ithaca, NY
Tom Huntsman
Chief division of reconstructive surgery
BAssett medical center
2151 County Hwy 26
Fly Creek, NY
Barbara Pease
111 Rachel Carson Way
Ithaca, NY
Gerald Wolfe
474 Snyder Hill Rd.
Ithaca, NY
Leaf Turner
Adjunct Associate Professor of Applied&Engineering Physics
Cornell University
85 Autumn Ridge Circle
Ithaca, NY
Taffy Williams
President
NY4Whales
191 Westchester Avenue
Tuckahoe, NY
Ruby Turner
85 Autumn Ridge Circle
Ithaca, New York
Penny J Beebe
P.O. Box 102
Freeville, NY 13068
Mark Klingensmith
Technical Specialist
NYSCC at Alfred
PO Box 549
Alfred, NY
Paul Eichten
Mr.
1400 Euclid Ave
Syracuse, NY
Rita Bergen
Ms.
West End Ave.
New York, NY
Helen Burlingham
Co-founder
Regional Action Group for The Environment
6320 Soper Rd.
Perry, NY
Kyllikki Inman
110 Halcyon Hill
Ithaca, NY
Cherry Rahn
16 Jay St
Geneva, NY
Mary Bergen
23 Wells Ave
Hartwick, NY
Bonnie Logan
3199 Grenell Road
Middle Grove, NY
Tom Inman
Technical Engineer
Ithaca College
110 Halcyon Hill
Ithaca, NY
Laurel Hodgden
112 Halcyon Hill
Ithaca, NY
Meredith Bocek
Member
RAFT
75 Glann Road
Apalachin, NY
Frank Bocek
none
75 Glann Road
Apalachin, NY
Gerrit Crouse
member
American Institute of Biological Sciences (AIBS)
38 4th Avenue, Apt 2-N
Nyack, NY
Kate Inman
110 Halcyon Hill
Ithaca, NY
joey cali
36 weatherwood lane
rochester, ny
Michael Checa
Carpinteria, CA
Jennifer Lahey
1 Orchard Drive
South Salem , NY
Beth Ellen Clark Joseph
Steam Mill Road
Ithaca , NY
Joan Schumaker
2050C Paine Rd.
Dalton, NY
Marie McRae
710 Irish Settlement Rd
Freeville, NY
John Breitbart
255 West 95 St., #1A
New York, New York
Susan Earl
1018 E. 5th Ave
Durango, CO
Sidney Berger
215 Camp Road
South New Berlin, NY
Walter Aikman
17 Liberty St.
Auburn, NY
Oksana Fuller
3971 County Road 16
Canandaigua, NY
Robyn Bem
3 Ringwood Court West
Ithaca, NY
Carl Rosenstock
270 1st Street, 1A
Brooklyn, NY
Lisa Lippitt
1 Brunner Hollow
Cooperstown, NY
Heather Dasilva
200 Church st.
White Plains, New York
Arthur Rifkin
7 Fourth Rd
Great Neck, NY
Carol Chambers
622 Honeypot Rd
Candor, NY
Ms.
415 Wall Street
Elmira, NY
Nancy Beers
Mrs
4542 Clark Rd.
Campbell, NY
Phyllis Perna
Psy.D.
527 Stevenson Rd
Westport, NY
Leslie Gold
40 Downing St.
NYC, NY
Christina McClelland
561 Cherokee St
Denver, CO
Donna Mummery
67 Village Trail
Honeoye Falls, New York
Harry Aceto
Mr.
411 Willow Ave.
Ithaca, NY
Ursula Rozum
2013 E. Genesee St.
Syracuse, New York
Geo Kidd
Annette Gurdo
7595 State Route 5, apt 2
Clinton, NY
Charles Place
31 Crescent Dr.
Apalachin, NY

Pages