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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

Mary Place
RAFT
31 Crescent Dr.
Apalachin, NY
Katherine Denison
Denison Creative
289 Richs Dugway Road
Rochester , NY
Ilse Funk
Ms.
238 Mill Rd
Cherry Valley, New York
Sharon Osika-Michales
4411 Vinegar Hill Rd.
Skaneateles, New York
Jennifer Markham
31 Camborne Circle
Fairport, NY
Govannon Thunorwulf
CEO
Wizard's Worxs
108 Foss St
Biddeford, Maine
John Hopple
3300 Perry City Rd.
Trumansburg, NY
Douglas Kinney, D.M.D.
525 Crawford Road
Otego, New York
Paula MacDonald
Ms.
Eldred Central School
PO Box 294
Narrowsburg, NY
Margo Alexander
Ms.
5585 Searsburg Rd.
Trumansburg, NY
Anna Gibson
311 Bailor Rd
Brooktondale, NY
Susan Kelech
53 North Arch Street
Johnson City, New York
debby mcnaughton
none
6280 dugway rd
canandaigua, ny
Yvonne Taylor
Vice President
Gas Free Seneca
PO Box 776
Burdett, NY
Stephen Dungan
404Granton Mountain Road
Walton, NY
Kristine Regan
1421 NY Rt 26 S
Vestal, NY
Jean Gerow
149 blakeslee hill road
Newfield, NY
Louis & Carol Piciullo
Member
Protect Laurens
149 Co Hwy 12
Laurens, NY
Richard Johnsen
None
None
343 Raymond Fish Rd.
Hartwick, NY
Ted Zinski
P.O. Box 443
Whitesboro, NY
Lucy Garrison
1605 Trumansburg Rd
Ithaca, NY
Chaw Chang
Stick and Stone Farm
1605 Trumansburg Rd
Ithaca, NY
David Gower
279 Nye rd
Cortland, New York
Wanda Harding
Green Party
1755 rt 17 c
Bartone , New York
Patricia Fiske
3051 State Hwy. 206
Bainbridge, NewYork
Eugene Marner
1245 Oak Hill Road
Franklin, NY
Samuel Warren
4972 foster road
Cortland, NY
Peter Cramer
13 James St
Auburn, NY
Richard Hepburn
Mr
Retired
119 Rachel Carson Way
Ithaca, NY
Michael Benard
Shale Property Rights http://www.shalepropertyrights.com/blog/
7785 Modock Road
Victor, New York
Bridget McMaster
211 Third St.
Liverpool, NY
Petra Hepburn
Ms
Retired
119 Rachel Carson Way
Ithaca, NY
PAUL ROBINO
Member
FUDR
701 SOUTH RODNEY STREET
WILMINGTON, DE
William Russell
112 Auburn St
Ithaca, NY
Erin Heaon Meyer
Vice Chair
Chenango Community Action for Renewable Energy
510 County Road 31
Norwich, NY
David Barouh
1350 East 5th Street, Apt 5N
Brooklyn, NY
Diane P Gardner
1038 County Road 30
Afton, New York
Allegra Schecter
Mrs
ROAR Against Fracking
211 Adair Rd
Cherry Valley, NY
Andra Leimanis
Volunteer
Solarize CNY
921 Maryland Ave.
Syracuse, NY
Ann Boehm
280 Speed Hill Road
Brooktondale, New York
Gail Musante
Official signer for group
Sanford-Oquaga Concerned Citzens
199 Front Street
Deposit, NY
Nedra Harvey
Co-Founder
R-CAUSE (Rochesterians Concerned About Unsafe Shale-gas Extraction)
275 Berkeley St.
Rochester, N. Y.
Sarah McNaull
2521 West Danby Road
West Danby, NY
Patricia Donohue
Volunteer
Citizen Action
21 Exchange St., apt #4E
Binghamton, New York
Nancy Finger
Citizen
NYS Resident
4264 State Route 21
Canandaigua, NY
Catherine Rossiter
89 White Birch Lane
Sayre, PA18840
Anne Marie Johnson
187 Creamery Road
Brooktondale, NY
Bernice Yarosh
1957 Slaterville Road
Ithaca, NY
Aimee Arceo
Mrs.
77 Cheshire Lane
East Amherst, New York
Barbara Decker
Citizens of Northern Broome
P. O. Box 1027
Whitney Point, NY

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