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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

Thomas Brewster
Mr.
Mr.
803 E Main St
Little Falls, New York
donna mundt
FNP
retired2027
po box 187
newark valley, NY
ANNA WRIGHT
447 SEYMOUR HILL RD
HARPURSVILLE, NEW YORK 13798-1865
george mundt,jr
attorney
po box 187
newark valley, ny
Diane Farnham
243 Dubois Rd.
Ithaca, NY
Bridgett Perry
6 Nottingham
Ithaca, NY
Patricia Duncan
Po box 16
Roseboom, New York2540
Jennifer Schwade
Groton Awareness Resource Coalition
28 Cemetery Lane
McLean, NY
Paula Fitzsimmons
5281 Peach Orchard Pt
Hector, New York
Patrick Chambers
7641 Merritt Drive
Baldwinsville, NY
Carol J. Painter, Ph.D.
141 Westhaven Rd.
Ithaca, New York
Karin Suskin
129 Kline Rd
Ithaca, NY - New York
eileen hughes
Ms
5370 Vooreis Rd
Trumansburg, New York
Daniel Emmons
476 Silver Lake Spur
Deposit, Ny
Eleanor Fox
151 East 118 Street
New York, NY
Beth Olearczyk, MD
87 Pioneer Street
Cooperstown, NY
Ronald Lytel
87 Pioneer Street
Cooperstown, NY
Rena Kovac
71 Carroll Street
Binghamton, NY
Malcolm Steinberg
40 Ridge Street #3N
Hastings on Hudson, New York
Goline Doremus
Execuctive Board Member
Catskill Heritage Alliance
101 Kelly Road
Arkville, NY
R. Dunleavey
Secretary, Executive Board Member
Catskill Heritage Alliance
101 Kelly Road
Arkville, NY
Rose Mary Hooper
5 Mechanic St.
Naples, NY
Susan Bishop
24 Church Street
Deposit, NY
Lawrence and Karen Stein
7426 State Route 17C
Endicott, NY
Noreen Canny
7 Ivanhoe Road
Binghamton, New York
Maria Luisa Tasayco
City College of New York
116 Pinehurst Ave H43
New York, NY
Miriam Barrows
2218 Lewis Road
Erieville, New York
Gregory Weiland
member
GRAC
30 Torok Rd.
Groton, NY
David DeVivo
15 New England Dr.
Rochester, NY
Eric Bopp
418 Chestnut St
Ithaca, NY
Patricia Witten
151 Wood Rd.
Freeville, NY
Gene Polito
45 Shady Rest Dr
Sag Harbor, NY
Melissa Stephenson
77 Peruville Road
Lansing, NY
Lisa Tait
Chair
Town of Middletown Democratic Committee
PO Box 366 / 4979 Cty Hwy 6
New Kingston, NY
Robert Gosselink
205 Grandview Dr
Cobleskill, New York
Melissa Bishop
Member
Catskill Citizens for Safe Energy
24 Church St.
Deposit, NY
Mary Beth OConnor
119 Middaugh Road
Brooktondale, NY
Karen Butler
self
self
317 County Highway 40
worcester, NY
Ann Kozak
219 Pennsylvania Ave
Hancock, New York
Florence Carnahan
co-founder
Concerned Burlington Neighbors
5626 State Highway 51
Burlington Flats, NY
Suzy Winkler
Co-founder
Concerned Burlington Neighors
174 Pickens Road
Burlington Flats, NY
J E Delman
Red Hook, NY
Virginia Lee
146 Randall Ave
Norwich, Ny
marilyn gold
101 Oak st
Brooklyn, NY
jonathan kline
5126 mott evans rd.
trumansburg, ny
Joan Sichterman
Secretary
Protect Orange County
PO Box 870
Goshen, NY
William Volcko
803 Crow Hill Rd
Skaneateles, NY
Suzannah Glidden
Treasurer
Community Watersheds Clean Water Coalition
19 Sunset Place
North Salem, NY 10506
Margaret Wright
641 Beech hill ridge rd.
Andes, Ny
June Gordon
1927 Ginnan Road
Corning, NY

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