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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

David LoParco
2604 Carson
Cortland, New York
Michael Blaine
Mr.
1773 Teedlebroom Rd.
Jefferson, NY
brian kuebel
89 eastgate drive
rochester, ny
Dennis Cook
8132 Creekview Drive
Bridgeport, NY
Gundula Lee
RD #1
Newfield, NY
Bridget Meeds
211 Cascadilla Street
Ithaca, NY
brenda lee
16 quarry dr
wappingers falls, ny
Cary Fassler
398 state rt. 69
Williamstown (Amboy), New York
Julie Kulik
Director
Earth Arts Ithaca
20 Elm Street
Brooktondale, ny
Melanie Mahoney Stopyra
109 Thurber St.
Syracuse, New York
James Ayers
59 Samsonville Road
Kerhonkson, NY
Joseph Honis
4271 Henderson Pl
Syracuse, NY
Cathy Farris
Ms.
40 church rd
Mountaindale, New York
Rebecca Casstevens
Ms.
22 Winding Way
Binghamton , NY
sarah brumberg
109 texas ln
ithaca, NY
Marty Blodgett
549 Spencer Rd
Ithaca, NY
Vincent Kotmel
1763 Danby Road
Ithaca, NY
Matthew Ryan
114 Dey St.
Ithaca, N.Y.
Jo-Ann O'Brien
4591 Misty Hill Drive
Canandaigua, N.Y.
Elizabeth Cobb
136 Crescent PL
Ithaca, NY
Linda Wells
, NY
GERALD HEATON
510 COUNTY RTE. 31
NEW BERLIN, New York
Mitchel Cohen
Coordinator
No Spray Coalition against pesticides
2652 Cropsey Avenue
Brooklyn, NY
Paul Baumann
101 Oak Street
Brooklyn, New York
Daniel Hill
Sacandaga Rd
Scotia, NY
Edward Seus
ZBA Board
CTPFL, KLA, BPA, JERUSALEM ZONING BOARD
6549 W. Bluff Dr.
Keuka Park, NY - New York
Angela Fox
Founder
The Mothers Project
2578 Broadway #108
New York, NY
Carole Marner
Compressor Free Franklin
1245 Oak Hill Road
Franklin, NY
Ellen and Oskar Schmidt
8 Gennung Circle
Ithaca, NY
james sherpa
302 giles st
ithaca, ny
Robin Schmidt
41-15 46th
Sunnside, NY
James Strait
Head Honcho
Christians for Impeachment of all Politicians in Office
1978 Grand Central Ave.
Horseheads, New York
Holly Anderson
8008 35th Ave
Jackson Heights, NY 11372
Marie LoParco
Ms.
PO Box 163
Cortland, NY
George Koury
Educatioin Coordinator
Olive Defense Against Fracking
8 Sahler Mill Road
Olivebridge, New Yori
Courtney Williams
Vice President
SEnRG
92 McGuire Ave
Peekskill, NY
Daniel Pagano
170 Second Avenue
New York, NY
Joanne Corey
member
Vestal Residents for Safe Energy (VeRSE)
209 Lewis St
Vestal, NY
Stephen Keast
PO Box 105, Hurd Rd, Slaterville Springs, NY, 14881
Slaterville Springs, NY
Howard Weinblatt
2684 Kenyonville Rd.
Albion, NY
Ariel Churi
424 Highland ave.
Montclair, nj
Gretchen Herrmann
433 Bostwick Road
Ithaca, New York
Julie Mundt
607 Broad St.
Endicott, NY
Lars Peterson
1623 Brown Rd.
King Ferry, NY
Bernie O'Doherty
607 Broad St.
Endicott, NY
Jeffrey Raczkowski
19 Timothy Dr.
Orchard Park, NY
Eric Mundt
100 Imperial Circle
Rochester, NY
Ramsey Brous
42 Sparrow Crest
Ithaca, NY
Nancy Lee
Select...
6003 SR 26
Whitney Point, New York
Michael Singer
481 Dugway Road
Spencertown, New York

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