We, the undersigned, respectfully write to request that you immediately require your Department of Environmental Conservation (DEC) to prohibit the use of "gelled propane," Liquified Petroleum Gas (LPG) and all other so-called "'environmentally friendly' or 'green' alternatives" hydraulic fracturing methods that have never been the subject of an Environmental Impact Analysis conducted pursuant to the State Environmental Quality Review Act (SEQR).

The use of propane, LPG and other hydraulic fracturing methods that do not involve water is referenced, but not comprehensively analyzed, in Section 9.3 of the Final SGEIS (Supplemental Generic Environmental Impact Statement): “'Green' or Non-Chemical Fracturing Technologies and Additives."

See: http://www.toxicstargeting.com/MS/2015-07-16/FSGEIS/Chapter-9/LPG

DEC concluded in its Final SGEIS:

"It is important to note that use of 'environmentally friendly' or 'green' alternatives may reduce, but not entirely eliminate, adverse environmental impacts."

DEC's Final SGEIS Findings Statement specifically rejects the use of an "environmentally-friendly chemical approach" for the same reasons that water-based high-volume hydraulic fracturing has been prohibited on a statewide basis:

"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).

The Department rejects the other available alternatives (the 'phased-permitting approach,' the 'environmentally-friendly chemical approach (emphasis added),' and the 'Special Places' alternative) because they all fail to limit unavoidable adverse environmental impacts and fail to address the risks and uncertainties of high-volume hydraulic fracturing (emphasis added)."

Nevertheless, DEC inexplicably failed to include gelled propane, LPG and all other "'environmentally friendly' or 'green' alternatives" within the definition of high-volume hydraulic fracturing adopted by the Final SGEIS Findings Statement.

DEC's high-volume hydraulic fracturing definition is limited only to "300,000 gallons or more of water:"

"1 High-volume hydraulic fracturing is defined as 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. The 300,000-gallon threshold is the sum of all water (emphasis added), fresh and recycled, used for all stages in a well completion. Well stimulation requiring less than 300,000 gallons of water (emphasis added) as the base fluid for hydraulic fracturing for all stages 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."

Conclusion

We request that you immediately require your DEC to prohibit the use of gelled propane, LPG and all other "'environmentally friendly' or 'green' alternatives" hydraulic fracturing methods that have never been the subject of an environmental impact analysis conducted pursuant to SEQR.

In addition, we request that New York adopt a high-volume hydraulic fracturing prohibition definition that includes all available "'environmentally friendly' or 'green' alternatives" for the same reasons that high-volume hydraulic fracturing using water has been barred on a statewide basis.

Finally, unless and until gelled propane, LPG and all other available "'environmentally friendly' or 'green' alternatives" non-water fracking methods are the subject of an environmental impact analysis conducted pursuant to SEQR, we request that their use not be permitted in New York either for conventional vertical gas or oil extraction wells or horizontal wells involving high-volume hydraulic fracturing.

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 address.

Thank you for your consideration.

Always respectfully,