I am writing to urge you to expand the scope of the

Dear Commissioner Joe Martens:

I am writing to urge you to expand the scope of the Supplemental Generic Environmental Impact Statement to address such issues as the disposal of gas drilling wastewater and oversight. To not do so would be a tremendous detriment to our state especially since we have seen other states such as Pennsylvania and Texas struggling with the aftermath of an unregulated, loosely monitored drilling process that has wreaked havoc on public health and public infrastructure. Since the natural gas industry is exempt from all major federal environmental laws, it is up to the state to put regulations in places that will provide the strongest protections for its citizens. The current draft of the SGEIS fails to do this.

I live in Auburn, N.Y., one of two places in the state that allows gas drilling wastewater to be disposed of at publicly-owned wastewater treatment plant. Gas drilling wastewater is very salty and radioactive and contains heavy metals that conventional plants cannot treat, yet our plant was given the go-ahead by the DEC to do so. Gas drilling companies were allowed to dispose of drilling waste for over a year without submitting the required quarterly monitoring reports. To correct the issue, the gas drilling companies only had to submit one lab analysis and a certificate stating the produced water did not come from the Marcellus Shale. Meanwhile, there has been no disruption of service on the part of the city. When I contacted the DEC and EPA, I was given the answer that it was up to the city to monitor the situation. The city’s stance is to take the gas companies at their word.

I cannot even begin to imagine the issues that will result when hydrofracking is in full swing in New York. As we have seen in Pennsylvania, the state had no plan in place to deal with the disposal of gas drilling wastewater once it was determined that wastewater treatment plants could not clean the produced water before discharging it into public drinking sources. In its current form, the draft SGEIS does not address this issue. As you are well aware, slick water hydraulic fracturing requires on average 5.6 million gallons of water to frack one well. Gas drillers plan to drill 71,000 in this state. Where will all that toxic, radioactive water go? We know conventional plants can’t treat the water. I certainly don’t want to see my county, Cayuga County, become a dumping ground for the gas industry’s waste. Who will monitor the gas drilling industry? The DEC does not have the staff to monitor the drilling that is occurring in our state now. When I see how little oversight has been given to the discharge of gas drilling wastewater in Auburn, I cannot even fathom how the state will be able to handle a gas drilling boom with its current staffing.

The state needs to address these problems before it issues its first permit.

I could understand keeping the SGEIS as is if we were the first state to have hydrofracking, but we are not the guinea pig. Unfortunately for other states, the lessons are being learned as the damage is being done, but that does not have to be the case with New York. Please do the right thing and broaden the scope of the report. I appreciate your time reading my comments.

Sincerely

Beth C