I am writing to request that the DEC address the following

Dear Commissioner Martens,

I am writing to request that the DEC address the following concerns as part of its revision of the draft SGEIS:

The SGEIS is based on two false premises. The first is that the GEIS (1992) is adequate to address aspects of gas drilling that pertained in traditional vertical wells. This premise has been demonstrated to be false by the 270 cases of leaks, unremediated pollution, explosions and other mishaps (documented by the DEC¹s own data) that have resulted from traditional vertical drilling).

The second premise is that hydro-fracking the Marcellus Shale is desirable and will be of economic benefit to New York State. This is highly debatable. While drilling may create some sorts of jobs and generate some forms of economic activity, it will also negatively impact current local economic activity: higher education; dairy industry; farming (especially organic farming); grape growing and wine making; hunting and fishing and tourism. In short, hydro-fracking is not necessarily a public good, and, is quite likely a malefic activity (unless it can be very carefully regulated and monitored).

1. The DEC must address water quality. The NYTimes articles expose the pollution of waterways by untreated/able fracking fluids. They outline a variety of pollutants, brine and radioactivity. All these must be addressed.

The Duke University study demonstrates that dangerous and unhealthful levels of methane from the Marcellus layers in drinking water wells are correlated with nearby gas wells in PA and NYS.

The DEC must address this with a public registry of mandated reporting of pre-drilling water well information (2 mile circumference) and any drinking water well problems within 2 weeks of developing. (In PA gas companies keep drinking water well problems secret because there is no mandated requirement to report them, thereby obfuscating the extent of water problems).

2. The DEC must address radioactivity. The DEC has yet to address these problems, including water from gas wells, cuttings in NYS landfills, exposure of workers, transportation of radioactive materials, etc. The NYS Department of Health indicated that the extreme amount of radioactivity from NYS Marcellus layers constitutes a major problem, and this point was amplified by the NYTimes articles. It is especially problematic if it gets into the food chain. The DEC must establish regular radiation testing for cuttings, wells and produced/flowback water at the expense of the companies.

3. The DEC must address the issue of hazardous waste: Related to the issues above is that of hazardous waste. All water issued forth from gas wells is hazardous and must be ticketed and tracked accordingly. There have already been numerous incidents in PA in which truckers have been sighted spilling such toxic water on the roads, in streams and leaked from holding ponds, etc. The holding ponds themselves must be eliminated in favor of closed systems. Yet there will always be some produced and flowback water needing to be disposed of safely.

4. The DEC must address well construction and cement issues: Most of the problems related to leakage and blow-outs have had some relationship to cementing problems. This area needs to be investigate thoroughly and carefully regulated with numerous inspections etc. Drilling literature recognizes that the cementing of wells is problematic and that the cement deteriorates over time. Can it ever be done safely?

5. The DEC must address the health effects of HHVHF drilling: The chemicals used to hydro-frack are known carcinogens, mutagens and endocrine disruptors. These chemicals leach into the environment through such means as spills, imperfections in casings, tears in impoundment linings, evaporation and through the spread of frack water on roads (or illicit emptying of frack tanks where no one is watching!). The broad spread of these chemicals in the environment come at a time when health professionals recommend decreased exposure to them.

Drilling activities and the attendant infrastructure (compressors, dehydration facilities pipelines, etc) produce air pollution and high rates of ozone. Among other health problems, high rates of asthma (25%) are reported in N. Texas school children. Air pollution must be addressed by DEC regulations.

The DEC should develop a mandatory reporting of health problems within a designated radius of gas wells and infrastructure, something that PA has just indicated it will start.

6. The DEC must address property value issues: Most studies indicate that the values of properties that are leased and those that are nearby decrease! Further, proposed setbacks of only 100 feet run counter to the secondary mortgage market, such that local mortgage lenders would not be able to sell them. (Most secondary financers require 200-300 ft setbacks). Gas drilling and infrastructure on properties would also compromise title insurance stipulations. Property value assessments are also compromised by leases and drilling.

7. The DEC must address cumulative effects: Probably the most cited criticism from the EPA on down is that the cumulative effects of gas drilling have not been documented. What happens to wildlife, water, health, the economy (of wineries, tourism and higher education) with the erasure of bucolic landscapes hacked up by roads, rigs, air pollution, truck traffic, compressors and the like? What happens when markets will no longer purchase Upstate produce because is comes from ³fracking country²? Credible economic studies (not those that are industry funded or inspired) show that, after
the boom phase, local economies of extractive industry boom towns perform worse than do those of nearby towns not engaged in mineral mining.

What will our landscape, air water and health look like after these industrial build-outs?

Finally, how can the DEC, with the loss of so many personnel, possibly regulate this runaway industry?

Thank you for considering these points. They are but the tip of the iceberg of concerns related to this form of gas drilling. NY State can ill afford to pollute its land, air and water for the short-term gains of multinational energy companies and a handful of landowners. The health and well-being of the State¹s people and wildlife come ahead on the short term gains for Exxon/XTO. Please wait until these and related issues can genuinely be dealt with before releasing the SGEIS.

Sincerely,

Gretchen H