I write to STRONGLY URGE that the DEC address

Dear Commissioner Martens-

I write to STRONGLY URGE that the DEC address, minimally, the following issues in their revision of the draft SGEIS regarding hydraulic fracturing, pursuant to Executive Order No. 41. I also respectfully urge DEC to complete its revision without regard to any arbitrary deadline; there is so much that needs to be reviewed that the 7/1/11 timeline is not feasible, and you NEED to get this right this time, addressing ALL pertinent issues, so that there is not a need for yet another round of drafts to deal with crucial issues not included in this revision! As you yourself said, “'We're trying to solicit and digest all the information we can and put it into a document that addresses all the concerns raised to date. It's a really formidable task.”

The issues still missing in the SGEIS, to be addressed in the revision, include:
1. Potential for fires, explosions, polluted water supply wells, home evacuations due to natural gas intrusion
2. The potential for massive gas drilling wastewater spills that (as experience shows) are very likely to exceed clean-up standards decades after occurring.
3. Inadequate gas release disclosure requirements
4. Lack of financial surety to address gas hazards
5. Failure to impose strict liability for clean-up of gas hazards
6. Inability of publicly owned wastewater treatment plants to deal with the waste from fracking: “They are neither designed, constructed, maintained nor regulated to be able to handle those contaminated materials.”
7. Failure to establish a dedicated gas pollution clean-up fund comparable to the spill remediation fund
8. Potential for decreases in property values and ability to sell land due to the existence of gas leases (companies must somehow “make up the difference”, or change their policies to make gas leases NOT carry forward to future buyers, etc.)
9. all discharges of gas drilling wastewater (including flowback as well as “produced” or “brine”) to groundwaters MUST be subject to New York State’s GA (groundwater that supplies potable drinking water) effluent limitations. I ask DEC to adopt that policy in its revised draft SGEIS.
10. Recommendations from the EPA, including numerous fundamental shortcomings, including:
 potential impacts to public health,
 impacts to water supply and water quality,
 problems with wastewater treatment options and operations,
 local and regional air quality,
 management of naturally occurring radioactive materials and
 cumulative environmental impacts.

I also know that the EPA is conducting a National Hydrofracturing Study, and I request that DEC review those documents and address all concerns deemed within the scope of Executive Order No. 41.

I also request that the EPA take advantage of the 30,000 pages of documents collected by the New York Times for their three articles on fracking, which include information on
• extensive gas drilling wastewater monitoring results,
• legal orders to halt gas drilling wastewater discharges to Publicly Owned Treatment Works,
• environmental assessments of gas drilling wastewater impacts on water quality and
• hundreds of EPA and State government documents detailing high concentrations of Total Dissolved Solids (TDS), petroleum hydrocarbons and radionuclides in gas drilling wastewater.
I request that DEC review all those documents and address all concerns deemed within the scope of Executive Order No. 41.

The last problem listed above, the high levels of TDS and the presence of high levels of petroleum hydrocarbons and particularly radionuclides in the waste water from this drilling are particularly distressing. Stories about the die-off of marine life downstream from treatment plants that are being used today, and about the high level of radionuclides in the sludge left at wastewater treatment sites (some of which is sold to farmers as fertilizer and ends up in our foods; some of which is used on roads and ends up as dust that humans may breathe) pose cancer threats that are unsafe and unfair to residents who gain no benefits from the drilling process. The EPA itself states the following about radionuclides: “such concentrations are considered elevated and many pose unacceptable human health risk mainly via external exposure, inhalation of radon and thoron decay products, and to some degree via inadvertent ingestion.”

Finally, the NYS DEC already requires State Pollutant Discharge Elimination System (SPDES) permits for deep well injection of natural gas fluid. Those permits can only be granted on the basis of site-specific, individual EIS reviews. Given DEC’s long-standing policy, I request that Marcellus Shale horizontal hydrofracturing permits be subject to individual EIS proceedings instead of a Supplemental GEIS. Since the DEC is already requiring individual EIS reviews for the New York City and Syracuse watersheds., I believe all New Yorkers who drink water drawn from unfiltered groundwater sources in the Marcellus Shale formation must be afforded equal protection in every aspect of the letter and spirit of New York law. I request that DEC adopt that policy in its revised draft SGEIS.

Honestly, my main concerns are ALL for the people, and the waterways of NYS. I live in the Finger Lakes region, and have a sense of dread when I realize that a few polluted streams could enter any of the lakes, killing off marine life and ruining the lakes, not to mention the tourist base that is key to this part of New York. I am afraid for the health of myself and my family, for the safety of the water from the wells that belong to all of my family members including myself, for the destruction of viewsheds and the pollution of both air and water. I am not opposed to drilling per se, but it is abundantly clear that at the present time, the gas industry does NOT have answers to all of the dangers of hydraulic hydrofracturing. For this reason, there are MANY issues that need to be added to the revised version of the SGEIS, and many hurdles that gas companies MUST be made to step through to ensure the safety of the residents, land and water supplies in New York. Again, I
urge you to take the time necessary to INCLUDE these vital issues, and to INCLUDE EVERYTHING pertinent.

Sincerely,

Kristin L