I have a Bachelor of Science in Chemical Engineering and have worked on helping to classify hazardous wastes, testing of a rotary kiln incinerator for hazardous waste disposal as well as filing of air emission permits at major corporations. I no longer work in the Chemical Engineering field but when I heard what the technique of hydraulic fracturing involved and that it was exempt from EPA regulations such as the Safe Drinking Water Act, the Clean Air Act, and that its waste was (improperly) classified as non-hazardous, I became very concerned. The more I find out about it, the more I wonder if this can be done safely with current techniques, especially with oversight left to budget-strained state regulatory agencies.
I write to you today to request that you provide at least 30 days immediate public comment to identify additional issues that might be included in the forthcoming draft SGEIS scope for hydrofracking. Also, I request that you expand the scope of the draft SGEIS to include additional concerns, notably how to manage gas drilling wastewater. Furthermore, I ask that you establish Citizens and Technical Advisory Committees to help the DEC revise the draft SGEIS.
Please require individual EIS reviews for horizontal hydrofracking permits, GA effluent limitations for hydrofracturing, deep well and wastewater treatment, as well as updating the DEC's 1992 draft GEIS which is now woefully out of date.
It's not enough to comment on the previous regulations because they did not address air impact, cumulative impact, or health impacts of this type of gas drilling. The citizens of NYS need to see those studied EXTENSIVELY before releasing the SGEIS. The health and safety of the water, air, soil, environment, and most importantly, the citizens of this state depend on it.
Thank you for your time.
Sincerely,
Valdi W