DEC SGEIS Comment Action Center

Submit Comments to DEC on the SGEIS by 5:00 pm January 11, 2012!

We want the DEC to receive as many comments as possible on its Supplemental Generic Environmental Impact Statement which paves the way for fracking in NY State.  We’re hoping to drown DEC in comments.  Please write comments using your own words.  Form letters are less effective.  Written comments will be accepted by DEC if received by DEC or postmarked by January 11, 2012 by two methods only. Written letter mailed to DEC or electronic submission using a web-based comment form available on DEC’s website http://www.dec.ny.gov/energy/76838.html which we’ve been told is not that user friendly. Comments that are faxed, telephoned, or emailed to the DEC will not be accepted for the official record.  We’re encouraging people to submit comments to DEC by regular mail because we’ve been told that letters are more effective.

Mail your comments to:
Attn: dSGEIS Comments
New York State Department of Environmental Conservation
625 Broadway
Albany, NY 12233-6510

Mail a copy to the Governor, your State Senator, and your Assemblyperson to let them know how seriously voters are taking this and that we’re holding them accountable:

The Honorable Andrew Cuomo, Governor of New York State
NYS State Capitol Building
Albany, NY 12224

To find your NYS Senator HERE.
To find your NYS Assemblyperson HERE.

If you are submitting your comments to DEC electronically, please remember to print out a hard copy and send it to Cuomo, your State Senator and Assemblyperson.

Suggestions for Writing Comments

1. Keep your comments focused.  Give a paragraph or two to each concern rather than discussing all of your concerns in one long paragraph.
2. If you can, make it clear what section and topic in the Draft you are referring to in your comments.
3. Every comment matters, but comments with concrete suggestions and with references to articles and papers, are especially useful.
4. For clarity, we encourage you to write separate comments on each topic.  You may send in multiple letters to DEC covering different topics in each letter.
5. Sign your letter individually with your address.  If you include a group affiliation, they could be grouped together and counted as one single comment.

A Sample Letter 

January 2, 2012

Attn: dSGEIS Comments
New York State Department of Environmental Conservation
625 Broadway
Albany, NY 12233-6510

Dear Ladies and Gentlemen:

Despite the growing body of evidence indicating that hydraulic fracturing gas drilling carry grave risks to public health, the revised draft SGEIS (September 2011) contains no public health analysis.

People living near compressor stations and well-pads have experienced unusual levels of asthma and other respiratory illnesses. Moreover, scientists have found pockets of unusual cancers in areas in which intensive drilling and fracking have taken place. The lack of a full public health analysis in the draft SGEIS is totally unacceptable. New Yorkers deserve to be informed of, and protected from, the health risks associated with hydraulic fracturing.

The current Revised Draft SGEIS should be withdrawn and any consideration for issuing regulations and permits for shale gas drilling must be put on hold until a comprehensive public health impact analysis of fracking be conducted and completed by an independent and creditable entity such as a school of public health not backed by the oil and gas industry.

Sincerely,

[Your Name]
[Your Address]

CC: The Honorable Andrew Cuomo, Governor of New York State
NYS State Capitol Building
Albany, NY 12224

[Your NY State Assembly member]

[Your NY State Senator]

Some Suggested Talking Points from us — SEE BELOW FOR MORE IDEAS!

1. New York City Watershed Inadequately Protected – 4,000 feet buffer for New York City and Syracuse watersheds is inadequate and not permanent in the Draft.  The horizontal well bore is known to go three miles underground in shale.  This would mean fracking could occur in and under the watershed.
2. Water Supply Infrastructure Would Not be Protected – 1,000 feet buffer can hardly be considered adequate.  Even worse, this protection is not permanent as a site specific review would be permitted.  Water infrastructure, tunnels and aqueducts, is aging, fragile and impaired.  The setback from infrastructure recommended by the Hazen and Sawyer study in 2009 was 7 miles.
3. There Was No Analysis of Subsurface Upward Migration of Produced Water from Fracking – It is known that naturally occurring methane moves up which can cause explosion.  If there is an explosion near the Delaware Aqueduct, New York City would lose half of its water in 24 hours.
4. All New Yorkers Deserve Equal Protection – By giving the NYC and Syracuse watersheds special protection, the DEC is implicitly admitting this process is inherently unsafe and denies many New Yorkers equal protection of the law.  We all know that NYC watershed is an unfiltered water source.  Many people in upstate New York are also using unfiltered water from private wells.
5. No Way to Dispose of Hazardous Fracking Wastewater – The Draft does not classify fracking wastes as hazardous wastes.  This means fracking wastes could be sent to municipal sewage treatment plants not equipped to properly remove the toxins.  Even worse, DEC itself has called into question New York’s capacity and ability to treat fracking wastes.  This practice is no longer allowed in other states, including Pennsylvania, where treated sludge was not properly disposed of, contaminating surface water.
6. Frack Fluid Disclosure Leaves Loophole Intact – The applicants for permits must agree to publicly identify the names of the additives, except where the applicants feel it necessary to protect confidential business information.  Leaving this exemption for industry to protect trade secrets will effectively allow the use of undisclosed toxins.  Disclosure of all frack fluid chemicals should be mandatory with no exemption.  In addition, the use of mutagenic and carcinogenic fracking chemicals must be outlawed.
7. No Public Health Impact Analysis in the SGEIS – Toxic chemicals used in the fracking process are carcinogenic and mutagenic.  Air pollution can travel more than 200 miles.  Fracking related air pollution and the potential for water contamination have serious effects on people, especially the elderly and children.  A comprehensive analysis of the impact on health must be conducted and made part of the SGEIS and a health registry must be established to document illnesses in fracking areas.  Pennsylvania is belatedly instituting a health registry.
8. Fracking in Floodplains –  In the aftermath of tropical storm Irene, disastrous flooding has overwhelmed large areas of New York State.  If fracking has taken place in New York, not only would the waters have destroyed everything in their path, the residue would have left highly dangerous toxic chemicals and radioactivity.  DEC proposes to ban well pad development in 100 year floodplains, but DEC acknowledges that the flood maps are out of date, have been unreliable and will not be updated until late 2012 after permitting may have already begun.  Fracking activities including infrastructure, open pits and holding ponds must be banned in any possible flooding area.
9. Positive Economic Impact of Fracking is Overstated – The positive economic impact of fracking has been premised on Marcellus gas reserve assumptions grossly over stated by the industry by 80%.  New York State is one of only two states that do not tax gas at the wellhead.  So New York State gets no direct revenue from the activity and the DEC has no funding source to regulate it.  The number of jobs for locals created by fracking has been consistently overstated by the industry and industry funded researchers.  The SGEIS does not include any analysis of jobs lost in the state’s agriculture and tourism sectors due to fracking.  Property value, hence property tax revenue, plummets where fracking takes place.  Banks will not provide mortgages on properties where there is fracking activity.

Find more information on the Draft SGEIS, its flaws, responses and comments on the following sites

The full revised Draft SGEIS can be found at: SGEIS

The full draft regulation can be found at Regulation

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