On Friday, February 17, New York City Councils Committee on Environmental Protection will hold a hearing regarding “Geophysical Evaluation of Infrastructure Risks of Natural Gas Production on New York City”. In other words, this is about how underground faults and fracking-induced earthquakes pose catastrophic risk to New York City residents.
Please attend this hearing if you can. It is very important to the City Council that citizens demonstrate interest in this issue by participating in events like this. The pro-gas forces are strong, but the City Council is listening to the people.
Here are the particulars.
- Date and Time: February 17, 2012 at 1:00 PM
- Location: 16th Floor Committee Room, 250 Broadway, New York, NY
Though RSVP is not required, it helps if you tell us your intention of coming. So if you think you will attend, please let us know by filling the brief form at this link: RSVP for Feb 17 NYC Council Hearing
You Can Testify, Too!
The City Council intends to allow time for public statements. If you would like to submit written or verbal comments, we have supplied some sound/text bites below, along with a summary of NYC DEP’s report on seismic hazards.
If you intend to provide verbal testimony, please keep it brief – no more than 2 minutes – so that others can also have a voice. The City Council also asks that you bring 20 copies of your testimony.
Here are some talking points:
Here are some text bits you can incorporate into your comments. Or check out the summaries below and the full report to generate your own comments.
It is preposterous to risk the vital infrastructure and water supplies of every resident of New York, and an equal number of people upstate, for a finite and backward looking, destructive energy source.
According to the NYC DEP’s letter to NYS DEC, 100% of NYC’s demand is currently served from aquifers underlain by the Marcellus formation. The damage due to mishaps or the triggering of uncharted faults to water infrastructure would be irrevocable. The same applies to upstate counties. There is too much at stake. Development of gas fields through fracking cannot be allowed to happen.
It is absurd and disturbing that the NYSDEC dismisses the risk of injection-induced seismic events because injection wells are separately permitted. This is a bureaucratic, not a scientific distinction. Hydraulic fracturing is an injection process. Fracking fluids and seismic events are not going to honor NYCDEC’s dysfunctional bureaucratic limitations.
RDSGEIS relied in its analysis on data sets that are known to be incomplete. Given what is at risk, this is unacceptable.
Studies of injection-induced earthquakes have just gotten started, and already a link has been found between fracked vertical wells and earthquakes Oklahoma and the UK. High Volume Horizontal Fracturing is orders of magnitude more aggressive than fractured vertical wells. It is common sense to expect even greater seismic risk.
Damage to underground structures such as tunnels has been attributed to seismic events at less than 4 on the Richter Scale that took place over 25km away. Injection-related seismic events at a magnitude of 4 have been observed next door in Ohio. Damage to essential water supply infrastructure is a demonstrated risk.
Why are we even considering investing further in destructive, dirty, short term solutions like gas, oil and coal when we should be investing in the production and delivery of sustainable energy?
Besides opposing the development of gas fields, we should also stop the construction of the explosive pipelines that bring gas to market.
Counties and municipalities throughout New York State should seek injunctive relief from the irrevocable harm that hydraulic fracturing will cause if it is allowed to proceed.
HERE IS THE BACKGROUND ON THE HEARING:
The NYC Council has invited NYS environmental commissioner Joseph Martens and former NYC Department of Environmental Protection Commissioner Al Appleton to testify. It is expected that official testimony will focus on this report:
- RDSGEIS: Revised Draft Supplemental Generic Environmental Impact Statement on the Oil, Gas and Solution Mining Regulatory Program – Well Permit Issuance for Horizontal Drilling and High-Volume Hydraulic Fracturing in the Marcellus Shale and Other Low-Permeability Gas Reservoirs (September 7, 2011)
- NYCDEP: New York City Department of Environmental Protection
- NYSDEC: New York State Department of Environmental Conservation
- HVHF: High Volume Hydraulic Fracturing
- LVHF: Low Volume Hydraulic Fracturing
Here is a summary of the major recommendations by New York City’s Department of Environmental Protection, on how the RDSGEIS needs to be revised.
- A seven mile Infrastructure Exclusion Zone, where no HVHF would be permitted, around the Delaware and Catskill Aqueducts from our terminal reservoirs.
- A two mile Infrastructure Exclusion Zone around all other tunnels plus an Infrastructure Enhanced Protection Zone from two to seven miles around these tunnels.
- All HVHF applications within the Infrastructure Enhanced Protection Zone should require site specific review of proposed HVHF wells and the City’s approval.
- Both the Infrastructure Exclusion Zone and the Infrastructure Enhanced Protection Zone should be measured from the tunnel to the tip of the lateral well bore rather than (as RDSGEIS proposes) to the well pad.
- Applicants for permits within the Infrastructure Enhanced Protection Zone must be required to provide all relevant documentation concerning the proposed activity including geophysical data and seismic surveys.
Scope Problems with RDSGEIS
One of the problems with the RDSGEIS is that its scope does not fully cover the hazards of fracking. In fact, the NYCDEP observes that the scope of the RDSGEIS is not fully defined in ways that leave gaping holes of drilling-related risk.
- Not clear if RDSGEIS scope includes low-volume hydraulic fracturing in vertical and horizontal wells. If low-volume fracturing is not included, then what are DEC’s plans for additional environmental impact analyses?
- NYCDEP’s charter is the protection of NYC’s environment, so the NYCDEP’s comments are necessarily focused on NYC metro area instead of the entire state.
The High Impact of Mishaps
The impact of adverse events related to drilling can be catastrophic. Here are a few points.
- The water from the Catskill/Delaware watershed is high quality and largely unfiltered
- ½ of the NYS’s population’s water is at stake
- 100% of NYC’s water supply is at stake
- The water of approximately 1 million upstate consumers is at stake
- Marcellus shale underlies the entire Catskill/Delaware watershed and most of the tunnels that transport the water.
- Potential for negative and irreversible impacts.
General Risks Presented by Fracturing
Here are some of the risks presented by drilling. These are not all the risks, these are just a few risks that relate to underground faults and brittle structures.
- Industrialization of the watershed
- Chemical contamination of surface waters
- Surface water withdrawals
- Damage to infrastructure (dams, tunnels, etc.)
- There are no other areas in the world where HVHF has been conducted near deep rock tunnels, so no experience or prior engineering to rely upon.
- Even with a robust regulatory program in place, and a diligent HVHF operator, failures due to human error or natural disaster are inevitable.
- Given the fact that almost half the population of New York State relies on NYC’s unfiltered water supply, nobody, including a drilling company, the State, or other responsible entity, could provide an alternate supply of potable water while the contamination was addressed.
- It would take more than a decade for the City to design and build a filtration treatment facility that could protect against the contaminants of concern (if that were even feasible); during these many years, the public health, safety, and welfare of millions of New Yorkers would be at risk.
- If LVHF is not included in RDSGEIS scope, that may created an incentive to conduct LVHF and present risks similar to HVHF.
Specific Risks Related to Pressure and Seismic Events
The NYCDEP-commissioned report does a deep dive into specific areas of risk. Here are some points abstracted out of the report summary. Look at the full report for specifics, maps, models and methodology.
- HVHF involves subsurface pressures between 5,000 and 10,000 PSI
- Engineering studies have concluded that differential pressures as low as 20 PSI could damage tunnel linings
- HVHF induced seismic activity is often 1 to 3 on the Richter scale, and a recent injection-related event in OH is estimated at 4
- Though most surface structures can withstand events at 3 on the Richter scale, subterranean structures remain at risk because they are closer to the source of these events. Magnitudes less than 4 from sources over 25km away have been known to damage tunnels.
- The link between HVHF and seismic activity has only recently come under study – more needs to be known
- Studies of events in UK and OK indicate hydraulic fracturing fluids have activated faults and caused earthquakes. In both of these cases, the fracturing was of lower-impact vertical wells.
- The RDSGEIS dismisses the risks of these events on bureaucratic rather than substantive scientific grounds – Because there is a separate permitting process for injection wells, so these risks for HVHF (which wells are also injection wells) are not evaluated.
- Faults are known to exist in the watershed, and natural, small scale seismic events have been observed
- Given the high stakes involved, a cautious approach is needed
- Fracture and fault data
- RDSGEIS analysis is based on an incomplete dataset of fractures and brittle structures
- Faults are known to cross tunnel systems
- RDSGEIS has not fully disclosed or analyzed fractures around the NYC water system
- Some faults within the Marcellus system are known to break out into overlying rock. Gas columns could extend up to 4,000 feet above Marcellus rock.
- The RDSGEIS conclusion that induced seismic activity is not a significant impact is not supported by the evidence.