December 7, 2011
Vivian Walsh
584 Lake Rd.
Pine Plains, NY 12567
Eugene Leff
NYSDEC
625 Broadway
14th Floor
Albany, NY 12233
RE: Public comment on the SGEIS for natural gas drilling in the Marcellus Shale
Dear Mr. Leff,
I am writing to you today as a concerned citizen of the Hudson Valley. I have read and
researched both sides of the hydraulic fracturing issue and understand the inclination of
New York State to permit the natural gas drilling companies to drill in the Marcellus
Shale area given the current economic climate. However, I would encourage you to
deny the permitting of an area so critical to the New York City watershed and southern
tier of New York State.
One concern that I have has to do with the enforcement of the rules and regulations that
are presently in place for drilling. I have read the NYSDEC webpage regarding
Marcellus Shale where it talks about the disposal of the fracturing fluid and how the
“fluid removed from the well is required by law to be handled, transported and disposed
of properly.” This statement is further explained in the SGEIS section 1.7.9. Knowing
how vastly understaffed and underfunded the NYS DEC is I am gravely concerned how
the disposal of the highly toxic flowback water can possibly be effectively monitored and
enforced.
New York City's Department of Environmental Protection has concluded that hydraulic
fracturing is too dangerous for the city's Catskill/Delaware watershed. This gives me
cause for another concern having to do with the individual property owners of the drilling
sites who do not have the resources to draw upon that the NYCDEP does in the event
of well contamination. The SGEIS makes various references to decontamination
procedures that will be followed, but I do not see any reference to protections for the
landowner and adjacent property owners. I feel that there should be greater protection
established for the property owner by way of having an independent unbiased legal
organization create the leases that establishes sufficient protection for the property
owners in the event that they have well contamination whether it be directly from the
natural gas production or a side effect of the drilling, such as methane contamination.
The Energy From Shale website states: “The EPA initiated its own study of
environmental risks from coalbed methane hydraulic fracturing and, again, no significant
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environmental risks as a result of proper hydraulic fracturing were identified.” After
watching the movie Gasland I cannot be convinced that there are no environmental
risks! The numerous documented contaminations cannot be ignored.
I have also read in the SGEIS about how this will create employment opportunities.
Here is the part that concerns me. “Given the highly specialized nature of natural gas
construction, workers with the skills required to complete a high-volume hydraulic
fracturing operation would not be currently available in New York State or in the
representative regions. If high-volume hydraulic fracturing operations were to begin in
New York State, most of the skilled workers would initially need to be recruited from
outside the state and would be both temporary and transient in nature.” The
construction phase by nature is a temporary phase because construction only last until
it is completed, it is not continuous. This doesn’t help the unemployed in the region.
Specialized workers such as these that are needed for this project are transient by
nature because they go where the work is until the work moves to another region. So I
don’t really see where local workers would replace these temporary workers since they
would move to the next project after the construction phase is over.
Lastly, the amount of fresh water to be used to drill one well is astronomical, One million
gallons needs to be trucked in for each well. Water is quickly becoming the next natural
resource crisis and this process is helping me to understand why this is happening. We
are depleting one natural resource to acquire another. Also, one million gallons would
require 125 trucks (each tanker can hold 8,000 gallons) per well to travel the roads to
and from the well. That is a tremendous amount of wear and tear on the area roads
and the maintenance of those roads fall to the towns and counties in the area not the
gas companies. Is there any provision that will guarantee that the gas companies
maintain the area roads so as not to impact the local taxpayer?
According to a Marist poll that was done on the subject, only 38% of the people polled
support permitting hydraulic fracturing in New York State. 41% are opposed and 21%
are unsure. This tells me that there may need to be more public education on the issue
and as things stand now the majority of the population agrees with me. Again, I
encourage you not to permit hydraulic fracturing on a grand scale in the Marcellus
Shale.
Sincerely,
Vivian E. Walsh
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