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Action Alert

Speak Out to Protect State Parks and Forests

Public Comments on DEC Hydraulic Fracturing Plan Due Jan. 11

The Department of Environmental Conservation (DEC) is accepting public comments on hydraulic fracturing through Jan. 11. (More here.) Gas drilling using high-volume hydraulic fracturing could have substantial environmental impacts on more than 1 million acres of publicly owned land from the Catskills to Lake Erie. Hikers who use the Finger Lakes Trail, the North Country National Scenic Trail and other trails in the region should be especially concerned. Fracking would greatly alter the environment and setting of these trails.

In response to ADK’s advocacy efforts, DEC has recommended a ban on gas drilling on public lands, including state parks, state forests and wildlife management areas. But the energy industry is lobbying hard to convince Governor Cuomo to reverse DEC’s decision and open our public lands for intensive gas exploitation. (More here.)

As it stands now, the proposed surface-drilling ban does not go far enough. It would not prohibit gas drilling infrastructure, such as pipelines, on state land. The ban would not prevent the state from leasing subsurface oil and gas rights to these lands, which would allow them be tapped from well pads on adjacent private lands.

New York acquired these lands to promote healthy forests and to protect ecosystems, wildlife habitat, aquifers, rivers and streams. High-volume hydrofracking is an industrial process that is inconsistent with those purposes and the state laws governing the management of these lands. Current gas exploration techniques involve extensive land clearing and tree cutting for well pads, wastewater storage pits, pipelines and compressors. It involves construction of roads and parking lots to accommodate hundreds of 18-wheel tanker trucks needed to transport millions of gallons of water to the well site.

There is also danger of accidental spills of toxic chemicals and well blowouts. ADK is also deeply concerned about the millions of gallons of contaminated wastewater produced from fracking. This “backflow” not only contains fracking chemicals, it is also highly saline and radioactive. If it is not properly treated and disposed of, this wastewater poses a serious threat to New York’s rivers, streams and underground water supplies.

What Should You Say? In your comments, you should urge DEC to  

  • Prohibit surface drilling on all state parks, state forests and wildlife management areas.

  • Prohibit the lease of subsurface oil and gas rights under state parks and DEC-managed lands.

  • Prohibit gas pipelines, pipeline access roads, compressor stations and other gas-drilling infrastructure on state lands.

  • Require 2,000 foot buffers (measured from the end of a potential horizontal fracture) around state lands and primary or principal water-supply aquifers.

  • Require a triple layer of steel drill casings, with cementing between layers, that would extend below the groundwater or aquifer layer at the drilling site.

  • Require storage of fracking wastewater (or “backflow”) in closed-loop steel tank systems. Prohibit open lagoons or surface impoundments for storing fracking wastewater.

  • Require drillers to disclose the chemical composition of all fracking fluids. Require drillers to disclose the chemical composition, total dissolved solids (TDS), salinity and radioactivity levels of all fracking wastewater.

  • Require the drill-permit applicants to submit wastewater treatment plans that address all contaminants in the wastewater, including radioactivity, chlorides, total dissolved solids, heavy metals and aromatic hydrocarbons, such as benzene, toluene and xylene.

  • Require that fracking wastewater be regulated and treated as hazardous waste under the State Pollutant Discharge Elimination (SPDES) permitting process.

  • Require that all fracking wastewater be sent to treatment plants that have the capacity to fully treat it.

 

How to Submit Comments

DEC prefers that comments be submitted electronically using a comment form. The form is available at

http://www.dec.ny.gov/energy/76838.html

You can also mail or deliver comments to:

Attn: dSGEIS Comments

New York State Department of Environmental Conservation

625 Broadway

Albany, NY 12233-6510

Please include your name, address and affiliation. Comments submitted by fax, email or telephone will not be accepted for the official record.

More information on this issue is available here.