THIS IS SO IMPORTANT!!!!
Email this to: dmnsgeis@gw.dec.state.ny.us
or go here:
http://www.dec.ny.gov/cfmx/extapps/SGEISComments/
You can find MY letter at this link or read below:
https://docs.google.com/Doc?docid=0AQz30Jr__qsOZGRwOTdqemhfMWNoYjk3YmZy&hl=en
Members of the NYC Council-
I would like to submit my comments urging the city to consider the banning of any natural gas drilling in the state. My name is Tyler Caruso and I am a graduate student at Pratt Institute in Brooklyn, NY. I am in the Graduate Center for Planning in the Environment working towards my Master of Science in Environmental Systems Management.
I would like to take this opportunity to urge you to ban gas drilling in all of NY state not just the watershed because-
- While it is true that, compared to the average air emissions from coal-fired generation, natural gas produces half as much carbon dioxide, less than a third as much nitrogen oxides, and one percent as much sulfur oxides at the power plant, natural gas also has the highest pre-combustion carbon dioxide emissions due to gas leaks from pipelines. Pre- combustion effects are responsible for 5-20% of the total emissions associated with all fuel used in a building. These drilling operations are highly industrial in nature, with large numbers of diesel engines running 24/7 to perform the drilling, pumping, and compression- all which produce a large amount of exhaust. This method of drilling has also been documented to have a very negative impact on air quality, with unacceptable ozone contribution, methane releases and extremely large amounts of green house gas emissions.
- New York City is currently one of only four cities in the country that the EPA allows to provide residents water without any filtration. If that permit is revoked due to possible contamination caused by nearby natural gas drilling, New York would have to borrow the money, during an already-troubling economic time, for the plant. Along with this, according to Comptroller William Thompson, NYC residents would pay an additional 30% water increase to cover just the loan interest payments accrued. If drilling is allowed, NYS could have the burden of building and maintaining $10 billion water treatment facility-- thus will also now have additional carbon to offset in order to meet the governor’s executive order of GHG emission reduction. And because NYC’s water supply is unfiltered, we need to implement an aggressive program of watershed protection to protect our water at its source. The continued quality of the city’s premier drinking water depends on ensuring that the watersheds remain unpolluted and that the water infrastructure, too, remains sound.
-Even if rigorous safety precautions are taken- there is still the human error factor- and when considering a watershed that will effect over 40 million people I don’t feel that any risk is appropriate or tolerable. Please consider a recent spill that the Pennsylvania environment officials are now trying to clean up: over 8,000 gallons of dangerous drilling fluids after a series of spills at a natural gas production site near the town of Dimock last week:
"The spills, which occurred at a well site run by Cabot Oil and Gas, involve a compound manufactured by Halliburton that is described as a "potential carcinogen" and is used in the drilling process of hydraulic fracturing, according to state officials. The contaminants have seeped into a nearby creek, where a fish kill was reported by the state Department of Environmental Protection. The DEP also reported fish 'swimming erratically'. The incident mentioned above is one the latest in a series of environmental problems connected to Cabot’s drilling in the Dimock area. Last winter, drinking water in several area homes was found to contain metals and methane gas that state officials determined leaked underground from Cabot wells. And in the spring, the company was fined for several other spills, including an 800-gallon diesel spill from a truck that overturned. Neither Cabot Oil and Gas nor Halliburton immediately returned calls for comment on Monday. A Halliburton spokesperson sent an e-mail referring any questions to information on the company’s Web site." (http://www.propublica.org/feature/frack-fluid-spill-in-dimock-contaminates-stream-killing-fish-921)
-Along with this, the potential effects of natural gas drilling on other parts of the ecosystem have also been realized. Take for example the sudden bursts of methane not uncommon from the drilling process that have been implicated in the death of 16 cattle near a drill site in Louisiana or the steaming mud eruption during an exploratory natural gas search in Indonesia that has continued to flow for over a year now that has left permanent, uninhabitable damage to the land.
- If drilling is allowed pollution of ground and surface water, degradation of the air quality and the damage to the surrounding ecosystems will occur at some if not at a massive level and this will undo any economic gain from drilling leases due to plummeting property values from contamination and also economic decline for towns due to a decrease in tourism.
-There is not enough treatment facilities available and the facilities that are present are inadequate to handle the massive volumes of “produced water” that will be contaminated by the fracking fluids, and will also be host to high concentrations of salt, benzene, tolulene, xylene and, in some incidents, “naturally occurring radioactive materials.” These millions of gallons of produced water will have to be detoxified or treated before the water can be discharged into our surface waters.
- It has been brought to my attention from a letter issued by Joseph J. Heath, Attorney at Law acting in capacity as General Counsel for the Onondaga Nation. The letter states that the DEC is currently moving forward with an Indian Nations consultation policy, "...which states that DEC will consult with Indian Nations on a government-to-government basis on all environmental and cultural resource matters of mutual concern. The Policy further states that DEC is committed to working cooperatively with Indian Nations to address issues of mutual concern involving environmental resources, whether located on or outside of Indian Nation Territory; that DEC recognizes that environmental resources transcend these boundaries, and that protection and preservation of those resources requires close cooperation between the Department and Indian Nations.
These mining activities affect Indian Nation interests. As defined by DEC’s consultation policy, “Affecting Indian Nation Interests” means: a proposed action or activity, whether undertaken directly by the Department or by a third party requiring a Department approval or permit, which may have a direct foreseeable, or ascertainable effect on environmental or cultural resources of significance to one or more Indian Nations, whether such resources are located on or outside of Indian Nation Territory. This form of mining will have profound environmental effects within the aboriginal territory of the Onondaga Nation – on water, land, air, culture, spirituality – and will effect the Nations’ abilities as stewards responsible for the protection of Mother Earth. Not only does the proposed mining affect the Haudenosaunee and Onondaga Nation’s interests in the environment and cultural resources, but in addition, the Marcellus shale formation lies below Haudenosaunee lands which are protected by federal treaties of 1784, 1789 and the 1794 Treaty of Canandaigua. Because federal law recognizes and supports Indian Nation “ownership” of the minerals beneath their Treaty Protected Territories, it is critical that New York State undertake consultation immediately to ensure that the State is acting within its authority in regulating these mining activities. At this time, the DEC has not initiated consultation with Indian Nations concerning hydraulic fracturing and other mining, though public meetings have been scheduled and are ongoing. Thus, these mining activities are an urgent and prime example of the need for Indian Nation consultation and an opportunity to put DEC’s consultation policy to work. The Onondaga Nation expects DEC to initiate consultation on these issues presented by this letter immediately, due to the speed with which DEC is moving its environmental review process forward".
The letter also goes on to point out that the Haudenosaunee, including the Onondaga Nation, had previously inhabited the majority of the area that is now under review for drilling and/or would be impacted from drilling. This area is the home to tens of thousands of unmarked graves of ancestors that require protection from disturbance. It is mandated very clearly in Federal law that a consultation with Indian Nations concerning any potential disturbance of archaeological sites is required- which has not been done.
"Moreover, Article 14 of the New York Parks, Recreation and Historic Preservation Law requires State agencies to consult with the Commissioner of Parks prior to undertaking any project “if it appears that any aspect of the project may or will cause any change, beneficial or adverse, in the quality of any historic, architectural, archaeological, or cultural property that is listed on the national register of historic places or property listed on the state register or is determined to be eligible for listing on the state register by the commissioner.” There is no indication in the scoping documents that NYSDEC has fulfilled its consultative obligation, among other things. This oversight is particularly outrageous, insofar as it is well documented in the scholarly literature that substantial cultural resources are present throughout the geographic area underlain by the Marcellus shale formation, and are likely to be damaged or destroyed by these mining activities unless avoided by prior documentation and study. There is no indication in the scoping documents that NYSDEC has fulfilled its consultative obligation, among other things."
-Finally the drilling process is moving the state’s energy policy in the wrong direction and should be re-evaluated immediately. Instead of investing further in the extraction of the remaining fossil fuels, our state, and nation should be developing energy policies which will move us to totally renewable sources, such as solar and wind and set a global example of what is possible.
-Please look over these articles and videos in order to further inform yourself and your colleagues about the issue from personal stories where drilling has already occurred:
http://blogs.wvgazette.com/coaltattoo/2009/09/21/more-on-dunkard-creek-fish-kill/
http://www.npr.org/templates/story/story.php?storyId=104565793&ps=rs
http://www.propublica.org/article/clean-natural-gas-not-in-my-backyard
http://www.npr.org/templates/story/story.php?storyId=112978060
http://www.shreveporttimes.com/article/20090430/NEWS01/904300327/1060
Videos-
http://www.youtube.com/watch?v=fLn4zh6Eadw
http://www.youtube.com/watch?v=U01EK76Sy4A&feature=related
http://www.youtube.com/watch?v=NKTK_VnGcBs&feature=related
http://www.youtube.com/watch?v=dUy7J7NF02M
http://lauraflanders.firedoglake.com/2009/07/20/hydraulic-fracturing-and-the-natural-gas-bonanza-obamas-moral-failing-on-honduras-and-the-spirit-of-humanity-in-gaza/
http://www.youtube.com/watch?v=QefLQKLb5co&feature=related
http://www.youtube.com/watch?v=EHj90ZqImGY
Thank you for your time.
Sincerely,
Tyler Caruso
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