Riverkeeper Team
In late December, Riverkeeper submitted detailed comments on DEC's Draft Supplemental Generic Environmental Impact Study (DSGEIS) on gas drilling using high-volume hydraulic fracturing, which demonstrate that the DSGEIS is deeply flawed and must be withdrawn. The following are highlights of our principal concerns:
- Failure to adequately analyze and address the potential establishment of exclusionary zones and permanent protection measures for critically important environmental areas
- Failure to adequately analyze and address cumulative impacts to the State’s air and water resources that would result from the processes used in horizontal drilling and high-volume hydraulic fracturing operations statewide
- Failure to adequately analyze and address the economic costs associated with environmental contamination from shale gas development and industrial gas drilling
- Failure to adequately analyze and address the economic value and benefits of intact forest and wetland ecosystems
- Failure to consider the findings and conclusions of state regulators from states that have experience with horizontal drilling and high-volume hydraulic fracturing that demonstrate clear examples of drinking water contamination from this process, in direct contradiction to the statements in the DSGEIS
- Failure to adequately analyze and address whether the State has the financial and personnel resources necessary to adequately permit, monitor and inspect all aspects of horizontal drilling and high-volume hydraulic fracturing operations and to enforce state regulations and permit conditions in the event of environmental contamination
- Failure to propose any new regulations to govern the proposed increase in horizontal drilling and high-volume hydraulic fracturing, and instead propose to process, monitor, mitigate impacts and enforce permits on a well-by-well basis
- Failure to adequately analyze and address the ability to handle and dispose of production brine and flowback water containing, among other toxics, naturally occurring radioactive materials (NORMs).
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