It's the last minute, yes, but you can still submit comments today on the Draft Supplemental Generic Environmental Impact Statement On The Oil, Gas and Solution Mining Regulatory Program, also known as the Hydrofracking dSGEIS.
Here's what I sent.
Posted by simon at December 31, 2009 4:07 PM in New York State , energy , lettersReading the Draft Supplemental Generic Environmental Impact Statement On The Oil, Gas and Solution Mining Regulatory Program has been a disappointing experience. While I recognize that New York State is taking a more active regulatory role than many states, the proposals in the dSGEIS suggest that the state isn't especially worried about hydrofracking.
After 809 pages, I still don't see a clear explanation of how wastewater from the process will be regulated. I don't see strong mechanisms for compensating property owners whose homes, farms, and businesses may be damaged by a process they didn't agree to.
The clearest indication of this document's failure to appropriately address risks is its handling of the New York City watershed. New York City and New York State have invested decades of effort to prevent even minor threats to that watershed, as the rules for steam cleaning boats in the reservoirs make perhaps absurdly clear. The writers of the dSGEIS, however, seem to think the risk to billions of dollars in infrastructure not to mention the drinking water of millions of people is too small to worry about. While I live Upstate, the risk calculations here make me wonder whether any part of this document is to be trusted.
I also find it strange that after massive effort over the past few years to make local municipalities regulate stormwater, the dSGEIS reserves jurisdiction over the stormwater impact of drilling sites to the state. I've not been impressed by the DEC's general lack of interest in local input regarding activities permitted under the 1992 GEIS - see https://livingindryden.org/2009/12/gas_drilling_permit_letter.html. This document seems intent on perpetuating the strange system in which muncipalities can regulate garden sheds but not natural gas drilling pads.
There are many more things wrong with this document, but given that thousands of people, governments, and organizations, are already commenting, I suspect that keeping it brief will improve my chances of being heard.
Thank you very much,
Simon St.Laurent
Town of Dryden