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Coalition Letter Request That Governor Hochul Prohibit All Forms of High-Volume Hydraulic Fracturing Combined With Horizontal Drilling in New York In Order to Prevent Carbon Dioxide Marcellus Shale Natural Gas Extraction



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The Honorable Kathy Hochul
Governor of New York
The State Capitol
Albany, NY 12224

Re: Request That You Prohibit All Forms of High-Volume Hydraulic Fracturing Combined With Horizontal Drilling in New York In Order to Prevent Carbon Dioxide Marcellus Shale Natural Gas Extraction

Greetings:

We, the undersigned, write respectfully to request that you take immediate action to prohibit on a comprehensive basis all forms of High-Volume Hydraulic Fracturing (HVHF) using Carbon Dioxide, water, nitrogen, natural gas, propane, also known as Liquid Petroleum Gas, or any other substances in combination with horizontal, directional or vertical drilling in New York's Marcellus and Utica shale and other geologic formations.

In 2020, New York codified the HVHF prohibition adopted pursuant to the Findings Statement for the Final Supplemental Generic Environmental Impact Statement (SGEIS) for Oil, Gas and Solution Mining, but that definition was limited to hydrofracturing involving "the stimulation of a well using 300,000 or more gallons of water (emphasis added) as the base fluid for hydraulic fracturing for all stages in a well completion, regardless of whether the well is vertical or directional, including horizontal."

This inadequate HVHF prohibition could be avoided by simply using one gallon of water less than 300,000 gallons or a variety of non-water HVHF methods that have already been proposed in New York involving pressurized Carbon Dioxide and gelled propane that can serve as hydraulic fracturing fluids. These fatal flaws must be immediately resolved as proposed herein.

Proposed Carbon Dioxide Fracturing in New York's Southern Tier

In the autumn of 2023, Southern Tier CO2 to Clean Energy Solutions reportedly sent 6,500 mineral rights leasing letters to Southern Tier landowners outlining a vast proposal to extract natural gas from Marcellus Shale using non-water carbon dioxide fracking.

See: Carbon Dioxide Marcellus Shale Leasing Letter from Southern Tier CO2 to Clean Energy Solutions

We request that you immediately prohibit all forms of water and non-water HVHF in order to fulfill the shale fracking prohibition specified in the Findings Statement for the Final SGEIS.

High-Volume Hydraulic Fracturing and Environmentally Friendly Non-Water Fracking Methods Deemed Unacceptable by Final SGEIS

DEC's Final SGEIS determined that non-water HVHF methods associated with the “environmentally-friendly chemical approach," including "Liquid CO2," "Nitrogen-based foam" and "Liquefied Petroleum Gas (LPG)," "all fail to limit unavoidable adverse environmental impacts and fail to address the risks and uncertainties of high-volume hydraulic fracturing (emphasis added)."

See: NYSDEC Final SGEIS Chapter 9.3 "Green" or Non-Chemical Fracturing Technologies and Additives

DEC also declared, "Based on unavoidable adverse environmental impacts and uncertainty regarding the science surrounding high-volume hydraulic fracturing and its potential impacts to public health and the environment, the Department finds that the best course of action is to select the No Action alternative. Selection of the No Action alternative means that the Department will not establish a high-volume hydraulic fracturing permitting program; that no individual or site-specific permit applications for wells using high-volume hydraulic fracturing will be processed; and that high-volume hydraulic fracturing will be prohibited in New York State (emphasis added)."

See: DEC Final SGEIS: Unavoidable Adverse Environmental Impacts and Environmentally-Friendly Chemical Alternative Unacceptable

DEC concluded, "In the end, there are no feasible or prudent alternatives that would adequately avoid or minimize adverse environmental impacts and that address the scientific uncertainties and risks to public health from this activity. The Department’s chosen alternative to prohibit high-volume hydraulic fracturing is the best alternative based on the balance between protection of the environment and public health and economic and social considerations."

See: DEC Final SGEIS: High-Volume Hydraulic Fracturing Prohibition Statement

Comprehensive High-Volume Hydraulic Fracturing Prohibition Proposal

With that goal in mind, we request that you immediately fulfill our request and adopt the following revised HVHF language pursuant to Section 1. Subdivision 3 of Section 23-0501 of the Environmental Conservation Law:

3. (a) No permits shall be issued authorizing an applicant to drill, deepen, plug back, or convert wells that use horizontal, directional or any other form of drilling combined with high-volume hydraulic fracturing to extract, complete or recomplete natural gas or oil resources. For purposes of this section, high-volume hydraulic fracturing shall be defined as the injection or stimulation of a well using any amount of water, carbon dioxide, propane, nitrogen, natural gas or any other substance as the base fluid for hydraulic fracturing for any individual stage or the combined total of all stages in a well completion, regardless of whether the well is vertical, or directional, including horizontal.

New York's Existing Oil, Gas and Solution Mining Regulatory Program is Woefully Inadequate and Unacceptable

Our request is underscored by DEC's own data which document a wide array of public health and environmental hazards associated with oil and gas extraction efforts in the years since the Final SGEIS decision was adopted. It would be unthinkable to permit Marcellus Shale fracking using carbon dioxide and other non-water HVHF methods because your administration's existing regulatory enforcement activities are woefully inadequate.

See: 44 New York Natural Gas and Oil Extraction Problems That Reportedly Were Associated With Fires, Explosions, Drinking Water Contamination, Wetland Pollution or Uncontrolled Environmental Discharges Between 2011 - 2023 and Were Never Cleaned Up in Strict Compliance With All Applicable Regulatory Requirements According to State Department of Environmental Conservation Spill Records

Conclusion

We trust that you will find our respectful request self-explanatory, but please do not hesitate to contact us if you have any questions that we might be able to answer.

Thank you very much for your consideration.

Very respectfully yours,

cc:
Hon. Members of the New York State Assembly Environmental Conservation Committee
Hon. Members of the New York State Senate Environmental Conservation Committee
Hon. Members of the Broome, Chenango, Chemung, Tioga, Steuben, Allegany and Cattaraugus County Legislatures
Hon. James V. McDonald M.D., DOH Commissioner
Hon. Basil Seggos, DEC Commissioner

Total Signatory Count: 708

Candace Mingins
141 Albee Hill Rd.
Van Etten, NY
Lesley Adams
6200 Mount Rd
Trumansburg , NY
Phoebe Lakin
Ithaca, NY
David Mitchell
402 Esty Street
Ithaca, New York
John Seakwood
Organizer
Rivers & Mountains GreenFaith Circle
100 Bird Road
New Lebanon, NY
Mark Ahrens
128 Oakwood Drive
Wading River, NY
Marc Messing
164 Eagle Creek Rd
Eagle Bay, NY
Ronald Bjick
35 Elmwood Drive
Apalachin, NY
John Cisne
Professor Emeritus
Cornell University, Department of Earth and Atmospheric Sciences
27 North Landon Road
Ithaca, NY
Barry Pendergrass
37 Ramsey Place
Albany, NY
Eileen Gottschalk
509 Shelford Rd
Rochester, New York
Thomas Bonn
110 Peny Lane
Ithaca, NY
Peter Gottschalk
509 Shelford Road
Rochester , NY
Luce Guanzini
Highwood
87 W Hill Rd
Spencer NY, NY
Kathleen Woodcock
167 Crescent Pl
Ithaca, NY
Kathleen Pasetty
629 Hayts Rd
Ithaca, NY
Katherine Dickin
108 Juniper Dr
Ithaca, NY
Tom Marion
85 Mountain Top Lane
Deposit, NY
Michelle McNamara
328 East Miller Rd
Ithaca, NY
Amy Kletter
chair, environment committee
Ulster Activists
20 Sunrise Lane
New Paltz, NY
Miriam Strouse
143 Huguenot street
New Paltz , NY
Patricia Wood
Executive Director
Grassroots Environmental Education
184 Main Street
Port Washington, New York
Ellen Weininger
24 Prescott Avenue
White Plains, New York
Mary Herbst
Interfaith Peace Network
3258 East River Road Grand Island, NY
Grand Island, Erie
David Kukella
7 Adams Street
Auburn, NY
Tammy Kukella
7 Adams Street
Auburn, NY
Thomas Vasile
157 Burtis Point Road
Auburn , New York
Linda Smith
265 Merrill Creek Road
Marathon, NY
Gordon Smith
265 Merrill Creek Road
Marathon, NY
Deedr Demers
883 DryBrook Road
Willseyville, NY
Karissa Bush
Shortsville, NY
Lynn Snyder
308 MIDLAND RD, VESTAL, NY 13850-1026
Vestal, New York
Amanda Hamlin
Julie Penrod
Springwater, NY. 14560
Cuming Deborah
chief cook and bottle washer
myself
9013 Jackson St
Weedsport , NY
James Little
Spokesperson
Western Broome Environmental Stakeholder Coalition
522 Winston Drive Endwell, NY
Endwell, NY
Catherine Rainwater
2070 Johnny Ln
Walworth, New York
Melissa Kellison
22 Pine St
Norwood, NY
Zoi Christanis
31 Hubbard Drive
North Chili, NY
Sally Godfrey
Constableville, NY
Michael Thompson Logan
2013 Route 44
Pleasant Valley, New York
Frank Holden
Concerned citizen
1194 Otisco valley Rd
Preble, New York
Kristin Lovelace-Ross
56 Waterburg Rd
Trumansburg , NY
Susan Holland
243 Union Center Road
Ulster Park, NY
AK Kelly
257 Carroll Street, Apartment, Suite, Unit, Apartment, Suite, Unit
Brooklyn, NY
Jonathan Culler
909 Wyckoff Road
Ithaca, NY
Laurie Goodhart
Laurie Goodhart Art
PO Box 545
Cambridge, NY
David Middleton
35 Hannum St
Skaneateles, NY
Nik Wylie
242south first street apt 4e
Brooklyn, NY
Cynthia Hale
Reverend
67 w. 1st Street
Corning , NY

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