You are here

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



SIZ - Simple Image Zoom


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

Katharine Adams
236 East 13th Streeet apt 14
New York, NY
David Jordan
292 E Miller Rd
Ithaca, NY
Sarah Irland
13938 Martville Road
Martville, New York
Patricia Woehrlen
562 Greenleaf Meadows
Rochester, NY
Wanda Mead Campbell
Citizen Action New York Southern Tier
73 Aldrich Ave.
Binghamton, NY
Rosemarie Bartus
4 Oak Street, Apt 1
Binghamton , NY
Gary Irland
13938 Martville Road
Martville, NY
Kimberly Noel
President
League of women voters Sussex Highlands
9 S Hayward Rd
Sparta, NJ
Charles Izzo
1108 North Cayuga St
Ithaca, NY
Sarah Olmsted
7027 Woodchuck Hill Rd
Fayetteville, NY
Kindra Bell
216 Queen St.
Ithaca, NY
Shirl Kozlowski
115 WEST RD
GROTON, NY
Robert Altman
29 Captiva Crossing, Fairport, NY, USA
Fairport, New York
Rose Mackiewicz
1773 Teedlebrook Road
Jefferson, New York
Laura Nowack
28 S. Main Street
Earlville, NY
Ellen Grapensteter
5 Skadden Terr
Tully, NY
Padme Livingstone
472 Harrogate Drive
Rochester , NY
Melissa Hamilton
8083 Falls Rd
Trumansburg, New York
Cari Gardner
Vice Chair
New York Progressive Action Network
26 S Greenwood Ln, # 2236
Athens, NY
John Striley
Humans for Clean Air Soil And Water
2088 State route 26 16B
Endicott, NY
Linda Aprea
193 SAPBUSH RD
CHENANGO FORKS, NY
Theresa Evans
131 Rigi Avenue
Syracuse, NY
Martha Scoppa
32 Cold Spring Road
Liberty, NY
Tonya Engst
CFO
TidBITS Publishing Inc.
50 Hickory Road
Ithaca, New York
Alexis Joseph Flynn
Volunteer
Camillus Parks & Recreation Volunteer
NY
Camillus, New York
Mark Kukla
1274 Lake Shore Drive
Webster, NY
Janet VanEtten
147 Stark Road
Newfield, New York
Patricia Marquardt
267 Jacobs road
Macedon, Ny
Robert Ross
PO Box454
New Baltimre, NY
Vheryl Kindy
61 Prospect Ave Apt 4
Binghamton, New York
Rosemarie Pupparo
n/a
131 West 1st St, 714
Oswego , NY
Ann Jamison
Concerned anti-fracking Citizen
411 Wolcott Ave
Syracuse , NY
Steven Foster
3906 Chatham Ln.
Canandaigua, NY
Sheila Squier
110 Columbia Street
Ithaca, NY
Michael Gorr
8 Deer Run
Skaneateles, New York
Jennifer Sutton
Owner
What If Wellness
349 William Street
Geneva, NY
Susan Multer
15 Penny Lane
Ithaca, NY
Mary Day
8502 State Route 89
Interlaken , NY
Valarie Vought
304 Oneida St.
Syracuse, NY
Peg Weidemann
CCCE
733 W. First St.
Elmira, NY
Carol Clarke
91 German Cross Road
Ithaca, NY
Carolyn Kenyon
1000 Cayuga Heights
Ithaca, NY
Victoria Zelin-Cloud
cofounder
Possible Rochester | Possible Planet
41 Elwell Drive
Rochester, NY
Matthew Nelson
103 Reservoir Ave
Rochester, NY
E Perrone
4 Brandon Rd
Brewster, NY
Thomas Marion
85 Mountaintop Lane
Deposit, NY
Joy Constantine
Ithaca, New York
David Inglis
Volunteer
Pachamama Alliance Rochester Area
173 Norwood Ave
Rochester, NY
Melanie-Claire Mallison
131 E Green St Apt 513
Ithaca, NY
Emily Tavares
2192 Mecklenburg Rd
Ithaca, NY

Pages