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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

Carolyn Tavares
2192 Mecklenburg Rd
Ithaca, NY
Miriam Rice
4396 Krums Corners Rd
Trumansburg, NY
Edward Price
Lecturer
Stony Brook University
31 Walters Ave
Cold Spring Harbor, NY
Elizabeth Sanders
retired teacher
Cornell U.
Ithaca, NY
Rebecca Musy
14930 Devonshire Woods Pl
Tampa, Florida
Fred Wilcox
Professor
105 West Court
Ithaca, New York
Jessica Palenchar
979 Virginia Street
Dunedin, FL
Delores Bennett
RN
11 Martin Brook St.
Unadilla, NY
Ric Allen
MD
43 Forest Acres Dr.
Ithaca, NY
Anna Bunting
2741 Arrowwood trail
Ann Arbor, MI
Clyde Zaloudek
431 East 12 Street 1B, apt. 1B
New York, NY
Audrey David
10 Stewart Pl.
White Plains, NY
Paul Robillard
Executive Director
World Water Watch
5405 NW Deerfield Way
Portland, OR
Don Crittenden
173 Bundy Road
Ithaca, New York
Leslie Gold
Ms
40 Downing Street
NY, NY
Patricia Taylor
1879 Ellis Hollow Road
Ithaca, New York
Diane Specioso
10003
27 E 13th St
New York, NY
Dru Wheelin
Mrs
36 Porter Hill Rd
Ithaca, NY
Brian Greeson
412 Linden Avenue
Buffalo, NY
David Nevin
36 Hargrave Street
Rochester, NY
Anne Lindsay Groves
Assistant Principal Cellist
Syracuse Orchestra
P.O. Box 930
Skaneateled, NY
Ann Pilcher
3727 Coleman Hill Rd.
Jamesille, NY
Judith Arnold
Resident
Year
868 E MAINE RD
Johnson City, NY
Charlotte Gillespie
Mrs
2888 Sherman Hollow Rd
Penn Yan, NY
Annelise Carleton-Hug
427 King Rd.
Mill Run, PA
Rose Hilbert
owner
The Inn at Gothic Eves Bed and Breakfast
112 East Main St.
Trumansburg, NY
Erica Crytzer
8202 Route 96
Interlaken, NY
Jeremy Crytzer
8202 Route 96
Interlaken, NY
Gregory Crowell
Chairman
Town of Otsego Zoning Board of Appeals
166 Phoenix Mills Rd, Cooperstown, NY, 13326, USA
Cooperstown, Otsego
Asher Pacht
Carol O'Brien
8415 Garlinghouse RD
NAPLES, NY
Nicholas Cohen
Professor Emeritus of microbiology and immunology
University of Rochester, school of medicine and dentistry
7289 Ludlow Drive
Canandaigua , NY
Jessie Reich
N/A
N/A
40 Seminary St
Auburn, NY
Lynn McMannis
PO Box 4174
Ithaca, New York
Suzanne McMannis
PO Box 4174
Ithaca, New York
Alice Saltonstall
409 Hanshaw Rd
Ithaca, NY
Susan Mosher
W. Highland Dr
Schenectady, NY
Mary Lee
9183 Booth Rd
Trumansburg, NY
Katherine Funk
2789 Forest Hill Drive
Corning, NY
J E Delman
, NY
Nancy Sharpe
216 6TH ST
LIVERPOOL, NY
Laura Jones
12180
114 3rd St
TROY, NY
Carl Klein
156 Indian Church Road
Buffalo, NY
William Turechek
392 Hathaway Rd
Otego, NY
Deborah Bruce
Phoenix Farms
7795 VERMONT HILL RD
HOLLAND, NY
Elaine Hardman
StoneFlowerPottery
3180 Riverside Dr
Wellsville, NY
Margo Alexander
5585 Searsburg Rd
TRUMANSBURG, NY
C Devine
Sustainable Warwick
26 Onderdonk Rd
Warwick, NY
Laura Engle
468 Cave Creek Rd
Mammoth Spring, AR
P Podmore
private citizen
, NY

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