Dec. 30, 2009: State's gas drilling EIS is flawed
To The Editor:
For a change, Catskill community leaders are welcoming the latest move of the New York City Department of Environmental Protection (DEP) to safeguard its water supply by prohibiting gas drilling within or adjacent to the city’s watershed. Unlike many constraints of DEP policies, a ban on drilling is as essential to the future of the Catskills as it is to the city’s very survival. DEP’s assessment issued last week of extracting large quantities of natural gas from deep layers of shale under the city’s watershed coincided with the deadline for commenting on New York State Department of Environmental Conservation’s (DEC) draft supplemental environmental impact statement (EIS) on gas drilling across the state’s Southern Tier. DEP’s killer document supports Mayor Bloomberg’s call upon Governor Paterson to withdraw the state’s faulty draft EIS. Every page of the DEP report identifies fundamental information on the hazards of gas drilling that DEC has overlooked, dismissed or failed to quantify cumulatively.
The most blatant flaw of the draft EIS is that it assesses only the impacts of a single well field and intends to regulate each well in a one-by-one permit review process, an impossible task when 6,000 wells could be drilled in the watershed alone. In comparison, the city study tallies the cumulative impact of gas well development in the watershed and warns that the likely density of wells (about six per square mile or approx. one per 100 acres) would change the character and image of the surrounding area. The city asserts that the extent of disturbed land in combination with massive new wastewater treatment facilities and over 7,000,000 heavy truck trips a year on local roads would “industrialize” the watershed and burden local governments with unreimbursed costs. Whereas state revenue would go up from added business income taxes, county and municipal taxes, which are based on property values, might even go down with widespread desecration of the landscape, the area’s greatest asset.
The premise of the state draft EIS is that the geological structure above the shale is very stable, and very generally speculates that one or another serious effect may occur. In contrast, the city study draws on DEP’s experience in constructing water tunneling systems and its first-hand knowledge of the geological character of the watershed and connecting transport structures. City data on tunnel breaks attest to the unpredictability and frequency of vertical and horizontal fractures in the rock formations in the area. These natural shifts, exacerbated by hydraulic fracturing and periodic re-fracturing, would permit upward and outward migration of methane, radon and other contaminants into surface waters and aquifers used for wells that may be miles away in any direction, adding to the burden on county health departments of monitoring the impact of gas drilling on drinking water quality.
Every page of the city’s page-turner describes yet another consequence of drilling, unaccounted for in the draft EIS, such as the drawdown of valuable ground water to meet the voracious demands of fracturing. To extract the tightly bound gas from the shale, each test well is injected with three to eight million gallons of high pressure water and a proprietary mix of a reported 167 tons of more than 200 chemicals, of which over 90 percent are unidentified. Of the known constituents, many are carcinogens or harm reproductive, respiratory and other systems. Depending on how often this process is repeated, the average demand for water adds up to eight to 14 million gallons a day for the 6,000 projected wells just inside the watershed. Even if treatment plants could be found that could handle the volume of wastewater, there is no practical technology to remove the tons of chemicals. The only way to bring the concentrations of organic chemicals to acceptable levels is by diluting the wastewater with additional large quantities of clean water. Dilution, of course, does nothing to reduce the mass of chemicals that grow to nearly 48,000,000 tons at full build out with re-fracturing at five year intervals to squeeze out the more difficult to release gas. The use, transport and disposal of such quantities increase the likelihood of chemical spills and leakage, endangering all water sources. These and many other issues are simply not addressed in the EIS on the grounds that sufficient data were not available to make area-wide or statewide assessments. However, DEP has shown that, with some effort, informed estimates of unmanageable and potentially devastating impacts in their and our area of concern can be used by DEC to calculate regional risks and benefits and determine whether and under what circumstances fracturing wells should proceed at all.
Alarmed readers have until New Year’s Eve, December 31 to insist on withdrawal of the draft EIS by e-mailing DEC (email@example.com) and Governor Paterson (firstname.lastname@example.org). For more information, see catskillmountainkeeper.org.
Brian Ketcham, P.E.