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Thirty Days of [Comments on] Fracking Regs
Don’t let this be our last chance to impact the regulations that would govern fracking!
The New York State Department of Environmental Conservation (DEC) has published draft regulations that would govern fracking in our state. They have given us just 30 days, until January 11, 2013, to review the regulations and make our comments. This may be the last chance New Yorkers will have to respond to the proposed regulations.
Based on where this process is going, there could be fracking by spring in New York State UNLESS we overwhelm the DEC with our comments about what is wrong with their fracking plan. It has been through your advocacy that we have been able to hold off the fracking juggernaut to date. Now we need to call on you again to respond in mass to tell the DEC why their regulations are inadequate, faulty, insufficient and flawed.
To start, the DEC is rushing regulations before even getting the results from the medical professionals they hired to study the health consequences of fracking, even though the review that they’re doing pales in comparison to what’s needed which is a comprehensive health study of fracking by independent scientists. And there are many, many other flaws in the DEC process and the regulations document they have produced.
Our colleague Sandra Steingraber has put together a website – Thirty Days of Fracking Regs that clearly explains the most flagrant flaws in the fracking regulations and provides an easy way to send comments to the DEC. We encourage you to visit the website to help become more educated about the problems with the DEC’s regulations and use the site to send in your comments. Catskill Mountainkeeper and our coalition partners will submit scientific and technical comments about the flaws in the regulations, but we want the DEC to know from the flood of comments it gets from the public, that the public does NOT want dangerous fracking in New York State.
Some of the more egregious failings in the state’s proposed fracking regulations are:
Minimal setbacks from fracking wells put our families, children and the environment at risk.
The DEC has arbitrarily picked 500 feet as the distance that no well pad may be located from a residential water well, domestic supply spring, water well or spring used as a water supply for livestock or crops, an inhabited dwelling or place of assembly. Not only is there is no scientific basis to claim that a 500-foot setback will provide safety, studies in Colorado have shown severe health effects to people and livestock living up to a half a mile away from drilling rigs.
There are no provisions for the disposal of toxic wastewater.
Despite the fact that fracking waste is incredibly toxic and can be radioactive, it is legally treated no differently than other waste because of federal exemptions specific to the oil and gas industry. That means that drill cuttings could end up in our municipal landfills and opens the possibility that wastewater containing benzene, biocides and radiation could be run through our sewage treatment plants.
There is nothing in the regs that prevents drill rigs from encircling and fracking under state land or fracking under lakes, streams and rivers.
The regs prohibit drilling on the top of state lands, but do NOT prohibit fracking operations on adjacent private lands or under lakes, streams and rivers. Underground horizontal drilling could extend fracking up to a mile underground into state lands.
The chemical constituents in fracking fluid can be hidden from the public—and from medical professionals—at the companies’ request.
There is no way that public health experts can predict the health consequences of exposure to fracking chemicals if they are unidentified. Without public disclosure we cannot offer informed consent to the risks we are being asked to assume.
These are only just a few of the problems with the DEC’s draft of fracking regulations. Please go to Thirty Days of Fracking Regs to learn more and send in your comments. Because it’s so important that the DEC get as many comments as possible, we ask you to forward this to your friends and neighbors. We need you to act so that fracking in New York State does not become inevitable.
We are in the trenches in our fight against fracking, and we now need to pull out all of the stops to make sure that New York State is not fracked. Please donate to our Fracking War Chest. We very much appreciate your support.
Between now and January 11, we must generate tens of thousands of comments in response to the Cuomo administration’s proposed fracking regulations and demonstrate the strength of our movement and the fierce opposition to fracking in New York.
We need people involved at all levels – whether it’s writing a comment every day or recruiting friends and neighbors to submit form comments online.
Here is our plan:
• There are risks associated with fracking – from toxic wastewater to methane emissions – that cannot be mitigated by any regulations. Simply put, there is no safe fracking – it must be banned.
• The process itself is fundamentally flawed. Issuing the draft regulations before finalizing the health and environmental impact study is like proposing rules for a game before deciding whether or not it’s safe to play.
• There are disturbing gaps in the draft regulations that demonstrate the inherent dangers of fracking, including no plan for treating toxic wastewater, no prevention of the hazards of radiation and radon, and no protections from toxic chemicals migrating underground.
We have developed several tools to help meet our objective of submitting a critical mass of comments calling for a ban that meet the DEC’s criteria.
Downloadable tools include:
Online tools include:
• Online form for people to sign and submit substantive comments
• Sandra Steingraber’s campaign to submit 30 comments in 30 days
Our most important objective is to amass and deliver as many comments as possible calling for a ban on fracking in New York.
Please note that in order for the comments to be formally counted by the Department of Environmental Conservation (DEC), the comments need to contain two additional elements:
1. The correct subject heading: High Volume Hydraulic Fracturing – Revised Proposed Regs, ID No. ENV-39-11-00020-RP
2. A critique of a particular problem with the regulations, and a citation of relevant the section of the regulations
3. Your name
New Yorkers Against Fracking and its coalition members are collecting comments – in both online and paper forms – to be delivered together.
Any comments produced using our online systems will be counted and hand-delivered to the Department of Environmental Conservation. Please mail any paper comments you collect to New Yorkers Against Fracking, 68 Jay Street, Brooklyn, NY 11231.
Please let us know if you have any questions, or need more information.
Together, we’re going to win.
David, Betta, Eric, Alex, Seth, Renee, John, Zora, Daniel, Forest, Isaac, and the rest of the NYAF team