Onondaga Nation Comments-Joe Heath
January 11, 2013
Heath-lDEC-RegsComment1-11-13fnl
January 11, 2013
Attn: Draft HVHF Regulations Comments
New York State Department of Environmental Conservation
625 Broadway
Albany, NY 12233-6510
RE: NYSDEC PROPOSED NEW AND REVISED REGULATIONS
REGARDING HIGH VOLUME HYDROFRACTURING
Dear Sir or Madam:
I am writing on behalf of the Onondaga Nation, for whom I am General Counsel, to
express the following concerns about the proposed regulations regarding high volume
hydraulic fracturing. These regulations appear to have been hastily compiled and contain
multiple internal inconsistencies that are beyond the scope of these comments, which are
limited to the broad shortcomings of the regulations. Please be advised that by commenting
on this document, the Onondaga Nation has called attention only to the most serious
shortcomings of these regulations to ensure that the Nation’s interests and treaty rights are
fully protected in the event that New York State takes the unwise step of allowing this
destructive practice. (Click on link above for full comments)