Recommendations on Commenting on Health issues in SGEIS 2011
The NYS DEC issued their preliminary revised draft SGEIS (http://www.dec.ny.gov/energy/75370.html) at the beginning of July 2011. In August or September the SGEIS will be supplemented with a part on noise impacts and a part on community and economic impacts. Other than that, it’s complete. Soon after that the DEC will begin a 60-day hearing period.
If you have expertise, even an opinion, your comments on the adequacy of the SGEIS to protect human health are very important. The SGEIS was delivered at the Governor’s direction without having assessed how humans would be impacted and without provisions to gather data and subsequently provide relief to impacted people. No health impact assessment was done, nor any risk analysis on potential human health impacts. Here is a link to the Battlement Mesa HIA (http://www.garfield-county.com/public-health/battlement-mesa-health-impact-assessment-draft2.aspx ) which studied the stressors to human health as experienced in Colorado; it will likely be different here in New York State. Also, attached, are three peer-reviewed papers on potential health impacts related to gas drilling, for your information.
The DEC and the DOH should receive your comments. Most importantly, the Governor must receive a copy. In addition, if you wish to share your comments on a website for others to read, please send a copy to SGEISHealthComments@gmail.com and your doc will be posted here http://www.gasdrillingtechnotes.org/sgeis-letter-requesting-health-comments.html . After you have submitted the comments, the web host will send you a link to your document.
Below is a list of potential stressors on human health in areas where gas drilling is occurring. Following the potential stressor are some of the locations in the SGEIS where you can find reference to that particular topic; however, additional references may be found scattered throughout the document–use the SEARCH option.
The list of mitigating procedures listed in Ch 11 will refer you back to the relevant section in the SGEIS).
STRESSORS:
- air pollution at drilling site and along pipelines (including GHG emissions, ozone, NOX, VOCs) (sec 6.1 and 6.5 and 6.6 and subparts http://www.dec.ny.gov/docs/materials_minerals_pdf/ogprdsgeisch6.pdf, and also see Appendix 19 http://www.dec.ny.gov/docs/materials_minerals_pdf/ogprdsgeisapp3.pdf, also Ch 11 )
- air pollution from truck traffic ( see Appendix 19 http://www.dec.ny.gov/docs/materials_minerals_pdf/ogprdsgeisapp3.pdf )
- water quality and quantity (sec 6.1 and subparts http://www.dec.ny.gov/docs/materials_minerals_pdf/ogprdsgeisch6.pdf , also sec 7.1 http://www.dec.ny.gov/docs/materials_minerals_pdf/ogprdsgeisch7.pdf and Ch 11)
- special exclusion for certain watersheds ( see sections 6.1.5.1 to 6.1.5.3 http://www.dec.ny.gov/docs/materials_minerals_pdf/ogprdsgeisch6.pdf )
- soil contamination (sec 7.1.3 and ch 11) and foodshed impacts (nothing)
- chemicals (can include endocrine disruptors here or in its own category) (see sec 5.4 http://www.dec.ny.gov/docs/materials_minerals_pdf/ogprdsgeisch5.pdf , sec 6.1.3.2 and 6.1.5.1 and 6.1.5.4 and 6.1.6.2 and 6.1.8.1 and 6.5 and 8.1.3.2 and 8.2.1.2 and 9.3.1 and ch11)
- endocrine disruptors (nothing in the SGEIS)
- NORM and radioactive waste (see sec 5.2.4.2 http://www.dec.ny.gov/docs/materials_minerals_pdf/ogprdsgeisch5.pdf and and 6.1.8.1 and 6.6 http://www.dec.ny.gov/docs/materials_minerals_pdf/ogprdsgeisch6.pdf and sec 7.7 http://www.dec.ny.gov/docs/materials_minerals_pdf/ogprdsgeisch7.pdf, and also Appendix 13 http://www.dec.ny.gov/docs/materials_minerals_pdf/ogprdsgeisapp2.pdf , also Appendix 27 http://www.dec.ny.gov/docs/materials_minerals_pdf/ogprdsgeisapp3.pdf , also Ch 11)
- other waste (like heavy metals, VOCs, etc) (sec 5.13 http://www.dec.ny.gov/docs/materials_minerals_pdf/ogprdsgeisch5.pdf and 6.1.8 and 6.1.9 http://www.dec.ny.gov/docs/materials_minerals_pdf/ogprdsgeisch6.pdf, and Ch 7, and Appendix 21 and 22 http://www.dec.ny.gov/docs/materials_minerals_pdf/ogprdsgeisapp3.pdf, also Ch 11 )
- spills (sec 7.1.3 and ch 11)
- accidents (a few references)
- noise, visual impacts and light (see sec 6.8 and 6.9 in August http://www.dec.ny.gov/docs/materials_minerals_pdf/ogprdsgeisch6.pdf )
- impacts on community character (could include socioeconomic issues here or separately) (sec 6.11 — will be added by August)
- socioeconomic issues (like property value loss, loss of usual income from farms, wineries, tourism, second-homes, displacement of families from rentals, etc) (will be added in August)
- impacts on health infrastructure (nothing found in the July 2011 SGEIS)
- psychological stressors (including addressing whether vulnerable populations are protected) (nothing found in the July 2011 SGEIS)
- is public health protected? (see sec 8.2.3.2–scroll down to citizen complaints)
- is the Precautionary Principle applied? (nothing found in the July 2011 SGEIS).
If you can, please review the SGEIS in its preliminary form, and again when the draft is completed, and please make comments.
DEC address for comments will be available in the near future and will be posted on the gas drilling tech notes site.
NYS DOH contact information:
Dr. Howard Freed, Director
Center for Environmental Health
New York State Department of Health
Flanigan Square, 547 River Street
Troy, NY 12180-2216
518-402-7500
ceheduc@health.state.ny.us and an additional address for the DOH dohweb@health.state.ny.us
Center for Environmental Health
New York State Department of Health
Flanigan Square, 547 River Street
Troy, NY 12180-2216
518-402-7500
ceheduc@health.state.ny.us and an additional address for the DOH dohweb@health.state.ny.us
The Honorable Andrew Cuomo
Governor of New York State
NYS State Capitol Building
Albany, NY 12224
http://www.governor.ny.gov/contact/GovernorContactForm.php and here is an alternate address: governor@chamber.state.ny.us
518-474-8390
NYS State Capitol Building
Albany, NY 12224
http://www.governor.ny.gov/contact/GovernorContactForm.php and here is an alternate address: governor@chamber.state.ny.us
518-474-8390
Regards,
Larysa
Larysa Dyrszka, MD
In addition, if you wish to share your comments on a website for others to read, please send a copy to SGEISHealthComments@gmail.com and your document will be posted here http://www.gasdrillingtechnotes.org/sgeis-letter-requesting-health-comments.html. After you have submitted the comments, the web host will send you a link to your document.
In preparing your statements on health, you may wish to use some references. There are many science and health articles posted on http://www.gasdrillingtechnotes.org/index.html, a site provided by Damascus Citizens. You can find additional, and more general, information about writing comments on the SGEIS at SourceWatch TinyURL.com/2011SGEISFlaws.As I wrote in the earlier email, we can all benefit from your comments, so please post them on http://www.gasdrillingtechnotes.org/sgeis-needs-health-comments.html or by emailing them to SGEISHealthComments@gmail.com and the webmaster will post them. I have been working with Damascus Citizens to develop this repository for comments on TechNotes.
Please note: Two articles which are peer-reviewed are only available for purchase, and should be labeled as such on any websites. They are :
- Dr. Aaron Wernham’s study … “discusses the first Health Impact Assessment for Alaska’s North Slope Region, looks at potential adverse and beneficial impacts of drilling for the culture and health of North Slope Inupiats” (as described on TechNotes).
- Dr.Adam Law & Dr. Madelon Finkel published an article this year in the American Journal of Public Health http://ajph.aphapublications.org/cgi/content/abstract/101/5/784
Two peer-reviewed articles are available in the public domain. They are also on TechNotes:
- Potential Exposure-Related Human Health Effects of Oil and Gas Development (Roxana Witter, et al, Colorado School of Public Health, 2008)
- Theo Colborn’s Natural Gas Operations from a Public Health Perspective (Theo Colborn, C. Kwiatkowski, et al., 2010).
*The page we are reproducing above was developed and offered to the public by Damascus Citizens for Sustainability (DCS) via its auxiliary website GasDrillingTechNotes.org – a library of gas extraction reference material – at this page http://www.gasdrillingtechnotes.org/sgeis-needs-health-comments.html DCS has its main website at DamascusCitizens.org
http://www.governor.ny.gov/contact/GovernorContactForm.php and an alternate address: governor@chamber.state.ny.us
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