Town of Ithaca Comments on SGEIS

November 24, 2011

Town of Ithaca Comments.pdf (application/pdf Object).

http://www.tompkins-co.org/tccog/Gas_Drilling/Public Hearing Comments/Town of Ithaca Comments.pdf

TOWN OF ITHACA
COMMENTS ON THE REVISED DRAFT SUPPLEMENTAL
GENERIC ENVIRONMENTAL IMPACT STATEMENT (sGEIS)
ON OIL, GAS AND SOLUTION MINING

ADOPTED NOVEMBER 21, 2011

Note: The comments submitted are only those feasible within the time period allowed for comments. Limited staff and elected officials’ time was inadequate to fully digest the 1000 plus pages of material. Thus, the comments submitted are not comprehensive and reflect those elements of the sGEIS that, for the most part, most directly affect the Town of Ithaca. Numerical notes in parentheses refer to specific sections of the sGEIS.

MUNICIPAL WATER

Of overwhelming concern to the Town of Ithaca is the threat to municipal surface water supplies. Well water in this area is often difficult to obtain in sufficient quantity and is of spotty quality. The Town is home to the three biggest municipal water supplies in Tompkins County: the City of Ithaca (Six Mile Creek), Cornell University (Fall Creek) and the Southern Cayuga Lake Intermunicipal Water Commission (aka Bolton Point), which serves the Town of Ithaca, the Town of Dryden, the Town of Lansing, the Village of Cayuga Heights and the Village of Lansing. Additional water is provided to the southern end of the Town of Ulysses. Any pollution of these water supplies would be a calamity of unparalleled proportions and no amount of remediation or compensation could replace the loss of these drinking water sources. Surface water – and the contaminants carried by it – flows downhill and therefore the entire watershed must be considered. Furthermore the rationale that the New York City and Syracuse water supplies are unfiltered and thus different is odd on its face: none of the municipal water plants are capable of filtering or otherwise removing potential contaminants resulting from gas drilling activity. Besides, the setbacks proposed for these two water supplies are not sufficiently protective. Therefore the setback provisions for drilling (7.1.12.1, Page 7-75 and 7.1.12.2 page 7-76 and Page 7-78) are wholly inadequate. Any gas industry activity within the watersheds of any municipal water supply must be prohibited.

HOME RULE

The DEC should expressly support the right of local municipalities under Home Rule to determine land use within municipal borders, including where or whether natural gas development occurs, consistent with zoning and comprehensive planning. (8.1.1) The DEC should explicitly state that if the applicant for a gas drilling permit encounters local laws, regulations and policies that are inconsistent with their proposal, the DEC will respect the municipality’s position and deny the permit. (8.1.1.5)

REGULATIONS AND THE sGEIS

New York State’s SEQRA law provides for the gathering of environmental information to inform the creation of regulations and prior to the implementation of projects. DEC’s proposal to write and perhaps promulgate regulations concurrently with the SEQRA review certainly violates the intent of the law and may invite legal challenge.

EXTRACTION AND AD VALOREM TAXES

All other states other than New York and Pennsylvania have an extraction tax of between 7% and 25%. Local municipalities (not to mention NYS) have already expended hundreds of thousands – if not millions – of dollars preparing for the expansion of the gas industry. An extraction tax of at least 12% must be imposed in order to pay for NYS’s regulation, inspection and enforcement of the gas industry and local municipalities’ costs as a result of the impact of gas drilling. The 12% tax should be evenly divided between the state and the local municipalities. The ad valorem tax should be increased to at least 8% and at least 4% go to towns, which are the level of government which must absorb most of the costs of gas drilling.

HEALTH

●The sGEIS does not require or refer to an analysis of public health impacts despite the fact that fracking-related air pollution and the potential for water contamination may have serious effects on people-especially the elderly and children – and communities downwind and downstream of proposed fracking operations. There is growing evidence of negative health impacts related to gas extraction in other states. The DEC in its sGEIS must undertake further review of fracking and the impacts of horizontal drilling to ensure that all environmental and public health impacts are mitigated or avoided.; ●As suggested by the United States Environmental Protection Agency (USEPA) in its 12/30/2009 commentary on the dSGEIS, the DEC should actively involve the NYS Department of Health in the review process. Local departments of health should also be involved. Indeed, the problems associated with shale gas development near housing have only recently been catalogued as drilling has moved into suburban locations and farming communities.

DEC STAFFING AND MANAGEMENT

●The DEC has an inherent conflict of interest since it is charged to “conserve, improve and protect New York’s natural resources and environment and to prevent, abate and control water, land and air pollution, in order to enhance the health, safety and welfare of the people of the state and their overall economic and social well-being,” but it also issues gas drilling permits which has been shown in other areas to likely harm the environment. These functions must be separated.; ●New York State DEC has been subject to steep budget and staff cuts and does not have adequate staff or resources to properly oversee fracking, even if every possible protection were in place This reality raises the possibility that the DEC will be forced to cut corners with its reviews or fast-track permits despite the risks. Therefore permitting must not take place until the DEC is fully staffed with a clear funding stream to support that staff.; ●The thousands of miles of pipelines (and compressor stations required for drilling) to get the resulting gas to market will be reviewed by a different agency under a different process. Without an accounting of such impacts, New York’s environmental assessment is incomplete and the full impact of fracking is unknown. The Public Service Commission (PSC) has jurisdiction over gas infrastructure. As such, Governor Cuomo should direct state agencies to coordinate their efforts in order to protect our air, water and communities. It should be stated explicitly in the regulations that any gathering lines not regulated by the PSC are under the jurisdiction of local municipalities (8.1.2.1, page 8-4).

CUMULATIVE IMPACTS FOR WATER WITHDRAWALS

The sGEIS addresses cumulative impacts for water withdrawals by using the pass-by flow determinations; however, the sGEIS needs to address cumulative impacts on water resources in all areas. Although the Water Resources Bill passed in 2011 would address cumulative impacts of groundwater and surface water withdrawals when and if regulations are developed, rules governing water withdrawal permits must be developed before permits are issued for drilling. Without the permitting framework for water withdrawals, it is not possible to determine if there are adequate safeguards for surface water and groundwater.

CUMULATIVE IMPACTS FOR ALL INTERCONNECTED DRILLING ACTIVITIES

In its 12/30/2009 comments USEPA suggested that analysis of cumulative impacts be “greatly expanded.” A process needs to be established to address impacts from all interconnected activities, including drilling operations, that are regulated by DEC and pipelines and compressor stations that are regulated by the Public Service Commission (PSC). An Environmental Impact Statement for the gas lines and compressor stations must be performed by the PSC to assess the cumulative impacts on water resources, community infrastructure and quality of life issues such as noise, road damage and air quality from the additional pipelines and compressor stations that will be needed to transport the gas from the thousands of individual well pads to the regional pipelines. Compressor stations will be needed, with pipelines from each well to the compressor station, and additional pipelines from the compressor station to the main transmission line. However, the sGEIS does not address the impacts of the pipelines or compressor stations necessitated by well drilling operations. The impact of the vast network of access roads, pipelines and compressor stations must be addressed by the sGEIS. The sGEIS identifies the PSC as the responsible agency to oversee construction and protection of the environment for pipeline construction. This segmentation of the environmental impact assessment makes it difficult for decision makers and the public to adequately assess the total environmental impacts anticipated from gas drilling activities.

PROGRAM TO MONITOR AND PROTECT DRINKING WATER RESOURCES

Proper monitoring and assessment strategies must be in place to protect the State’s water resources, and sufficient laboratory capabilities for analysis must be in place prior to drilling.The state currently does not have a strategy in place for data collection and analysis. Such a strategy is key to developing a comprehensive regulatory process that must be in place prior to drilling. All stakeholders (regulatory personnel, drilling companies, and the public) need to be ensured that valid data are being collected and disseminated in a cost effective manner. Considering the volume of environmental and public health data that will be generated by gas drilling, it is essential that NYS Department of Health develop and manage comprehensive databases in order to facilitate effective, comprehensive oversight and public protection during gas drilling. A program must be developed for electronic sharing of monitoring data and must be shared with local health departments as they will be the agency first contacted if any contamination is detected.

PERMIT RE-EVALUATION

The NYSDEC re-evaluation of specified permit conditions in two or three years should involve public review and comment.

OTHER LOW PERMEABILITY SHALE FORMATIONS

The scope of the sGEIS includes all low permeability shale formations where high volume hydro-fracturing gas drilling will be employed. However, many sections of the document only reference the Marcellus Shale. Environmental impacts associated with other low permeability gas reservoirs where the hydrogeochemistry is different from the Marcellus shale are not addressed in the sGEIS. The sGEIS must be expanded to include potential impacts from other formations.

LOCAL GOVERNMENT NOTIFICATION

Local Governments need to be involved and informed in all aspects of the drilling process and a procedure for this needs to be in place before drilling begins. Each municipality must receive copies of gas drilling permit applications, including parcel tax map numbers, before any permits are issued by NYSDEC. The NYSDEC should also be required to provide each local municipality and county government with 1) accurate Environmental Inspector contact information for permit coordination between agencies as well as emergency and spill response coordination, and 2) written notification to each municipality of the location of each well-plugging permit application, including tax map parcel number and mapping coordinates.

ACCIDENTS AND VIOLATION REPORTING

Currently the DEC does not have an adequate electronic record-keeping system of violations, accidents, and spills which makes aggregating problems and notifying local governments and residents so difficult as to be nearly impossible. The DEC must bring their violations reporting system into the 21st century by making them easily available to the public electronically.

PROPRIETARY CHEMICALS

●The sGEIS allows any “proprietary” chemical constituents not to be subject to public disclosure. It appears that the companies can avoid disclosure if they simply claim the additive is a “trade secret.”The DEC must require full disclosure of all chemicals and additives, including chemical composition of each, used in the hydro-fracturing process.(8.1.3.2,)

●The sGEIS only weakly suggests operators “evaluate the use of alternative fracturing additive products that pose less risk.” The DEC must require that the least toxic alternatives be used and then only if proven to not be a danger to the public and the environment.

FLOWBACK WATER DISPOSAL

○The state must not allow municipal sewage treatment plants to treat drilling wastesbecause such plants are not capable of handling the toxic elements in such wastes. (7.1.8.1); ○Some components of drilling waste would normally qualify as hazardous wasteunder state and federal law, but have been exempted from these laws. The DEC must not allow any waste that would qualify as hazardous waste in any other settings to be sent to municipal sewage treatment facilities unable to properly treat it or to disposal wells (here or in other states), putting the health and safety of our waters and communities at grave risk. (1.7.9)

MANAGEMENT OF DRILL CUTTINGS

The plan by the DEC to track the solid and liquid wastes generated in connection with fracking is positive; however tracking of these wastes is said to be the responsibility of the gas industry operators. The DEC must take a more active role in tracking waste that in other settings qualifies as hazardous. The gas industry must not be allowed to oversee itself in this area.(1.7.10)

COMMUNITY AND SOCIOECONOMIC IMPACTS

●The DEC needs to do a comprehensive, focused plan to review and analyze the consequences of a full build out of many wells on a community. (1.7.15)

●A monetary value must be assigned to potential degradation of the environment in a comprehensive review of community and environmental impacts from drilling.

●As proposed, the DEC staff will review the well applications one at a time, without considering the impact of many wells being permitted in close proximity. Impacts on communities must be considered from the standpoint of multiple wells being introduced to an area not one at a time since the industry profits from a high drilling density within an area.

●In its considerations of the economics of drilling, the DEC and the State must acknowledge that:

○Relatively few local jobs will be produced by the gas companies. Many of the higher paying jobs associated with HVHF go to employees who are residents of other states and will not be paying state income taxes. Likewise, most of the technical field jobs go to transient workers with no social or other connection to the local community. The experience in other communities has demonstrated an increase in crime, local housing costs, and a strain on health care resources (see Sayre Health report).

○Small businesses will face higher labor costs as a result of competing with wages paid by the gas companies in order to keep their employees on the job

●The sGEIS is incomplete because it does not yet contain the socio-economic analysis of whether there is a balance between risk/reward.

PUBLIC WATER SYSTEMS

Primary and Principal Aquifers

Prohibit HVHF near all primary aquifers. The DEC is proposing to prohibit fracking in primary aquifers that serve as public drinking water supplies, but this “prohibition” is only limited to a couple of years after which the state could “reconsider” the bans. In addition, the DEC does not lay out the conditions under which “reconsideration” would be reviewed. The DEC needs to prohibit HVHF near all primary aquifers. 2.4.4.1

Sunset date for buffers

The preliminary draft proposes to place some areas of the state off limits to gas drilling, but upon closer examination, many of the restrictions have sunset dates and some of the protective buffers only call for site-specific individual environmental review, rather than clear restrictions. The DEC needs to strengthen and clarify restrictions and the requirements for buffers and site-specific environmental review.

Mapping of aquifers is Inadequate.

In order to determine a 500 foot buffer to a principal aquifer, the aquifer must be mapped at least to the scale of 1:24,000 feet but many aquifers are only mapped at the 1:250,000 foot scale. The DEC must increase buffer requirements overall but particularly when mapping of the aquifers is inadequate. Part of the fee structure for permitting should go to funding better maps of aquifers throughout the state.

NATURALLY OCCURRING RADIOACTIVE MATERIALS (NORM)

According to James W. Ring, Professor Emeritus of nuclear physics from Hamilton College, the draft sGEIS does not include adequate study of radon in its review of issues. This is a subject which deserves further study before supplies of Marcellus gas are delivered to households where it may endanger the health of citizens. (4.6)

ROAD SPREADING

The DEC has already failed to protect NY drinking water by allowing produced water from PA to be spread on roads in New York State, within Tompkins County, without SEQR review. Road spreading of produced water and brine must be expressly prohibited. (5.13.3.4)

IMPOUNDMENTS

Given the recent history of “100 year rains” occurring every few years and the inherent long-term instability of impoundments, only closed-loop systems for all hydrofracking operations must be permitted. (8.2.2.2)

ROAD PERMITS

The DEC must require, not merely encourage, gas companies to make road use agreements with local municipalities. (8.1.1.4)

COMPULSORY INTEGRATION

New York State is one of the few states to allow compulsory integration and possibly the only one to allow it against individual homeowners. NYS must rescind compulsory integration to respect the rights of its homeowners.

NO ACTION ALTERNATIVE

Based on the sGEIS analysis the No Action Alternative is the preferred outcome. Given the clear dangers to the environment and public health of high volume hydraulic fracturing using the current technologies, the lack of significant financial gain for the overwhelming majority of the citizens of New York State and the assured decades-long damage to the way of life of those residing in the gas-drilling regions, the No Action Alternative is the logical and proper finding resulting from this SEQRA study. (9.1)

END

Filed under DEC Tagged with hydrofracking, SGEIS, town of Ithaca

Fracking regulations: DEC’s latest script produces high drama at Binghamton Forum | Press & Sun-Bulletin | pressconnects.com

November 18, 2011 1 Comment

Fracking regulations: DEC’s latest script produces high drama at Binghamton Forum | Press & Sun-Bulletin | pressconnects.com.

Fracking regulations: DEC’s latest script produces high drama at Binghamton Forum

8:56 PM, Nov. 17, 2011 |

60 Comments

Purchase Image

The Department of Environmental Conservation holds a hearing on its proposed guidelines for hydraulic fracturing Thursday afternoon at The Forum in downtown Binghamton. / CASEY STAFF/ Staff Photo

Written by

Steve Reilly

BINGHAMTON — It was the perfect setting for the Southern Tier’s longest-running drama.

In Binghamton’s downtown Forum theater Thursday, two hopelessly divided sides took center stage in a region at the crux of New York’s naturalgas drilling debate.

And, predictably, voices were raised and fingers were wiggled when the estimated 1,050 people began voicing their opinions on the state Department of EnvironmentalConservation’s proposed regulations for hydraulic fracturing.

This was the second of four hearings DEC will hold this month to take public comments on its proposed regulations. After the close of the public comment period Dec. 12, the agency is expected to consider relevant feedback as it creates the final draft of the regulations before issuing permits to drill wells as soon as sometime next year.

During the first of two three-hour sessions Thursday, 63 people spoke, divided almost evenly between the two sides of the drilling discussion.

The comments — limited to three minutes each — drew lively reactions from a vocal crowd, which met the speakers with applause, boos, and the wiggling fingers and crossed arms popularized by the Occupy Wall Street protests.

Drilling advocates expressed frustration with DEC’s three-and-a-half year moratorium on hydraulic fracturing. Meanwhile, opponents urged further study.

Assemblywoman Donna Lupardo, D-Endwell, the leadoff speaker, expressed concerns about drilling in floodplains. Still, she was one of the few who straddled the fence.

“It’s obvious that many people are frustrated with the pace of the review process,” she said. “Some want to speed it up, some want to slow it down.”

Both sides shared grievances with DEC’s revised draft of the Generic Environmental Impact Statement, a 1,500-page document that lays out the agency’s regulatory groundwork for high-volume, hydraulic fracturing — a technique used to unleash gas trapped deep inside rock formations like the Marcellus Shale.

Sarah Eckel, policy director for Citizens Campaign for theEnvironment, called for a ban on treatment of hydrofracking wastewater in municipal sewage treatment plants.

“There’s no plan for waste disposal for fracking waste in New York,” she said. “We can track it and know where it’s going, but we have no plan.”

Others, like Tioga County resident Ron Dougherty, said onerous environmental restrictions in the SGEIS and a proposed prohibition of drilling on some state lands will push drilling companies and jobs out of the state.

“These barriers go against the New York State energy plan and will deprive New York of a source of long-term reliable energy and long-term tax growth,” Dougherty said.

Advocates of drilling echoed a common refrain: the three-and-a-half year moratorium on hydrofracking in New York has gone on too long.

“These drilling opponents will never be satisfied,” said Julie Scott, a landowner from the Town of Barker. “Their tactic is to delay, delay, delay until it is too late. Please don’t let this happen.”

Not surprisingly, perhaps, those concerned with the state’s movement toward natural gas drilling said the delays are necessary because of perceived inadequacies in the regulatory framework.

Wes Gillingham, program director for Catskill Mountainkeeper, said the SGEIS presents an “erroneous analysis” of the environmental risks of hydraulic fracturing and includes other oversights, including failing to ban the storage of wastewater in open pits.

“This is outrageous,” he said to standing applause. “We want that document thrown out.”

While the crowd was mostly civil, at least four people were escorted out of the theater — two of whom attempted to unfurl a large protest banner, which violated the facility’s rules.

Speakers were urged to focus their statements on the SGEIS, but many comments veered toward appraisals of whether drilling should take place in New York.

“Waste disposal and earthquakes alone are two insurmountable problems,” said Chenango County resident Kim Michaels. “Natural gas drilling in New York needs to be banned.”

“This is a limited time offer,” said John Cuomo, a Tioga County landowner and consultant. “Gas companies will not invest their resources where the regulatory environment is full of requirements and restrictions. Drilling opponents will never be satisfied.”

Comments of elected officials, who were allowed to speak first, took up the initial half-hour of the early hearing.

Assemblywoman Barbara Lifton, D-Ithaca, drew cheers for urging the DEC to withdraw the document and referring to the portion of the document dealing with socioeconomic impacts as a “cut-and-paste job from industry press releases.”

A common pro-drilling argument — that gas drilling could be a source of much-needed job growth in the Southern Tier — came from Broome County Legislator Steve Herz.

“I submit that with the good and reasonable regulations that DEC has put together, and the leases the landowners have formulated, the natural gas industry will provide the funding to create what we need,” Herz said.

The public hearing was the second of four that will be held by DEC this month, and the only one in the Southern Tier, a region has drawn strong interest from natural gas companies for its position atop an energy-rich swath of the Marcellus Shale.

The crowd remained equally boisterous in the second three-hour portion of the meeting, but some of the reaction took a different twist.

“Our natural resources that we have here with natural gas have brought our country closer than ever to achieving energy independence,” said Scott Kurkoski, attorney for the Joint Landowners Coalition of New York, whose comments elicited a strong reaction from both sides. “It’s time to move forward. Three-and-a-half years is enough.”

Fingers were wiggled at the comments of Brendan Woodruff, hydrofracking campaign organizer for the New York Public Interest Research Group.

“The revised SGEIS does not include an adequate assessment of cumulative impacts, including public heath impacts and proper disposal of the toxic and possibly radioactive wastewater,” Woodruff said. “You have opted to fast-track the process instead of … undertaking a full environmental review.”

Filed under DEC Tagged with Binghamton, DEC, NY, SGEIS

N.Y. has to really study gas drilling impact – Times Union

November 15, 2011

N.Y. has to really study gas drilling impact – Times Union.

By Robert Howarth and Larysa Dyrszka, Commentary

Updated 07:57 a.m., Tuesday, November 15, 2011

When Gov. Andrew Cuomo said he would let science and health concerns drive his decision about issuing permits for hydraulic fracturing natural gas wells, we were encouraged. When we read the draft Supplemental Generic Environmental Impact Statement prepared by the state Department of Environmental Conservation, however, that encouragement evaporated.

We are part of a group of physicians and scientists with expertise in public health, engineering and environmental risk assessment and a keen interest in hydrofracking. We have come together as Physicians, Scientists and Engineers for Healthy Energy (http://www.psehealthyenergy.org). From the many problems with the environmental impact statement — both with what it contains, and what is left out — there clearly is need for far greater study before the state begins issuing permits that can affect the long-term health and well-being of New Yorkers.

We are frankly stunned by the absence of any serious health impact assessment in the SGEIS. The state rejected a call by the federal Environmental Protection Agency that the Health Department be named a co-lead agency to ensure that human health implications of hydrofracking get their proper attention. It is not encouraging that Health Department officials told members of a special state advisory committee they had not performed specific public health impact analyses, and did not plan to do so until hydrofracking began.

To say that this is putting the cart before the horse is an understatement. As Dr. Thomas Schaeffer of the American Academy of Pediatrics District II office in Albany noted, “Children are far more susceptible to environmental toxins, since they absorb and metabolize toxins at a higher rate for their body mass.”

The SGEIS mentions many of the toxic chemicals used in hydrofracking, but makes no attempt to evaluate the kinds of health consequences that have already shown up in other states where shale gas drilling is taking place. It is an established scientific fact that exposure to these chemicals in early life, as well as the air pollution generated by hydrofracking, is associated with preterm birth, asthma and lowered IQ in children, and higher risks of heart attack, breast cancer and diabetes in adults.

How could the state even think of proceeding based on a document that does not consider these health impacts?

The state’s promise to exempt the New York City and Syracuse watersheds raises questions about whether this is a political rather than a science-based decision. The state argues that those two cities do not filter water supplies, while other municipal water systems do.

But the SGEIS does not analyze in any depth the ability of existing drinking water filtrations systems to process and remove the toxic effluent, or flowback, from hydrofracking processes. Current filtration systems, many based on a century-old design, are designed to remove pathogens and will not provide adequate protection against toxic substances that enter the watershed.

And the SGEIS recognizes that there will likely be accidents, and that hydrofracking can lead to water contamination with toxic substances.

If the risk from hydrofracking is too high for the watersheds of New York City and Syracuse, then it is too high for any watershed in the state.

We urge New Yorkers to attend the public hearings beginning Wednesday in Dansville and continuing later in Binghamton, Loch Sheldrake and New York City. Tell the DEC and the governor that the rush to issue permits before knowing the health implications cannot stand.

It is a matter of life and health.

Robert Howarth is the David R. Atkinson professor of ecology and environmental biology at Cornell University. Dr. Larysa Dyrszka is a pediatrician.

Filed under DEC, Health Tagged with health impacts, hydrofracking, NY, SGEIS

Hydrofracking opinions count – Times Union

November 15, 2011

Hydrofracking opinions count – Times Union.

Hydrofracking opinions count

People are talking about hydrofracking. I hear snippets of conversation wherever I go. The fact that hydrofracking is on people’s minds is a good thing. That’s about the only good thing.

The Supplemental Generic Environmental Impact Statement on High Volume Horizontal Hydraulic Fracturing cannot protect New York from the negative environmental impacts of natural gas development. Here are a few flaws in the statement and original draft study:

(1.) The focus at this point has been on the effects of one well-pad. We need a full-out comprehensive study on the impacts of thousands of wells on our air, water, soil, ecosystems and communities.

(2.) The watersheds of New York City and Syracuse have been protected by a ban on drilling. What about all of the other New York residents whose water tables are at risk?

(3.) The statement fails to adequately address the anticipated disposal of millions of gallons of drilling waste.

(4.) Natural gas development cannot happen without the construction of a pipeline delivery system and compressor stations that can have long-term toxic air emissions.

(5.) Already stressed regulatory staffing and resources are not addressed.

We cannot allow hydraulic fracturing gas drilling to take place in our state. Many of us feel ineffective, but we can still make a difference. Read the impact statement at the Department of Environmental Conservation website (http://www.dec.ny.gov/). Submit comments there or send them in writing to: NYS DEC, 625 Broadway, Albany, NY 12233-6510, Attention: dsGEIS comments. Comments will be accepted until Dec. 12.

Virginia Boyle Traver

Chairwoman, Sierra Club Hudson-Mohawk Group

Albany

Filed under DEC Tagged with hydrofracking, NY, SGEIS