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					Drilling for Natural Gas in the Marcellus Shale
NYSDEC’s Draft Supplemental Generic Environmental Impact Statement Proposed Mitigation Measures

Organization of the dSGEIS
I. Introduction II. Description of Proposed Action III. Proposed SEQR Review Process IV. Geology V. Natural Gas Development and High Volume Hydraulic Fracturing VI. Potential Environmental Impacts VII. Mitigation Measures VIII. Permit Process and Regulatory Coordination IX. Alternatives

Impacts of well drilling
• One three acre site per 40 acres or one five acre industrial site per square mile (640 acres) • 5 million gallons of water per well • Drilling 4-5 weeks per well 24 hours/day • Up to 10 wells on one pad – must be drilled within three years • 1200 or more truck trips to site per well

Tompkins County Planning Department’s Review of the dSGEIS Mitigation Section
• Mitigation Measures that would appear to be useful in addressing the potential environmental impacts if properly implemented • Mitigation Measures that are “suggested” in the dSGEIS that should be “required” • Mitigation Measures that are inadequate or not addressed

Mitigation Measures
Water Resources Floodplains Freshwater Wetlands Ecosystems and Wildlife • Air Quality • Greenhouse Gas Emissions • • • • • Centralized Flowback Water Impoundments • Naturally Occurring Radioactive Material • Visual Resources • Noise • Road Use • Community Character • Cumulative Impacts

Water Resources
• • • • Water withdrawals Stormwater runoff Surface spills Groundwater impacts • Waste transport • Flowback requirements • Fluid discharges • Solids disposal

Water Resources
• Water withdrawals regulated in the Delaware and Susquehanna River Basin • Elsewhere assure retention of 30% of average daily/monthly flow in streams • Suggests cumulative impacts could be addressed but doesn’t commit to doing so • Great Lakes Basin requires prior notice and consultation regarding consumptive withdrawals greater than 5 million gallons per day averaged over 90 days • Stormwater discharges handled under General Permit for Industrial Activity

Water Resources
• Secondary containment required for some types of on-site tanks • Flowback water handled on site must use steel tanks • EAF addendum will require additional site specific information regarding receiving tanks for flowback water • Require notification prior to surface casing cementing for all wells so that DEC “may” witness • Site specific SEQRA review for fracturing shallower than 2000 feet or less than 1000 feet below base of known aquifer

Water Resources
• Require Drilling and Production Waste Trucking Form – similar to requirements for medical waste • Setback requirements for rig fuel tanks from sensitive resources such as wells, streams, wetlands • Supplemental EIS for drilling within 1000 feet of municipal water supply and site specific SEQRA within 2000 feet • Require “evidence of diligent effort” to identify public or private water wells within ½ mile • Require pre- and posttesting of wells within 1000 or 2000 feet • County Health Departments receive well tests • Require fluid disposal plan

Water Resources
• Flowback Water and production brine may only be disposed of at public wasterwater treatment plants after analysis of capability of plant (headworks analysis) • Many issues with this as there is no way to know characteristics of wastewater until after drilling has begun • High concentration of Total Dissolved Solids may inhibit wastewater treatment processes

New York City Watershed
• Prohibition against centralized flowback water surface impoundments • Require removal of fluids from on-site tanks of reserve pits within seven days of completion of drilling/stimulation • Site specific SEQRA required within 3000 feet of a reservoir or 150 feet of a watercourse

• Require local permit for development in a floodplain • Closed loop tank system required • Centralized flowback water surface impoundments prohibited

Freshwater Wetlands
• Basically relies on existing regulatory requirements • Not clear on wetlands not currently subject to DEC regulation

Ecosystems and Wildlife
• Require site-specific and species-specific invasive species mitigation plan • Should monitor all equipment entering site • Impoundments should be constructed to be unattractive to wildlife • Does not address cumulative impacts from habitat fragmentation

Air Quality
• Extensive complex analysis of various emissions • Suggests barriers to public access within 500 feet of well pad to avoid exposure

Greenhouse Gas Emissions
• Greenhouse Gas Emissions Impacts Mitigation Plan is required but no thresholds for permissible emissions are provided • Magnitude is significant – first year emissions from one well would be double all emissions by Tompkins County government in a year

Centralized Flowback Water Impoundments
• To be regulated similar to what is required for landfill leachate • Suggests that above ground storage tanks would be preferable to impoundments but no requirement to use tanks • Site specific SEQRA within 1000’ of a reservoir; 500 feet of a stream, wetland, 300’ of a public or private well

Naturally Occurring Radioactive Material
• Significant variability expected • Sampling and analysis will be undertaken during initial development efforts to assess • Will be used to determine whether additional mitigation is necessary

Visual Resources
• Require visual impact mitigation plan that “considers” local land use policy documents • Suggests restrictions to minimize impacts but no specific requirements, e.g., regarding avoiding “uplighting” and light cast onto neighboring properties • Reclamation standards for Agricultural Districts • Outlines Bureau of Land Management reclamation standards

Visual Resources
• Visual impacts are most effectively addressed at the siting and design phase • Visual EAF Addendum “may” be required

• Noise impact mitigation plan required • Incorporate “to the extent practical” local land use policy documents • Includes description of mitigation measures but does not require specific measures

Road Use
• Operators should “attempt to obtain a road use agreement with the municipality or document the reasons for not obtaining one.” • Process for notifying municipalities limited to first well in a town • Thereafter up to municipality to monitor

Community Character
• Applicant must “attest” to having reviewed existing comprehensive, open space and/or agricultural plans or similar policy documents

Cumulative Impacts
• Chapter 6 – Potential Environmental Impacts, states: “any limitation on development, aside from the mitigation measure discussed in the next chapter, is more appropriately considered in the context of policy making, primarily at the local level, outside of the SGEIS.”

Preliminary Conclusions
• On at least some topics the dSGEIS presents a thorough technical analysis • Implementation, enforcement and monitoring mechanisms are often unclear • dSGEIS is ambiguous and sometimes confusing regarding what will actually be required and local government role

Preliminary Conclusions
• Relies heavily on industry information and self-policing • Includes unfunded State mandate for County Health Departments • Totally inadequate consideration of cumulative impacts