41 Reasons to Reject the SGEIS

SUMMARY CRITIQUE OF THE DEC'S DRAFT SGEIS ON FRACKING:
41 REASONS WHY THE DEC SHOULD WITHDRAW THE DRAFT

Prepared by Sustainable Otsego, 10 November 2011 Adrian Kuzminski, Moderator

(Editor's note: this list has been expanded. Please see also: http://sustainableotsego.org/component/content/article/435-summary-critique-of-the-decs-draft-sgeis-on-fracking )

I. INADEQUATE CRITERIA OF REVIEW:
1) Failure at scoping stage to assess reasons to prohibit fracking.
2) Reliance on outdated and vastly overstated estimates of gas reserves.
3) No evaluation of gas production vis-à-vis renewable fuel production.
4) Failure to take seriously peer-reviewed studies of relevant issues.
5) Reliance on generic rather than site-specific review.
6) Traffic and infrastructure impact estimates far too low.
7) Compulsory integration a taking of property rights.

II. GLOBAL IMPACTS IGNORED:
8) No assessment of methane emissions in relation to global warming.
9) Failure of current fracking technology to contain methane emissions.

III. INADEQUATE ECONOMIC AND ENVIRONMENTAL REVIEW:
10) No assessment of cumulative impacts.
11) Inadequate assessment of economic costs and liabilities of fracking.
12) No assessment of negative impacts on other industries.
13) No assessment of effects on local services and taxpayers.
14) No assessment of effects on residential property values.
15) Potential of fault lines to transmit methane or toxic fluids ignored.
16) No assessment of risks posed by major faults lines.
17) Recent studies showing additional fault lines ignored.
18) No provision for safe dispososal of drilling wastes.
19) No systematic discussion of Utica shale.
20) Inadequate assessment of fracking impacts in Pennsylvania.

IV. HEALTH ISSUES IGNORED:
21) No public health risk assessments.
22) No specified role for the Department of Health.
23) Unequal treatment for NYC and Syracuse water sources.
24) Inability of filtration to screen out fracking toxins from water.
25) No required independent before/after water testing.
26) No guarantees that drilling can safely be done anywhere.

V. INADEQUATE DRILLING REGULATIONS:
27) 1000 foot depth limit too close to aquifers.
28) Pace of permitting and drilling uncontrolled.
29) Current fracking additives receive less scrutiny than "green" additives.
30) Recycling of drilling and fracking fluids not required.
31) $5000 bond for plugging wells insufficient protection.
32) Inadequate setbacks, especially from homes and public buildings.
33) Setbacks from municipal water sources only temporary.
34) No certification/competency program for drillers.
35) No requirement that drillers use the least toxic fracking fluids.
36) No provision for treatment facilities for plowback fluids.
37) Open pits still allowed for drilling cuttings.

VI. INADEQUACY OF DEC:
38) Conflicting missions to preserve and exploit the environment.
39) Preferential and uncritical treatment of industry sources by the DEC.
40) Failure of DEC to regulate past gas drilling.
41) Continued inability of DEC to regulate gas drilling.