SENECA LAKE—The Seneca Lake Pure WatersAssociation has submitted its concerns and recommendations to the New York State Department of Environmental Conservation about high volume hydraulic fracturing. In its letter, the association identified eight areas of concern on which they will provide more detailed analysis to the DEC by the December 12, 2011 deadline for public comments. The purpose of this initial list is to get these concerns to the DEC early. The following are areas of concern: • Rate/location of issued permits should be controlled to protect high risk areas. • Protection of human health should engage the full capabilities of the NYS Department of Health. • Drinking water supplies should be fully protected. • The draft Supplemental Generic Environmental Impact Statement (dSGEIS) should describe an environmentally acceptable system for the disposal of all toxic/hazardous wastes from the HVHF process.
• Full regulations should be in place before any permits are issued. • Cumulative impact assessment of assumed number of wells in each region needs to be completed for the regions selected. • The Pennsylvania experience data should be analyzed statistically to determine high risk steps in the process. • Fiscal responsibility should be detailed. The group wants the same protection for watersheds currently included in the DEC’s draft; drilling would be prohibited only within the New York City and Syracuse watersheds. The letter also says buffer zones around drinking water sources should be expanded so that horizontal drilling will not go under the drinking water sources. SLPWA also called for the DEC to await the results from Environmental Protection Agency research which is underway on the environmental impact of such drilling. Additionally, the EPA is planning to establish rules for the disposal of waste water from HVHF. The pure waters association says that by proceeding with the issuance of permits before the federal studies and regulations are established, New York state could find itself out of compliance with federal regulations. The association’s website at http://www.senecalake.org/ has current information regarding its activities.