CITIZEN POWER ALLIANCE

November 1, 2009
Bureau of Oil & Gas Regulation
NYSDEC Division of Mineral Resources
625 Broadway
Third Floor
Albany, NY 12233-6500

Attn: dSGEIS Comments

Advocates for Springfield is a group of about 235 individuals concerned with land uses in the Town of Springfield, Otsego County, New York. We have been following the drafting of a supplemental generic environmental impact statement for the expansion of gas drilling in New York State. Approximately 12% of our town’s land area has recently been leased for drilling to exploration companies. This activity concerns us greatly as we anticipate many environmental issues that will affect our community and fear that the DEC is failing to perform its regulatory responsibilities to protect us.

Our specific comments/questions about the draft SGEIS are attached.

It is our belief that the draft fails in many respects to take the required hard look at the proposed horizontal drilling and expanded use of hydraulic fracturing. Community impacts are swept under the rug as too subjective to analyze; cumulative impacts are not fully discussed; there is no clear path for citizen participation in reviewing those well sites that fall within sensitive areas; and much of the opposing discussion of the dangers of hydraulic fracturing are summarily dismissed as “anecdotal.”

Our most critical concern is the likely contamination of our water. This precious commodity is more valuable than natural gas. Without water, we would be unable to live in our town. The risk of contamination of surface water or aquifers is significant in our limestone area. We cannot understand why the DEC did not recommend “no drilling” zones to include most of our town.

We are also concerned about the financial cost of damage to our roads. After reading the draft, we believe that we can anticipate such damage. There is no proposed mitigation other than each town must address this concern by itself. This seems rather cumbersome and we believe a more regional approach is required.

We are disappointed that the DEC has failed to evaluate all the risks and environmental impacts associated with hydraulic fracturing and horizontal drilling. Until the DEC performs a responsible evaluation and establishes thorough controls, we strongly request that this activity be banned in our town and throughout the state of New York.

We close by repeating the DEC’s own words: “...it is less expensive to prevent pollution than pay for remediation of environmental problems, health care costs, and lawsuit expenses" (draft SGEIS Appendix 2).

Sincerely yours,
Harry Levine
President