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Well Site Impacts

Well Site Impacts

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Published by: James "Chip" Northrup on Jan 04, 2013
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01/05/2013

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 January 4, 2013Attn: Draft HVHF Regulations CommentsNew York State Department of Environmental Conservation625 BroadwayAlbany, NY 12233-6510Dear Commissioner Martens,I submit the following comments on the draft HVHF regulations, but first I must protest theprocess by which these draft regulations have been released for comment before therevised SGEIS is finalized, as required by law to inform the drafting of regulations. The DEChas also placed undue burden on citizens, organizations, and municipalities to preparecomments on highly technical regulations with a minimal 30 days over the holidays,thereby squelching meaningful public participation. Due to the inherent risks to health,the environment, economies, and community character, hydrofracking must not bepermitted in New York anytime in the foreseeable future. Notwithstanding the aboveobjection, I submit the following comments relating to
well site and well pad impacts
.High-volume hydraulic fracturing is a major industrial activity involving a tremendousamount of water, toxic chemicals, trucks traffic, and noise—all of which have greatpotential to harm the environment and disrupt agricultural, business and residential useswhere drilling occurs. The scope and content of draft regulations relating to well site andwell pad activities are wholly inadequate to address these issues.
 The draft regulations fail to limit the number of well pads that may be constructedwithin a spacing unit. Although the 2011 revised draft SGEIS acknowledges that it isdesirable for wells to be concentrated on a single well pad, nothing has been stipulatedin the regulations to require this.
To limit surface impacts, the regulations shouldrequire that all wells (including infill wells) be built and drilled from a singlemulti-well pad within the spacing unit, and any future drilling to otherformations within the boundaries of the spacing unit should be required touse this same pad, once established.
 The draft regulations fail to limit the size of well pads.
The regulations shouldrequire that well pads be no more than five acres in size to limit surfaceimpacts.
 The draft regulations fail to confine all drilling and fracking related activities strictly tothe well pad. The definitions of "well pad" in 560.2(b)(30) and "well site" in 560.2(b)(31) both refer to "directly" disturbed or impacted areas, leading to ambiguousinterpretations and a potential for scattering of impacts throughout the spacing unit.
Regulations should be revised to require that
s
taging activities associatedwith drilling, including the assembly of trucks or tanks containing water andadditives, must be located in a compact formation inside the boundaries of awell pad area. Similarly all pits containing any liquid, cuttings, or othermaterial (with the exception of freshwater impoundments) should be locatedinside the boundaries of the well pad area.
 
 The draft regulations fail to require the applicant to identify and depict all areas thatcould be impacted by gas development. Section 560.3(c)(2) states that a topographicmap should be produced that depicts certain features such as tanks and pits within2,640 ft of the well, but this does not necessarily include all gas development activitiesin the spacing unit.
The regulations should be strengthened to require theidentification of all features and equipment associated with gas developmentoperations in the entire spacing unit, including but not limited to thoselisted, as well as any other chemical containers, equipment, storage, stagingareas, and water impoundments. Any transmission or processinginfrastructure, such as compressor stations and gathering lines should alsobe identified. The regulations should require that all impacts be consolidatedto the greatest extent possible to minimize impacts within the spacing unitand to surround area.
 The draft regulations fail to require the identification of all natural and human featuresthat could be impacted by gas development within the spacing unit. Section 560.3(a)"Application Requirements" requires the identification of distances between the wellpad and domestic springs, water wells, aquifers, streams, and dwelling for whichspecific setbacks apply, but does not require the identification or mapping of any otherenvironmental features. Similarly the regulations require that a list of invasive speciesfound on site be prepared along with BMPs, but does not require the identification of natural communities or wildlife, including rare and non-rare species, or BMPs regardingthem. It is not possible to ensure that environmental impacts are minimized withoutthis information.
The draft regulations should be strengthened to require theidentification and mapping of all natural and human features within thespacing unit where fracking is planned. This includes all natural surfacefeatures, including but not limited to topography, waters, wetlands, springs,floodplains, vegetation, natural communities, and wildlife. Also includedshould be all subsurface features including aquifers, karst areas, faults, andold wells. Property lines should be identified and mapped, along withexisting land uses (including agriculture) and development such as homes,schools, barns, businesses, roads, and transmission lines. All informationsupplied should be documented by certified biologists, engineers, or otherexperts as applicable and an assessment prepared to demonstrate thatadverse community, property, and environmental impacts have been avoidedor minimized. An applicant pursuing a project involving multiple well sitesand spacing units should be required to submit all of the above for the entireproject along with an assessment of impacts, direct and cumulative withinthe project area and affected by the project area. Finally the regulationshould clearly state that DEC has authority to require revisions to planssubmitted to ensure that impacts are avoided or minimized.
 The draft regulations contain no specific site requirements regarding wildlife andhabitat or the avoidance of habitat fragmentation. Although some Best ManagementPractices (BMPs) are discussed in the 2011 revised draft SGEIS as possible "permitconditions", no indication has been given regarding which, if any, of these will actuallybe required. Unlike, for example, BMPs to control invasive species, well-site BMPsrelating to wildlife, natural habitat, and fragmentation are not even referenced in thedraft regulations, suggesting that DEC has little intention of addressing these impactsor their avoidance. This also raises the question of what, if anything, can or will be

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