This action might not be possible to undo. Are you sure you want to continue?
Cuomo Governor, New York State Executive Chamber, NYS Capitol Albany, New York 12224 Commissioner Joseph Martens Department of Environmental Conservation 625 Broadway, 14th Floor Albany, NY 12233-1010
Dear Governor Cuomo and Commissioner Martens: On behalf of the Joint Landowner s Coalition of New York (JLCNY), I am writing to express our strong disappointment in Governor Cuomo’s recent comments that the release of the final draft SGEIS and the corresponding regulations will be extended beyond November 29, 2012. The JLCNY has supported and continues to support best environmental practices concerning natural gas development, but fails to see the purpose, or benefit, of yet another delay. As you have said, reliable available science and studies should guide us in a straightforward simple review of health impacts related to the proposed safeguards defined by the DEC in its SGEIS. To extend the process beyond November 29, 2012 is an insult to the tremendous efforts of your DEC experts, taxpayers and all of us who have strived diligently to contribute reliably to this over four year process. The JLCNY representing 77,000 New York landowners have been active and substantive contributors to the dialogue for careful development over the past four years. Our families and friends are physically the closest to the potential impacts of
high volume horizontal hydraulic fracturing (HVHF) and have the utmost responsibility to inform ourselves and our government about HVHF. Our self-interest is in protecting our generations-old properties, our families’ health, communities and our basic economic and property rights. Our organization has advanced numerous constructive recommendations to require better handling of produced water at the well site, to include reduced air emission “green” completions, to require repair to surface disruptions and other tangible improvements to protect community impacts. We want to ensure that New York is at the forefront of the safeguards for natural gas development. We recognize that natural gas will power our economies, lead to more affordable energy options and have positive environmental impacts on air quality and greenhouse gasses. On air emissions, states and the Federal government (US Environmental Protection Agency) have already done substantial work on health issues. For example, on April 17, 2012, the EPA issued regulations to reduce air pollution from the oil and gas industry. “A key component of the final rule is expected to yield a 95 percent reduction in VOCs (volatile organic compounds) emitted from more than 11,000 new hydraulically fractured wells each year. This significant reduction would be accomplished primarily through the use of a proven process – known as a “reduced emission completion” or “green completion” – to capture natural gas the currently escapes to the air” (EPA OVERVIEW OF FINAL AMENDMENTS TO AIR REGULATIONS FOR THE OIL AND NATURAL GAS INDUSTRY). We also refer you to important activities at the state level. In Colorado, “The EPA’s approval of the Regional Haze Plan is a ringing endorsement of a comprehensive and collaborative effort between many different groups," Colorado’s Governor John Hickenlooper said. "Colorado’s utilities, environmental community, oil and gas industry, health advocates and regulators all came together to address air quality. We embrace this success as a model for continuing to balance economic growth with wise public policy that protects community health and our environmental values.” The plan implements sweeping public health and environmental protections by reducing pollution through emissions controls, retiring coal-fired power plants and converting certain electric generating units from coal to cleaner burning natural gas. (Press Release, Office of the Governor of Colorado, September 11, 2012 http://www.colorado.gov/cs/Satellite/GovHickenlooper/CBON/1251630618478) In the JLCNY’s comprehensive comments to the SGEIS submitted in January, we recommended that the NYSDEC petition the New York State Public Service Commission to allow pipelines to be installed so that natural gas completions at well sites could be conducted as reduced emission completions.
To review air emission impacts, we would encourage turning attention to a review of existing expert studies concerning air pollution from natural gas development, such as the “City of Fort Worth Natural Gas Air Quality Study: Final Report” published July 13, 2011. This report is the most useful because it reviews an area with both a high population density and extensive natural gas development with hydraulic fracturing. Please see the attached Appendix 1 for key language from the “Conclusions and Recommendations” portion of the final report. We also recommend that you review the Health Watch by the Australian Institute of Petroleum Health Surveillance Twelfth Report from the University of Adelaide Department of Public Health. This report follows workers in the oil and gas industry for decades and compares their health and mortality with the general population. While the JLCNY works to provide constructive solutions, paid professional activists are increasingly targeting everything related to energy, even natural gas pipeline projects and elements essential to powering job creating factories, reducing school and consumer heating costs, and firing power plants to serve major load demands as called for under the Governor’s Energy Highway Blueprint just released. The activists have been offering good paying compensation packages to hire obstructionists from Long Island to Buffalo and all metro areas to halt all energy related development (see Food & Watch announcements; Appendix 2). Continued delay only empowers these paid professional activists whose goals are to stall shale gas drilling and all forms of progress to build a viable energy infrastructure. Our message is simple and clear. We respect the State’s need to be diligent in its efforts. We also recognize that it is our obligation to contribute constructively to our selfgovernment with reliable and well considered information. After four years of analysis and preparation, there is no need to be influenced by paid professional activists. Health issues associated with natural gas development have been studied. We, as neighbors to potential well sites, appreciate the need to ensure that health and safety concerns are appropriately addressed. We have actively researched scientific studies, facts, and real life development to assure the best practices are observed. The JLCNY continues to support best management practices on all aspects of natural gas development, including closed loop drilling, use of steel tanks to contain flowback, multiple pipe casings cemented to the surface, GPS units on trucks, stormwater pollution prevention plans, spill containment personnel on site, reduced emission completions, and meeting all present and future air quality regulations. Stable and affordable energy is essential for those desperately seeking a better future like seniors struggling to heat their homes, families striving to educate their children and keep them close to home, urban cities looking to produce power while reducing air
emissions, small businesses struggling to attract new consumers and growth industries looking to innovate and expand across the State. Our members listened carefully to your promise that sound science and the facts, not baseless scare tactics and politics, would govern this process. Delay beyond the November 29, 2012 despite having considered over 80,000 comments, is a breach of faith in our government and flies in the face of the promise that New York is beyond its dysfunction and truly open for new business investment. We urge you to be guided by the important existing science and evidence captured by the experts within your agencies and to proceed without further delay. Respectfully, Joint Landowners Coalition of New York, Inc.
By:_______________________________ Dan Fitzsimmons, President cc: Commissioner Shah
Appendix 1 City of Fort Worth Natural Gas Air Quality Study: Final Report July 13, 2011 Section 8 – Conclusions and Recommendations p. 8-1 “Commencing with planning activities in July 2010 and field activities in August 2010, the Fort Worth Natural Gas Air Quality Study was a multi-phase project aimed at characterizing the air quality impacts of natural gas exploration and production, determining any potential health risks associated with those impacts, quantifying the total amount of pollutants being emitted, and determining if natural gas sites were in compliance with air quality regulations. Two primary raw data collection activities were used: 1) an ambient air monitoring network, and 2) a systematic point source testing program. Point source testing data were then used to perform air dispersion modeling, and measured and modeled air concentrations were used in the public health evaluation. Each of these tasks was designed to help city officials answer the following questions: • How much air pollution is being released by natural gas exploration in Fort Worth? • Do sites comply with environmental regulation? • How do releases from these sites affect off-site air pollution levels? • Are the city’s required setbacks for these sites adequate to protect public health?” p. 8-6 “ERG conducted a health screening evaluation to evaluate the health implications of air emissions from natural gas exploration and production activity. This evaluation was based on protective health-based screening values, primarily those published by TCEQ, though consideration was also given to EPA and ATSDR values for the pollutants of greatest concern. The ambient air monitoring data revealed no siterelated pollutants with 24-hour average concentrations or program-average concentrations above TCEQ’s health-based screening levels. The modeling analysis identified three pollutants—acrolein, benzene, and formaldehyde—with estimated 1hour average or annual average concentrations above screening levels at some offsite locations. This was most prevalent for sites with multiple, large line compressor engines. However, due to the highly protective nature of the healthbased screening values, none of the estimated concentrations reached levels expected to be associated with adverse health effects.
The modeling analysis served as the basis for evaluating the adequacy of setback distances. For the overwhelming majority of sites considered in this study, the modeling results indicate that Fort Worth’s 600-foot setback distance is adequate. More specifically, for sites with no engines and for sites with smaller lift engines, no pollutants were found to have estimated 1-hour maximum or annual average concentrations above TCEQ’s applicable health-based screening levels beyond the setback distances. For the relatively few sites with multiple, large line engines, the modeling analysis found some areas beyond the setbacks to have estimated acrolein and formaldehyde concentrations greater than TCEQ’s ESLs, though not reaching concentrations expected to cause adverse health effects. For both pollutants, ERG’s modeling is based entirely on estimated emission rates, and not measured values.”
Temporary Organizers based in Long Island, Hudson Valley, Albany, Syracuse, and Rochester
Food & Water Watch is a leading national consumer advocacy organization that runs dynamic, cutting edge campaigns challenging the corporate control and abuse of our food and water resources. Working together with Frack Action and over 170 groups across the state we formed New Yorkers Against Fracking, a broad-based coalition fighting for a ban on fracking throughout New York. We are building out our organizing capacity in New York to prevent fracking in New York State and are seeking a temporary contract organizer to build capacity in the following five areas of the state: Long Island, the Hudson Valley, Albany, Syracuse, and Rochester. Each Organizer will work to develop and implement legislative, field organizing, and media strategies in support of this campaign. The Organizer represents FWW and New Yorkers Against Fracking and works as a leader in local coalitions to broaden support for our policy goals. This position runs from October through the end of the year.
• Serving as Food & Water Watch’s and New Yorkers Against Fracking’s representative in the local area as needed. • Developing localized campaign plan • Outreach to local organizations and elected officials and other grass-tops leaders • Developing and working with activists and volunteers to build support for a ban on fracking and incorporating them into Food & Water Watch’s leadership development structure • Developing and implementing organizing strategies for gathering petitions and databasing those petitions so we can contact new activists through our e-alert system • Participating in media events and other speaking engagements • Leading strategy sessions • Coordinating with Food & Water Watch and New Yorkers Against Fracking staff in New York • Electronic communication with activists on fracking • Promotion of Food & Water Watch membership at events. • Other duties as assigned
• Experience: At least one year experience in advocacy on public policy issues, and/or grassroots/field organizing. • Knowledge: Organizing, advocacy and legislative strategy techniques; familiarity New York political environment; consumer and environmental issues; working with the media. Experience and familiarity with the local area is a major plus but not required. • Skills: Excellent written and oral communication skills; strong interpersonal and planning; excellent organizational skills. Knowledge of online activism and email listservs strongly preferred. • Capabilities: Ability to think creatively and quickly to respond to legislative developments and to take advantage of breaking news; demonstrated leadership capability; ability to work
well with a wide variety of people and to coordinate diverse tasks; ability to present technical concepts to a mass audience; can-do attitude and commitment to public interest work. Work well under pressure, handle multiple tasks at once, and adapt to changing situations on a daily basis. High level of independent judgment. • Conditions: Strong interest in and commitment to promoting the goals of Food & Water Watch and New Yorkers Against Fracking. Applicant must be legally eligible to work in the United States.
This is a non-benefited temporary organizer position. Salary range $600-$800/week depending on location and experience.
How to Apply
Please send a resume, cover letter, writing sample and three references to firstname.lastname@example.org. Position open until filled. Incomplete applications will not be considered. Food & Water Watch strives for a diverse work environment and encourages women, people of color, LGBTQ individuals, and differently-abled people to apply.
This action might not be possible to undo. Are you sure you want to continue?
We've moved you to where you read on your other device.
Get the full title to continue reading from where you left off, or restart the preview.