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December 18, 2012 Attn: Draft HVHF Regulations Comments New York State Department of Environmental Conservation 625 Broadway Albany, NY 12233-6510 Re: Lack of Protections for Aquifers Revised Proposed Express Terms 6 NYCRR 560.4 (a) (3) Summary: The proposed 500 foot setback of a HVHF from a Primary Aquifer and the exclusion of protections for Principal Aquifers are devoid of any scientific basis. They are both arbitrary and will be detrimental to the health and safety of New Yorkers. Proposed Protections for Aquifers "560.4 Setbacks (a) No well pad or portion of a well pad may be located: (3) within a primary aquifer and a 500-foot buffer from the boundary of a primary aquifer;” Setback Inadequate 500 foot buffer - There are no scientific studies of methane migration to definitively conclude that 500 feet would be adequate to prevent an aquifer from being gassed. On the contrary, the only scientific studies indicate a setback of a kilometer would be appropriate.1 http://www.scribd.com/doc/65577477/How-Gas-Wells-Leak http://www.scribd.com/doc/65704543/Casing-Leaks http://www.scribd.com/doc/73405864/Anomaly-in-the-Duke-Methane-Study http://www.scribd.com/doc/97207776/Ground-Water-Impacts-of-Gas-Wells http://www.scribd.com/doc/88489724/Horizontal-Well-Leaks
Indeed, there are no industry papers to indicate that gas wells are not prone to vent methane into groundwater – and there are well services sold to attempt to mitigate that problem: http://www.scribd.com/doc/76174462/Schlumberger-Gas-Leak-Study http://www.scribd.com/doc/80574646/Well-Failures There are a few papers that seek to deny or obfuscate the problem that gas wells vent into groundwater as they age, but none of them are peer reviewed, and all them are tendentious. http://www.scribd.com/doc/73405864/Anomaly-in-the-Duke-Methane-Study http://www.scribd.com/doc/71819754/Water-Contamination-From-Gas-Drilling http://www.scribd.com/doc/96519252/Cabot-Groundwater-Methane-Hoax http://blog.shaleshockmedia.org/2012/12/03/mit-frackademics/
No protections for Principal Aquifers There is no exclusion and no setback in the proposed regulations for “Principal Aquifers,” which provide drinking water for much of Upstate. 2 Despite repeated assertions that the regulations would be “based on science” there is no scientific evidence advanced to conclude that Principal Aquifers do not merit the same protections afforded Primary Aquifers, indeed the only science involved in this distinction appears to be political science.3 Indeed, the disparate treatment of Principal Aquifers is willfully devoid of science.4
Setback determination “(b) All distances noted above are measured from the closest edge of the well pad.” Commentary: "Well pad" does not include ancillary equipment, storage areas, pits and roads: "(30) 'well pad' shall mean the area directly disturbed during drilling and operation of a gas well."'
http://blog.shaleshockmedia.org/2012/12/05/fracking-unprotected/ http://www.scribd.com/doc/66390117/The-Political-Science-of-the-SGEIS http://blog.shaleshockmedia.org/2012/12/02/no-science-involved/
Those ancillary facilities are included in a "well site : (31) 'well site' shall mean the well pad and access roads, equipment storage and staging areas, vehicle turnarounds, and any other areas directly impacted by activities involving a well subject to this Part.”
In sum, Primary Aquifers are inadequately protected by an insufficient setback of HVHF drilling. And Principal Aquifers are completely unprotected from HVHF industrialization. No HVHF should be issued near Primary Aquifers until an appropriate setback is determined based on science. And Principal Aquifers should be afforded equal protection.
James L. Northrup 17 River Street Cooperstown, NY 13326