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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 Air Pollution Protections Revised Proposed Express Terms 6 NYCRR 556.2 (a) & (b) Summary The proposed regulations allow a gas well to be vented for up to 7 days or more. Given the lack of setback protections in 560.4 that would effectively gas most nearby buildings, livestock and people with raw, unprocessed natural gas. It hardly represents a green completion.

Part 556, Operating Practices

The venting of noxious gases at the well site is not adequately addressed. More often that not, waste gases - which contain radon, etc. are vented at the well bore, not necessarily flared. 556.2 allows either venting or flaring for a cumulative period of one hundred and sixty eight (168) hours, or more. The proposed regulations would allow gas wells to vent raw gas for up to 48 hours after completion, plus 48 hours after stimulation (fracking), and 48 hours (workover), plus 24 hours test, plus more escaped gas "used in any operational requirements. That equates to 48 after completion + 48 after fracking + 48 hours after workover + 24 hours after a test = 168 hours cumulative or seven (7) days of venting raw gas, plus an indeterminate length for "any operational requirements" which could mean any operation involved in bringing the well online. Given the lack of setbacks proposed in 560.4, this should be sufficient to gas school children, cattle, etc., that, per 560.4, could be immediately adjacent to the well.

This is simply unacceptable in terms of local air pollution and from a greenhouse gas standpoint. "Subdivisions (a) and (b) of Section 556.2 are amended to read: (a) The operating practice requirements of subdivisions (b) through [(d)] (g) of this section shall be applicable only to gas wells. The last line is essentially a loophole to allow unregulated venting of oil wells that may produce waste gas as a byproduct which is not uncommon. Venting and flaring standards should be applied to all oil and gas wells. (b) No gas from any gas well, except such as is produced in a clean-up period not to exceed 48 hours after any completion or stimulation operation or workover , plus that used for the controlled testing of the well's potential in a period not to exceed 24 hours, plus that used in any operational requirements, shall be permitted to escape into the air. Pollution from gas wells is laced with toxic chemicals.1 Flaring the raw gas can compound air pollution.2 And is debilitating to nearby properties.3 Conversely, there is no requirement in the regulations to flare the wells can be vented, maximizing greenhouse gases. Most land uses are not protected by setbacks in the proposed regulations from gas wells.4 Allowing such venting or flaring of raw gas in proximity to unprotected uses is grossly irresponsible. No raw gas should be allowed to escape from the well. All gas should be captured at the wellhead and taken to a processing facility. Completions should be green or no permits issued.

James L. Northrup 17 River Street Cooperstown, NY 13326 withfigures.pdf 2 3 4