A must-read Hurley water fracking setbacks testimony EXCERPT FROM ---- Testimony Carter H. Strickland Commissioner, New York City Department of Environmental Protection Committee on Environmental Conservation The Assembly of the State of New York October 6, 2011 Buffer Areas The draft SGEIS requires additional studies within a buffer area extending 1,000 feet from aqueducts. In that buffer area, drillers would need to conduct a site-specific analysis to identify whether drilling poses significant adverse environmental effects. If any potential effects are identified, the driller would need to initiate a full environmental impact study before drilling could be approved. DEC has offered assurances that it will not approve drilling near the City’s aqueducts unless the City is satisfied with a study’s results, but neither the SGEIS nor the proposed rules formalize that process. Another significant concern is over the measurement of the setback or buffer distance. Horizontal drilling adds a new complication to traditional regulatory setbacks. An illustrative graphic is attached to my testimony. It shows that where the setback is measured from the well pad, as specified in the draft SGEIS, then horizontal drilling may occur directly beneath critical infrastructure, effectively eliminating any protective buffer. DEP has recommended and will continue to recommend that the setback be measured from the end of the nearest horizontal drill leg to the tunnel or other structure or even to the edge of the spacing unit. That measuring standard ensures that, at a minimum, the buffer distance is maintained. Let me explain why this is a concern. Many of our aqueducts pass outside of the watershed. A well pad could be located just outside the 1,000 foot buffer proposed in the SGEIS, and yet a horizontal drill leg could extend well more than 1,000 feet towards our aqueduct. In fact, horizontal drill legs have been extended over 3,000 feet when extracting natural gas, and the constantly evolving technology is likely to result in even longer horizontal drill legs. Our reservoir dams are all at the edge of the watershed and therefore have 4,000 feet of setback protection under the SGEIS. But if a horizontal drill leg were to extend 4,000 feet past a well pad, then hydrofracking could occur directly underneath a dam. Full commments --- nyc.gov/html/dep/html/testimony/hydrofracking_revised_eis_10062011.shtml
Posted on: Tue, 20 Aug 2013 15:00:37 +0000