From: Podr

Date: June 30, 2010

Page 1 of 3

To: New York State Governor David A. Patterson, N.Y.S. Assembly Speaker Sheldon Silver, N.Y.S. Senator Antoine Thompson, N.Y.S. Senator John Sampson, N.Y.S. Senator Malcolm Smith. Regarding: Please enact the proposed Englebright / Addabbo two-year moratorium on high-volume, slick water hydraulic fracture drilling for natural gas (S.07592 /A.10490).

Dear New York State Senator Valesky and New York State Policymakers, In recent months, debates about allowing high-volume slick water hydraulic fracture drilling for natural gas AKA 'hydro-fracking' in New York State have often become highly emotionally charged. However, for a decision this serious, we also need facts. Nationally, hydro-fracking accidents reported by news media over recent years indicate a potential for cumulative health and safety risks. In New York State, toxicologist Walter Hang reviewed conventional gas drilling accident data from NYS Department of Environmental Conservation (NYS DEC) accident data since 1980, also finding safety and health concerns (Hang 2009). For ourselves and for the world, New York State should ask, 'Wait a minute, let's think this over'. Many scientists agree on a lack of comprehensive and scientific review regarding hydro-fracking technology's impacts, despite a decade of widespread deployment in several U.S. states (Legere 2010, Howarth 2010). Many existing shale gas drilling studies seem biased and compartmentalized, ignoring social, environmental and economic linkage. The U.S. Environmental Protection Agency (US EPA) critiqued NYS DEC's currently proposed hydrofracking regulations as failing to consider cumulative impacts, including public health (dSGEIS, 2009, EPA 2009). In Texas, Colorado and Wyoming, air quality studies found intensive hydro-fracking increased regional nitrogen oxides, volatile organic compounds and ozone levels beyond U.S. Clean Air Act limits, increasing smog and acid rain, risking health and agriculture (Armendariz 2009, Bar-Ilan et al 2008, and Fox 2009). In Canadian rural areas, a 2007 scientific study found gas drilling generates carcinogenic benzene, and advised further studying oil and gas drilling impacts on rural air quality (Burstyn et al 2007). Cornell bio-geochemist Robert Howarth is currently reviewing hydro-fracking life-cycle greenhouse gas (GHG) emissions. Howarths preliminary findings suggest GHG emissions from hydro-fracking may compare with GHG from mountaintop coal mining (2010). The rationale for hydro-fracking emerges as our society is challenged by energy and climate planning. In Winning the Oil End Game, energy expert Amory Lovins estimates the U.S. can profitably reduce at least half our natural gas consumption through conservation, efficiency and renewable energy (2004: pg.19). Throughout New York State, citizen groups and experts in conservation, renewable energy and ecology are addressing our energy challenge and creating new economies. However, the hydraulic fracturing allowed under the DEC dSGEIS could divert local community resources away from true energy independence and climate adaptation. Our communities are best focused on preparing for climate change and peak oil, rather than cleaning up disasters. Could hydro-fracking sabotage our progress in sustainability and public health? Some scholars ask if hydro-frackings long-term yields indicate an un-sustainable energy choice. Shale gas analyses by Dr. Charles Hall at SUNY-ESF in Syracuse, Syracuse University geology graduate Bryan Sell, Canadian geologist David Hughes and petroleum geologist Arthur Berman predict potential steady declines in Energy Returns on Energy Invested (EROEI), and significantly lower overall yields within a decade (Hall 2009, Hughes 2009, Sell 2009 and Berman 2010).

From: Podr

Date: June 30, 2010

Page 2 of 3

Even from a short-term 'purely' economic viewpoint, maintaining infrastructure for hydrofracking operations under NYS DEC's proposed guidelines may cost state and municipalities more than the economic and tax benefits derived. Drilling companies seem likely to externalize costs to maximize profits wherever possible; potentially increasing Cost of Community Services (COCS). COCS including road maintenance, fire protection, local hospitals and other emergency services, water and air quality control, and legal fees are likely borne by municipal and state taxes (AFT 2007). For example, after six years of intensive gas drilling, the state of Arkansas recently estimated road repairs at $218.7 million dollars, seven times the accrued Arkansas state revenue from gas severance tax (Oman 2010). Moreover, New Yorks farms could be adversely impacted by hydro-fracking impacts to soil, water and air. New York State can only benefit from a two-year moratorium on hydraulic fracturing. New Yorkers can participate in and learn from the pending US EPA study. Senator Valesky and N.Y. policymakers, please enact the Englebright / Addabbo Bill (S.07592 /A.10490), creating a two-year moratorium on hydraulic fracturing for allowing US EPA enough time to reasonably assess this question. Thank You, (Podr), NYS CC: Governor David A. Patterson Assembly Speaker Sheldon Silver Senator John Sampson Senator Malcolm Smith Senator Antoine Thompson

References American Farmland Trust (2007) Cost of Community Services Studies; FIC Fact Sheet and Technical Memo. American Farmland Trust; Northampton, MA. Retrieved from web-page: http://www.farmlandinfo.org/index.cfm?function=article_view&articleID=27757 Armendariz, A. (2009) Emissions from Natural Gas Production in the Barnett Shale Area. Retrieved from web-page: http://lyle.smu.edu/~aja/barnett-shale.html Bar-Ilan, A., Friesen, R., Grant, J., Pollack, A., Henderer, D., Pring, D., Sgamma, K., & Moore, T. (2008). A Comprehensive Oil and Gas Emissions Inventory for the Denver-Julesburg Basin in Colorado (presentation). US Environmental Protection Agency, 17th Annual International Emission Inventory Conference. Retrieved from web-page: http://www.epa.gov/ttnchie1/conference/ei17/index.html Berman, A. (2010) 100 Years of Natural Gas Supply from Shale? Its More Like 6 Years. Petroleum Truth Report web-log. Feb. 27, 2010 Retrieved from web-page: http://petroleumtruthreport.blogspot.com/2010/02/100-years-of-natural-gas-supply-from.html Burstyn, I., You, X., Cherry, N., & Senthilselvan, A. (2007). Determinants of airborne benzene concentrations in rural areas of western Canada. Atmospheric Environment, 41(36), 7778-7787.

From: Podr

Date: June 30, 2010

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Fox, J. (2010). Gasland [Motion picture]. United States: International WOW Company. Hall, C. PhD. (2009). Comments made during a public information meeting. Hydrofracking Information Meeting held Thursday, October 29, 2009 at May Memorial Unitarian Universalist Society, 3800 East Genesee Street, Syracuse, NY. Hang, W. (2009) Oil & Gas Spill Profiles. Toxics Targeting, Ithaca, NY. Retrieved from web-page: http://www.toxicstargeting.com/MarcellusShale/drilling_spills_profiles Howarth, R. (2010) Preliminary Assessment of the Greenhouse Gas Emissions from Natural Gas obtained by Hydraulic Fracturing. Retrieved from web-page: http://www.eeb.cornell.edu/howarth/Howarth_Energy_and_Environment.html Hughes, D. (2009) Natural Gas in North America A Panacea to Replace Foreign Oil? Capital Region Energy Forum, Albany New York. September 14, 2009. Retrieved from web-page: http://www.capitalregionenergyforum.org/archive.html Legere, L. (June 20, 2010) Growing number of scientists say not enough known about effects of drilling. Pottsville Republican. Retrieved from web-page: http://republicanherald.com/news/growing-numberof-scientists-say-not-enough-known-about-effects-of-drilling-1.855990 Lovins, A. (2004) Winning the Oil Endgame - Slide Presentation. Rocky Mountain Institute. Retrieved from web-page: http://www.oilendgame.com/ReadTheBook.html New York State Department of Environmental Conservation, Division of Mineral Resources. (NYS DEC) (2009) Draft Supplemental Generic Environmental Impact Statement on the Oil, Gas and Solution Mining Regulatory Program (dSGEIS). Retrieved from web-page: http://www.dec.ny.gov/energy/47554.html Oman, N.E. (June 3, 2010) Bad roads sprout in Fayetteville Shale. State directs gas-severance-tax revenue to repairs put at $218.7 million. Arkansas Democrat-Gazette. Retrieved from web-page: http://www.arkansasonline.com/news/2010/jun/03/bad-roads-sprout-fayetteville-shale-20100603/ Sell, B. (2009) Peak Gas and EROI: Conventional on the Upside, Unconventional and Marginal on the Downside. [presentation] 2nd International Biophysical Economics Workgroup, Oct. 16- 17, 2009. Retrieved from web-page: http://web.mac.com/biophysicalecon/iWeb/Site/BPE Conference.html U.S. Environmental Protection Agency (US EPA) (Dec. 30, 2009) Marcellus Shale Horizontal Drilling and High-Volume Hydraulic Fracturing. Review submitted to New York State Dept. of Environmental Conservation, Division of Mineral Resources. Retrieved from web-page: http://www.epa.gov/region2/spmm/r2nepa.htm#r2letters