New York state environmental regulators have not gone far enough in their investigation of the impacts of Marcellus Shale gas development, the U.S. Environmental Protection Agency (EPA) said in commenting on the draft Supplemental Generic Environmental Impact Statement (dSGEIS) prepared by the New York State Department of Environmental Conservation (NYSDEC).
"EPA believes that the analysis and discussion of cumulative and indirect impacts in the dSGEIS need to be significantly expanded," EPA told the NYSDEC in its comments.
The dSGEIS was released at the end of September and addresses the range of potential impacts of shale gas development using horizontal drilling and high-volume hydraulic fracturing and outlines safety and mitigation measures that operators would have to follow to obtain permits (see NGI, Oct. 5, 2009). Since its release, drilling interests have called for the adoption of the rules, which would allow development of the Marcellus to proceed in New York (see NGI, Dec. 21, 2009). However, environmental groups and New York City have said the rules do not go far enough (see related story).
EPA suggested that NYSDEC collaborate with the New York Public Service Commission as the latter is the agency with jurisdiction over natural gas gathering lines. "Such collaboration may also provide the opportunity to coordinate actions in order to minimize the amount of flaring of gas between the time of opening a well and the construction of gathering lines," EPA said. The agency also recommended an analysis of the "new drilling service industries that would undoubtedly result" from Marcellus Shale development.
More germane to the debate around the effects of hydraulic fracturing on drinking water, EPA also suggested that the New York State Department of Health (DOH) join NYSDEC in leading development of the State Environmental Quality Review Act (SEQRA) document. "Not only does DOH have expertise to offer on health impacts, but it was delegated primary enforcement responsibility (primacy) of the Safe Drinking Water Act by EPA," the agency noted.
While EPA said it understands that the dSGEIS -- as a supplement to a 1992 SEQRA document -- is primarily concerned with hydraulic fracturing, it said the earlier document might have become outdated over the last 17 years. "...[T]he 'existing' environment and conditions in New York state have changed sufficiently that using the information from that report as a baseline for the dSGEIS will not take into account the cumulative impacts from habitat fragmentation, population increase and climate change that may have occurred during that time," EPA said.
Echoing a recent report from New York City's Independent Budget Office (see related story), EPA said it "is particularly concerned about the potential risks associated with gas drilling activities in the New York City watershed and the reservoirs that collect drinking watter for nine million people." Should a water filtration system be made necessary by Marcellus development activity, it would cost New York taxpayers $10 billion to construction and $100 million per year to run, EPA said. "Clearly, it is in all our interests to avoid this scenario."
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