December 27, 2011
Mr. Joseph Martens, Commissioner
Department of Environmental Conservation
625 Broadway
Albany, NY 12233-1011
Dear Commissioner Martens:
I was pleased to read that the Department of Environmental Conservation has asked Ecology & Environment (E&E) to expand its study of the socioeconomic impacts that hydrofracking will have on New York State. As you know, many of us think that the E&E report included in the Revised Draft SGEIS is more than “a little thin”. Along with two other economists, I recently sent you a letter detailing some of its flaws including:
A failure to identify all the costs and benefits that shale gas extraction will entail.
A failure to clearly identify all the winners and losers who will be impacted by fracking.
A failure to consider all the phases of shale gas extraction - from the activities of landsmen and leasing, up to and including the build out of transmission systems, including compressor stations and pipelines, that may seize land by eminent domain.
A failure to consider the cumulative effect of an industrial activity that could radically transform much of the western part of the state.
A failure to consider the long term effect that shale gas extraction will have on New York State. (The E&E study does not look beyond the period supposed to be required to extract the gas.)
A failure to consider worst case scenarios.
The absence of common oil and gas industry discounted cash flow analysis.
A failure to fully account for environmental costs, and the loss of “next best use” of the land that will be industrialized by the gas extraction.
The use of inappropriate economic models, and a sole reliance on input/output analysis.
The use of arbitrary estimates of how local labor will replace transient labor.
An assumption that shale wells will produce for thirty years, which does not seem to be grounded in reality.
A vague and undeveloped description of how shale gas extraction will impact real estate values.
A failure to consider the fact that proximity to gas wells might violate conventional home mortgages and make it impossible to refinance homes, or to obtain home insurance.
The losses that will be incurred by other industries, including tourism, outdoor recreation and agriculture, are not quantified.
Tax revenue estimates appear to be based on overstated gas production estimates and an overestimate of New York’s recoverable shale gas reserves.
Adjustment costs, such as the estimated $226 million it will cost to build out the DEC are completely ignored.
The NYS Department of Transportation estimate that infrastructure improvements and repairs will cost hundreds of millions of dollars a year is ignored.
The cost of mitigating environmental damage is ignored.
The cost of mitigating adverse health impacts is ignored.
The costs to local communities for increased demands on first responders, law enforcement and medical services are ignored.
A “one size fits all” approach to the impact that shale gas extraction will have on communities ignores the actual impacts that might be felt by some communities.
Clearly New York State should not move forward with shale gas extraction until these many defects have been addressed by a thorough and competent socioeconomic analysis. It is equally clear that such an analysis will be very different than the E&E study in the Draft SGEIS. A satisfactory assessment may require the input of experts beyond those available at E&E.
We believe the public must be permitted to read and comment upon the revised socioeconomic report before its findings are incorporated into a final version of the SGEIS. Because of the potential impact on the Revised Draft SGEIS, the SGEIS comment period should be extended until after the expanded report is released. We ask that when the Department receives the expanded report from E&E it release it to the public, and commence a public comment period of not less than ninety days.
Sincerely,
Jannette Barth, Ph.D.
Catskill Citizens for Safe Energy
[other signatories]
CC: The Honorable Andrew Cuomo
Deputy Commissioner Eugene Leff
January 7, 2012
Riverkeeper, the organization I lead, is devoted to protecting the Hudson River and the drinking water supply for nine million New Yorkers. We originally engaged with this issue to protect New York City's drinking water, but the risks go far beyond one watershed, even one so important it serves the nation's largest city.
The risks posed by hydrofracking are dead serious. Those YouTube clips that show people lighting their drinking water on fire? They're not isolated cases: Duke University recently proved that drinking water wells near hydrofracking sites have 17 times more methane than wells not located near fracking. Fracking operations have generated billions of gallons of radiation-laced toxic wastewater that we can't manage properly and forced families to abandon their homes because of dangerous levels of arsenic, benzene and toluene in their blood. Fracking's caused earthquakes in Ohio and Oklahoma, ozone in Wyoming that out-smogs L.A. and a 200% increase in childhood asthma in parts of Texas. A top federal scientist admits we just don't know enough about all the different ways fracking can make us sick.
Given this parade of horribles, it's no surprise that environmentalists aren't alone in warning against New York's rush to frack -- dozens of counties and towns in the Empire State have imposed moratoriums or bans on fracking. It's also no surprise that only 13% of New Yorkers polled by Quinnipiac Collegebelieve that fracking is safe for the environment. Yet, the frackers are still icing champagne, in anticipation of a thumbs-up later this year. They know that a whopping 30% of all New Yorkers are so worried about the economy they want fracking to happen whether or not it's safe for the environment.
You've got to wonder what those folks would say if they knew that fracking has so many drawbacks it would leave New York in worse economic shape, not better.
Road maintenance alone will cost communities up to $375 million, according to a draft report by the state Department of Transportation, since each well generates about 4,000 extra heavy truck trips. Many local officials and businesspeople warn that fracking will erode New York's all-important tourism sector, by "creating an industrial landscape that far outlives the profitability of gas extraction." Studies show that drill-friendly communities do worse than others in personal income, employment growth, economic diversity, educational attainment, and ability to attract investment. Then there are the risks to private property and real estate. Several major national lenders refuse to grant mortgages to homeowners with gas leases; fracking puts as much as $670 billion in secondary mortgage debt at risk.
What's truly scary is that state officials have ignored all this evidence about hydrofracking's potential to ruin our economy. The state did prepare an "Economic Assessment Report" on fracking, with the help of a consultant. But, it appears that the consultant was asked to study only the economic benefits of fracking, as the report spends a scant seven pages dismissing concerns about fracking's negative economic impact, in terms so superficial they'd make a booster blush, while devoting 250 pages to fracking's supposed benefits.
New York is one of the few states yet to give in to the frackers. That could change within months -- unless Gov. Andrew Cuomo pays heed to the tens of thousands of his constituents who have already spoken out against fracking, and the tens of thousands more who are expected to do so before the public comment period closes Jan. 11.
If Gov. Cuomo does give fracking the green light, watch out. The drillers are going to have one hell of a party, and we New Yorkers will end up with the hangover. However, if our famously rational governor thinks this one through, he can avoid disaster. The facts show that hydrofracking doesn't just destroy air and water quality, undermine community character and make people sick. Fracking would also do serious harm to New York's economy. Net-net, fracking is simply a bad bet.
No question that America needs a sustainable energy plan, but fracking is neither safe nor sustainable nor good for the economy. Those who say it is are selling snake oil, not natural gas.
http://www.huffingtonpost.com/paul-gallay/fracking-environment_b_1186998.html