And another critique:

“AD 44 KIngs County Assemblyman Brennan’s A08748 is a remodeled version of Brennan’s earlier A01322.

“A08748 would provide Jim Crow environmentalism… separate and unequal protection.

“Under the provisions of Brennan’s A08748, the waters of the Catskill/Delaware Watershed, which was colonized by and for the disproportionately politically powerful New York City, would be exclusively and absolutely protected from Halliburton’s high pressure chemical hydrofracking process; while the air, water and soil, that all the far less powerful individuals throughout the Southern Tier of New York State depend upon for their health and well being, would be relentlessly assaulted by that same process that Brennan clearly understands can’t ever be safe… no matter how it is done, nor who is watching it while it is done.

“Fact is, the DEC hasn’t regulated gas drilling. The drillers manage, monitor and investigate themselves… on the corporate honor system. Even if all the smoke surrounding Brennan’s bill were to remain, if it were passed without any amendments, it would then be just the soot of empty promises. The thoroughly corporate compromised Albany government would never allow the DEC to have sufficient staff to effectively protect our environment from corporate short-term profit based practices. Brennan’s bill only serves to aid the DEC in regulating and neutralizing dissent.

“The goal of Brennan’s bill is for New York City to be able to continue to drink reliably pure water, while the entire Southern Tier (outside the Catskill/Delaware Watershed) is inexorably Iraqified to provide stone gas for New York City to burn.

“New York City should use its enormously disproportionate power within New York State to protect the water of all New Yorkers — everywhere within this state — by providing state legislation banning the stone gas extraction Halliburton horizontal hydrofracking everywhere within New York State.

“In interpreting provision 2 of 23-2901 of Brennan’s bill,
’2. Natural gas drilling shall not be permitted within the watershed of the Delaware River, in any recharge area of a sole  source  aquifer,  in any  area  where  groundwater contributes a significant  base flow to surface water sources of drinking water, and in any other area where the department shall find presents a significant threat of  hydraulic  fracturing compounds entering into a significant source of drinking water’
it’s important to first grasp the meaning of the last sentence of the first paragraph of Section 1 (its **INTENT** clause):

“‘Legislative intent. 1. The legislature finds that the process used to stimulate natural gas extraction referred to as hydraulic fracturing utilizes components that are often toxic, that are non-biodegradable, and that are virtually impossible to remove once they enter the natural environment. Thus, they pose such a high level of environmental risk that the policy of the state must be to insure [sic] they are excluded from any area that is significant for public drinking water resources or any other area that is environmentally sensitive.’

“a) The intent of Brennan’s bill is clearly to protect special people’s places only, while corporate invaders are allowed to occupy and exploit those of other people, who are not so special. Every provision of the bill must be interpreted in that light. It’s easy to enforce a complete and absolute ban on drilling within a specific area special to special people. It will not be possible for the DEC to ever actually protect the health and well being of all those not so special people, at hazard from the thousands of stone gas drilling sites industry desired over the vast area in which the Halliburton process would still be allowed by the Brennan bill.

“b) Note the interesting ambiguity of that provision 2, of 23-2901 of Brennan’s bill, which you quoted. It’s just one sentence, using commas… not semicolons. Is it intended as a list of different places? That should use semicolons. The 1st clause is independent. The other 3 that follow might be fully dependent (embedded or subordinate to the 1st clause: i.e. related to the watershed of the Delaware River)… which a contextual reading of that bill (and a knowledge of its precursor) implies. But let us be generous, and assume that each clause in that sentence does refer to discretely different situations. The first (“watershed of the Delaware River”) is quite explicit. The others are vague and subject to proofs necessarily provided by those targeted for drilling… proofs that places where their water comes from are “significant” “public” and “environmentally sensitive” too. Even without knowing the history of this bill, it is obvious that its goal is an absolute ban for protection for New York City’s water supply, while allowing for as much stone gas drilling as possible outside the watershed that New York City is dependent upon. The recent inclusion of “sole source aquifers” is merely an act of political expedience, cynically calculated to gain support for the bill in those few population areas within the Marcellus formation region, that are supplied by the already designated sole source aquifers (see map):  http://www.epa.gov/Region2/water/aquifer/

“c) Note that the one and only river mentioned anywhere in Brennan’s bill, which its 12 sponsors deem worthy of mention to be worthy of any particular protection within all of New York State, is the Delaware River (the river upon which New York City is greatly dependent, and near which river a great number of relatively affluent New York City residents have 2nd homes). Why doesn’t Brennan’s bill also specifically call for the same protection within the watersheds of any of the other rivers in New York State, like the Susquehanna, or the Genesee? Why doesn’t it call for the same protection for the watersheds of **ALL** the rivers within New York State? Why doesn’t it call for the same protection of **ALL** watersheds and **ALL** wells within New York State? The reason is clear. It’s a bill designed to absolutely protect the water of those having more political power, while allowing the air, water and soil of those not having as much political power to be jeopardized by the hazard of the Halliburton process… while ignoring the reality that the strong share the same environment as the weak… that what is done to the weak will some day eventually affect the strong too.

“d) Note that the qualifier “significant” is used 3 times in that one sentence of the Brennan bill that you quoted. Who will actually be deciding who and what is significant?

“Consider the first complete sentence in the NYS Constitution’s Article 1 (Bill of Rights) Section 11:  ‘No person shall be denied the equal protection of the laws of this state or any subdivision thereof.’”

David J. Cyr
Delhi, NY
GPNYS SC member – Delaware County

see also pdf:  brennan-a8748-merits-and-demerits1

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One take:

“Section 23-2901. The watershed of the Susquehanna River should be
included. I don’t trust the DEC to make meaningful “determinations”.
One overriding problem with the bill, as written, is that it does not provide
for important judgments, determinations, findings, etc to be made by
reputable, independent experts. Proving responsibility for contamination
is difficult unless, as a condition to issuance of the permit, the driller
has been required to test wells of all property owners within a spacing unit
and deliver results to DEC and to the property owners. Spills should not
only be reported to DEC but also to representatives of local government i.e.
Town Supervisors. Sanctions should be imposed not only if driller refuses to
clean up but also if it FAILS to do so within a specified time frame.
“In a timely and appropriate manner” is far too vague! Why limit the felony to
surface waters?

“Section 23-2903. All components of frack materials MUST be disclosed to
DEC and to local authorities — end of discussion. Nothing less than full
public disclosure should be considered. The cloak of confidentiality
under any circumstances is dangerous to the public health, hampers appropriate
local response and frankly the “proprietary” information argument is a
crock. They should not be permitted to invoke the law to hide behind
their mistakes. This is the weakest part of the bill. I don’t think that DEC
should be the sole arbiter of “establishing a standard for the composition of
hydraulic fracturing compounds. They are too cozy with the drillers.
Liquid waste should also be prohibited from being disposed of in dry
wells.

“Section 23-2905. Drillers are responsible for mitigating environmental
damage but in accordance with what standards and with what kind of
independent oversight? They ought to be financially responsible but the
actual mitigation should be done by an independent, reputable company
with no ties to the industry. Hooray. I like the part about state lands.
Again, applications for permits will require an “assessment” of impacts.
Whose assessment? Surely, we should not be prepared to accept the driller’s
assessment or that of any industry “consultant.”

“Section 23-2907. DEC should have more than the authority to impose fees.
This law should establish a superfund to be funded by the industry and by
permitting fees etc. Restoration should specifically include reforestation
and restoration of soil so the land can again be used for agricultural
purposes — if that’s even possible! The restrictions on lighting are
pathetic. In a rural area, the lights can be seen for miles. Enforcement of
noise, lighting and all safety issues should be permitted at the local
level. It is silly to think that the DEC has the manpower and resources
to monitor these operations on any kind of regular basis. Local
enforcement is key to protection of the public health and safety. The right of
rescission on a lease is a joke as long as the law fails to address the
point at which the clock starts to tick. It should be measured from the
date that the landowner receives a fully-executed original of the lease
document and not before. As for the other protections for lease
transactions–see my memo. This section requires a great deal more
specificity. Indeed, some of these provisions should apply retroactively.

“Section 23-2909. Again, monitoring and enforcement should be local.

“Section 23-2911. Providing for unannounced inspections and actually
carrying them out are two entirely different issues. The DEC is woefully
understaffed and underfunded. Adding more responsibilities will only
look good on paper unless the tools are there to carry out the intentions.
Again, this is why local government should be permitted to play a role.
“Periodic inspections” – This too is a joke — Periodic could mean once
in every blue moon.

“Section 23-2913. Measurement of production must be fool-proof. Treat it
like gas pumps at the filling station. Taxes must be direct and must
benefit the localities.

“The major flaw with this bill is that it continues to see the State DEC
as the only player — that is, besides the industry — not really an even
match. The sponsors fail to accept that drilling is also very much a
local issue that strains local resources. Local officials must have a role.
Finally, the advisory committee should be given some power. Other
members should include chemists, physicians, geologists, and the county
supervisor of each county where a certain threshold of drilling is taking place.”

Jane Welsh, P.C.
Hamilton, NY 13346


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