In its Executive Summary of the revised SGEIS released yesterday, the DEC states clearly that groundwater is at sufficient risk from gas drilling to restrict gas drilling to protect those drinking groundwater. But they only afford that protection to those drinking from primary aquifers. The DEC leaves the great majority of drinkers of groundwater in the Marcellus unprotected. They have some explaining to do.
I’m looking forward to hearing the DEC’s logic and science—their risk assessment strategy— used to assess that only some drinkers of contaminated groundwater need protection.
Primary aquifers are used as drinking water for some municipalities.
The list is on on page 5: http://www.dec.ny.gov/docs/water_pdf/togs213.pdf
The list includes about 300,000 people in those municipalities drinking water from these primary aquifers in counties in the Marcellus shale. (see attached spreadsheet and chart at bottom.)
Page 18 of the new DEC doc describes the exclusion of primary aquifers. It’s pasted below, bold face added.
No HVHF Operations on Primary Aquifers
Although not subject to Filtration Avoidance Determinations, 18 other aquifers in the State of New York have been identified by the New York State Department of Health as highly productive aquifers presently utilized as sources of water supply by major municipal water supply systems and are designated as “primary aquifers.” Because these aquifers are the primary source of drinking water for many public drinking water supplies, the Department recommends in this dSGEIS that site disturbance relating to HVHF operations should not be permitted there either or in a protective 500-foot buffer area around them. Horizontal extraction of gas resources underneath Primary Aquifers from well pads located outside this area would not significantly impact this valuable water resource.
- http://www.dec.ny.gov/docs/administration_pdf/execsumsgeis072011.pdfAs the DEC says, this is in addition to the exclusion of drilling in the watersheds of NYC and Syracuse.
Now, one can make an argument, as the DEC has, that the exclusion of drilling in the NYC and Syracuse water supplies is based on their being unfiltered surface water (as opposed to ground water), with a risk of “turbidity” from surface drilling activity. And because there have been rules in place for years restricting industry and development in unfiltered surface watersheds to avoid having to build super-expensive filtration plants, as for NYC. A more clear eyed assessment of carving out the NYC watershed is that the DEC wants to excise the political opposition of NYC, which could easily create a critical mass of opposition in the state. But they do have the surface water “turbidity” argument to fall back on to explain this preferential exclusion, even if politics is the underlying reason.
But when you are dealing with groundwater sources, how can you rationally and scientifically exclude some aquifers and not others? Again, the actual rationale appears overtly political, rather than based on the science or risk. The DEC is trying to carve out the opposition of the municipalities drinking from primary aquifers—including Jamestown, Elmira, Cortland, Binghamton, Corning, Salamanca. After all, these municipalities are really organized entities of people…….. who would otherwise likely oppose drilling.
Problem is, there are at least 1,140,000 people drinking groundwater in the Marcellus shale. What’s up, DEC? You’ve determined that groundwater is at risk. You’re going to protect 300,000 people from ground water pollution, but not the other 840,000.
Who are those people? Hello, it’s us, the people of rural NY State who will be drinking from polluted wells. It’s us, people who will not be receiving equal protection against the very threats that the DEC assesses are too risky for the people of upstate municipalities.
I think I’m going to call my lawyer.
Ken Jaffe, MD
Slope Farms
Meredith, NY
www.slopefarms.com
county percent of population drinking groundwater county population population drinking groundwater population drinking groundwater from primary aquifer population drinking groundwater not from primary aquifer name of primary aquifer Cortland 100 49,336 49,336 39,000 10,336 Cortland-
Homer-
PrebleChenango 95 50,477 47,953 47,953 Tioga 90 51,125 46,013 46,013 Waverly-
OwegoCattaraugus 90 80,317 72,285 72,285 Salamanca Allegany 85 48,946 41,604 41,604 Steuben 80 98,990 79,192 49,000 30,192 Corning-Cohocton Broome 80 200,600 160,480 110,000 50,480 Endicott-
Johnson
CitySchuyler 80 18,343 14,674 14,674 Madison 75 73,442 55,082 55,082 Otsego 75 62,259 46,694 46,694 Chemung 70 88,830 62,181 50,000 12,181 Elmira Yates 60 25,348 15,209 15,209 Genesee 60 60,079 36,047 36,047 Wyoming 55 42,155 23,185 23,185 Chautauqua 50 134,905 67,453 52,000 15,453 Jamestown Seneca 30 35,251 10,575 10,575 Ontario 25 107,931 26,983 26,983 Cayuga 25 80,026 20,007 20,007 Albany 20 304,204 60,841 60,841 Tompkins 15 101,564 15,235 15,235 Onondaga 15 467,026 70,054 70,054 Monroe 10 744,344 74,434 74,434 Erie 5 919,040 45,952 45,952 Totals 3,844,538 1,141,468 300,000 841,468
Source material
http://www.dec.ny.gov/lands/36164.html
http://www.dec.ny.gov/docs/water_pdf/305bgrndw10.pdf
http://www.dec.ny.gov/energy/46381.html
http://www.dec.ny.gov/docs/water_pdf/togs213.pdf
notes
- incomplete DEC data on primary aquifer in Cattaraugus and Tioga Counties may underestimate those drinking from primary aquifer by up to 50,000; this could raise the total using primary aquifers to about 350,000
- incomplete DEC data on total users of ground water does not include Delaware and Sullivan Counties; this could raise the total users of unprotected groundwater to about 950,000
Tags: aquifer, primary aquifer, revised SGEIS, unequal protection
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