NORTHRUP

Senator Avella 504 Legislative Office Building Albany, New York 12247 Dear Senator Avella: Thank you for hosting a public forum on fracking. Although I will be unable to attend, I would like for the following comments to be entered into the record. The Cuomo Administration has failed to protect the people of New York from the hazards of shale gas industrialization. It has done so by systematically ignoring the hazards of horizontal shale drilling and consistently overstating the benefits. In this, it parrots the gas industry an industry that has poor credibility in the scientific community, that has orchestrated financial scandals of epic proportions, and that has systematically bought off politicians and regulatory agencies. In short, the Cuomo Administration has sold the state out to the gas cartel for nothing - gas production is notoriously tax-exempt in New York: http://www.scribd.com/doc/63145742/New-York-State-GasProduction-Tax The DECs boilerplate SGEIS is a case study in how that sellout has played out in Albany. Most of my critique of the SGEIS can be found at this website: http://www.sourcewatch.org/index.php?title=DSGEIS_Responses Here are a few salient points: 1. A measure of gas well regulations is their protection for the built environment. In that regard, the DECs proposed setbacks for gas wells in are the worst of any setback provisions in the United States. http://www.scribd.com/doc/72545747/Worst-Fracking-Regs

2. There is considerable risk for gas wells to leak gas into groundwater. Horizontal wells are four (4) times more prone to leak than vertical wells. The DEC goes out of its way to ignore the growing body of science on this problem. And proposes no viable solutions. http://www.scribd.com/doc/65577477/How-Gas-Wells-Leak 3. The DECs failure to protect the built environment or drinking water is a powerful argument for a state-wide ban, and, failing that, for local land use ordinances via the exercise of home rule. http://www.scribd.com/doc/63141534/New-York-Gas-Well-Zoning 4. There is no rush to permit horizontal shale wells this decade in New York. There is no economic incentive to do so because shale gas is uneconomic at current and projected prices. http://www.scribd.com/doc/71446252/New-York-Shale-GasFrackonomics Shale gas exploration offers no economic benefits at this time in New York - even with the financial chicanery of the gas exploration companies. http://www.scribd.com/doc/88281876/The-Shale-GameFrackonomics-5-0 The DEC went out of its way to ignore the underlying economics of shale gas exploration, overstating the benefits by 5 x. http://www.scribd.com/doc/65070417/SGEIS-Socioeconomic-HypeVoodoo-Frackonomics-2-0 5. There is no safe, economic way to dispose of fracking flowback in New York. Some of the methods allowed in New York treatment in municipal wastewater plants are illegal in other states. Spreading flowback on rural roads is likewise illegal in other states. http://www.scribd.com/doc/65435029/SGEIS-Fracking-Flowback

6. The SGEIS grossly understated the seismic risks associated with fracking. This oversight was not lost on the USGS: http://www.scribd.com/doc/83492110/USGS-Letter-to-DEC http://www.scribd.com/doc/81397215/Fracking-New-York-Faults 7. The DEC is not capable of regulating horizontal shale gas industrialization. Indeed, the DEC has never adequately regulated oil and gas drilling: http://www.scribd.com/doc/76085928/Worst-Practices-at-the-DEC I request that you do everything in your power to ban horizontal hydrofracking of shale in New York until it can be done safely. Respectfully submitted,

James L. Northrup Cooperstown