About Submitting Comments on the SGEIS for the Marcellus Shale

Seven Key Points to Consider

Now that the New York State Department of Environmental Conservation (DEC) has completed its study of the potential environmental impacts of the drilling and the hydraulic-fracturing that is proposed to develop natural gas reserves in the Marcellus Shale formation, we are actively seeking input on the proposed measures to diminish, allay and mitigate impacts.

DEC's analysis, called the draft Supplemental Generic Environmental Impact Statement, or SGEIS, will be revised and become final after all the public comments have been received and considered, and will ultimately comprise a set of measures limiting and mitigating the impacts of the proposed gas industry activities in New York well into the future. This is a critical moment. It is also your chance to influence the environmental protections that will be in place.

You are encouraged to offer your comments and, in doing so, to consider the following:

The SGEIS is an analysis of negative environmental impacts and a statement of measures to mitigate such risks. While you are free to comment on positive impacts, such comments are not necessarily useful for the purpose at hand, which is to protect public health and the environment by understanding the risks of the subject activities.
The SGEIS itself is not an argument for or against drilling. Rather, it is a discussion of potential impacts of developing gas production from the Marcellus Shale and other low-permeability formations, as researched by geologists, engineers and environmental scientists.
Because of the wide range of topics covered, the SGEIS is a daunting 800 pages long, but there are shortcuts to get through it. If you go to the document on the DEC website you will see that it is clearly divided into chapters and subdivided into topics - focus on the issues that concern you. The website also has summary information on the basics of well drilling and hydraulic-fracturing if you wish to skip or skim the more detailed information on those processes in the SGEIS.
Don't assume you know what is in the SGEIS based on what others say - there are many mischaracterizations and much editorializing out there by both pro- and anti-drilling constituencies. Test out the credibility and thoroughness of the document with your own eyes, or at least be skeptical of outlandish claims that you may hear.
Keep in mind what is new to New York - and thus the subject of the SGEIS - and what is established already. The reason the document is referred to as a "supplement" is that there already exists an original Generic Environmental Impact Statement for oil and gas drilling in New York -- which has guided the drilling and operation of thousands of wells over the last 17 years, including the more than 13,000 wells currently operating. Hydraulic fracturing is not new. Nor is horizontal drilling. What is new is the combined use of these techniques to extract gas from deep shale layers such as the Marcellus and Utica formations in New York, and the extraordinary amounts of water and "flowback," with its attendant chemicals, that must be managed in the process.
Specific comments tend to be more useful than general comments.
Every comment submitted will be read. As part of the revision process in producing a final SGEIS, DEC will respond to the comments received in a formal "Responsiveness Summary" which will explain which comments resulted in changes in the document and which were rejected and why.

How to Provide Comments

The public comment period has been extended until December 31, 2009. The Department is offering four ways in which to submit comments. Comments may be provided at one of the scheduled public hearings. We have created an on line submission system which will allow you to write comments and tag them to your areas of concern. Attachments can also be included. You may submit e-mail comments; please include your name, e-mail or return mail address to ensure notice of the Final SGEIS when it is available. Finally, written comments should be sent to: Attn: dSGEIS Comments, Bureau of Oil & Gas Regulation, NYSDEC Division of Mineral Resources, 625 Broadway, Third Floor, Albany, NY 12233-6500.