On January 11 Otsego 2000 submitted comments to the DEC on the 2013 Draft Regulations on hydrofracking. See the full comments here (15.9MB file)
The comments outline major issues with the regulations, which were not developed after consideration of the final SGEIS and the 2011 draft SGEIS public comments.
Other major concerns include:
- A failure to integrate SEQRA into the regulations; further, the proposed regulations do not include all of the mitigation measures developed through SEQRA.
- A failure to consider the regulatory impacts of the proposed regulations, as required by the State Administrative Procedure Act.
- The proposed regulations would have significant and unmitigated impacts on the water quality, air quality, community character, historic assets and economy of Otsego County.
- The proposed regulations lack input from the Department of Health on the public health impacts of high volume hydraulic fracturing.
- The DEC continues to offer unequal protection under the law, treating upstate New York citizens differently from New York City and Syracuse citizens, offering more rigorous protections for the New York City and Syracuse watersheds.
- The DEC lacks information about the cost of the regulations and lacks the staff to enforce them.
- The established water usage threshold to determine what is hydraulic fracturing is set arbitrarily.
- There are a range of unaddressed problems with the proposed setbacks for well pad development and subsurface drilling.
- Many of the chemicals used in hydraulic fracturing may be significant public health risks, yet the proposed regulations do not ban any of the chemical additives, including those already known to be harmful.
Otsego 2000 requests that the DEC revise the proposed regulations.