Marcellus Shale Drilling
Natural gas accounts for approximately 20 percent of our domestic energy supply. It burns cleaner than coal, producing about half the amount of harmful emissions for the same amount of energy. Interest in increasing natural gas supplies from New York reserves has amplified recently and resulted in the review of existing rules and regulations. The New York State Department of Environmental Conservation (NYSDEC) has written a Supplemental Generic Environmental Impact Statement (SGEIS) built upon the previously written Generic EIS (1992) and existing information. While the NYSDEC currently has only a few dozen applications for horizontal drilling, it is expected that thousands of new wells will be developed if and when new regulations are put into place. Most of this development would occur across the southern tier of the state. Development of this magnitude has the potential to change the face of the landscape in an area where residents and visitors alike value its beauty and recreational opportunities. These activities will also place enormous pressure on natural resources, such as water, and on the fish and wildlife dependent on aquatic resources and terrestrial habitats. It is essential that the SGEIS recognize the scope of the potential impacts and develop regulations to minimize them to the greatest extent practicable.
The issues that we believe are most important for fish and wildlife are habitat loss, habitat fragmentation and degradation, the introduction of invasive species, mortality from construction and chemical exposure, disturbance from noise, construction, truck traffic, and lighting, and water associated impacts. This would include water use and withdrawal, change in surface water quality and quantity, surface flows, potential for spills and contamination of groundwater, and the proper treatment and disposal of drilling fluids, including water and associated drilling chemicals. We believe it is critical to adequately address these issues in the SGEIS and prevent impacts from occurring by implementing protective regulations.
|Hydrofracking involves injecting 3 to 9 million gallons of water and chemicals into deep wells to break up underground shale and create microscopic pathways for natural gas to escape. Natural gas and some of the drilling fluids are retrieved upon completion of the well. Water used in drilling is usually found in nearby waterbodies such as rivers, streams and lakes. However, some of these waterbodies may be adversely affected by water withdrawal, especially during summer and periods of low flow. Impacts associated with water withdrawals include entrainment of fish eggs and small aquatic organisms, loss of habitat due to lower water levels, as well as temperature and dissolved oxygen extremes.
The well flowback fluid contains mostly water and sand mixed with various chemicals, some of which are considered industrial waste, according to the NYSDEC. Flowback water may also contain metals and Naturally Occurring Radioactive Materials (NORMS) found in the Marcellus formation. Draft regulations issued last year by the NYSDEC require companies to have a plan for disposing of the wastewater. But it is not clear what specifically will be approved in the plans. Options identified by the NYSDEC include use of injection wells to store the contaminated water underground, take it to municipal sewage treatment plants or haul it out of state to industrial treatment plants. Currently, the DEC leaves it up to companies to choose the best way.
Wastewater can be extremely saline and have as much as five times more salt than the ocean. It may also contain high levels of total dissolved solids, which are microscopic minerals and organic materials dissolved in the water. Most municipal sewage treatment plants are not equipped to handle the levels of salinity or total dissolved solids found in flowback water. Both salt and dissolved solids can kill bacteria that the municipal sewage plants use to break down sewage, harming the effectiveness of the treatment. If high levels of dissolved solids pass through sewage plants to streams and rivers, they can kill aquatic life and degrade ecosystems.
The larger drill rigs typically used for hydrofracking have greater amounts of lighting associated with them. We did not see information in the SGEIS regarding the potential impact this lighting may have on wildlife. There is potential for migratory birds to be attracted to and/or disoriented by the lighting during night migration. Nocturnal animals could be affected as well.
A baseline evaluation of plant communities (to species level) would be required for each well site to prevent the spread of invasive species. The document acknowledges that water withdrawals can transfer aquatic invasive species and that screens may reduce the transfer, but there is no specific requirement for the size of the screening, type of screening, or that it is used in all cases. Equipment can be a major carrier of seeds and individual organisms, but there is no suggestion for cleaning equipment prior to moving it from one site to another. We have recommended to NYSDEC that a requirement be added that all equipment be cleaned prior to transport to a new site.
Habitat fragmentation could be one of the greatest impacts associated with Marcellus gas development in New York State. The required infrastructure includes well pads, construction areas, sedimentation ponds, and compressor stations. However, the many linear features, such as roads, gathering lines, pipelines, water lines, and electric transmission lines have the potential to greatly fragment existing habitats. Fragmentation of large habitat blocks into smaller ones may be harmful to some wildlife. Habitat fragmentation is detrimental to area-sensitive species, can promote nest parasitism and predation, and facilitate generalist species and potentially invasive species. Our concern stems from the current condition of an already fragmented landscape, and we believe it is important to limit additional loss of large blocks of habitat. To limit the amount of fragmentation, proposed infrastructure should be required to be placed within existing utility right-of-way corridors including roads, transmission lines, and pipelines. If this is not feasible, any proposed linear infrastructure (i.e. electric lines, water lines, and pipelines) should be placed within the right-of-way of new access roads. This collocation of utilities and infrastructure will reduce the potential “spider web” effect which has occurred at drilling sites in other states (Pennsylvania and Colorado).
We believe proper planning and review should take place prior to well drilling approval. Several federal laws enacted to protect fish and wildlife, such as the Endangered Species Act (87 Stat. 884, as amended; 16 U.S.C. 1531 et seq.), Bald and Golden Eagle Protection Act (16 U.S.C. 668‑668d) and the Migratory Bird Treaty Act (40 Stat. 755; 16 U.S.C. 703-712) may come into play depending upon the resources potentially affected by natural gas development activities. The U.S. Fish and Wildlife Service (Service) will continue to work with the NYSDEC and other agencies to lessen any potential impacts to fish and wildlife.
View the Service's comments on the NYSDEC's Draft Supplemental Generic Environmental Impact Statement concerning natural gas drilling and proposed regulations.
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