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Oil and gas companies are eager to use unconventional, resource intensive drilling methods to recover natural gas from shale deposits in New York State. The State released draft regulations to permit this drilling. CCE is working to protect drinking water, public health, and habitat for fish and wildlife as part of any proposal to use high-volume hydraulic fracturing (hydro-fracking) of the Marcellus and Utica Shale formations.
New York relies upon natural gas for 24% of its energy supply. New York’s natural gas demand is primarily met through sources from the Gulf Coast and Canada. New York State sits atop one of the largest shale formations in the United States, which contains large deposits of natural gas. This formation is called the Marcellus Shale. Additionally, New York has other shale formations, including the Utica Shale formation. Oil and gas companies propose to recover natural gas in the Marcellus and Utica Shales by combining hydraulic fracturing of the shale with horizontal gas drilling wells.

What is High Volume Hydro Fracturing?
Large deposits of natural gas are estimated to be located deep within the Marcellus shale formation. The natural gas is trapped in pockets, or veins, where the shale naturally fractured during settling. It is more commercially viable to extract Marcellus Shale through high volume hydro-fracking. Hydraulic fracturing is a process of fracturing rock in order to release the natural gas from isolated veins within the shale formation. The fractured rock is kept open using a “proppant” typically composed of sand or other chemicals. High-volume hydraulic fracturing is named because it uses millions of gallons of water per well. In order to capture a commercially viable amount of gas from the Marcellus shale formation the well is drilled vertically to approximately 500 feet above the formation and then the wellbore is turned horizontal to tap all the tiny pockets and veins of gas in the shale. In Pennsylvania a typical horizontal wellbore is 4,500 feet.
According to the DEC there are four primary differences between horizontal drilling and vertical drilling: 1) larger rigs with longer per well drilling time; 2) a higher likelihood of multi-well pads; 3) Using drilling mud rather than air to cool and power the drill; 4) the volume of rock cuttings associated with high volume hydro-fracking.
In July 2008 Governor Paterson signed the well-spacing law which allows for multiple wells to be drilled off of one well-pad. Because multiple wells can be drilled off the well-pad there will be a larger acreage of disturbance during the drilling and during production. During drilling a single well would disturb approximately 3 acres of land and during production where there is partial reclamation there would be 1.5 acres disturbed. For a multi-well pad there 5 acres of land is disturbed and during production it is 3 acres. Because there are multiple wells they have to be spaced further apart so in a X square mile area for single wells there would be 160 pads and for multiple wells there would be 10. Multi-well pads are an attractive solution to minimize land disturbance for natural gas drilling. The drawback is in the concentration of waste generated during the drilling process. Multi-well pads tend to have six wells per pad so the waste generated by a high-volume hydraulic fracturing process is quite substantive.
Drilling mud is used by horizontal, or directional, drilling to cool and power the drill. Drilling mud can be 1) water-based; 2) potassium-chloride/polymer-based with a mineral oil lubricant; or 3) synthetic oil-based. After the drilling occurs the well is fractured. For high-volume hydro-fracking for Marcellus shale a process known as slickwater fracking is proposed. According to the industry it is 98% freshwater, and according to the DEC there are 12 classes of additives proposed to be included: 1) the proppant; 2) acid; 3) breaker; 4) bactericide/biocide; 5) clay stabilizer; 6) corrosion inhibitor; 7) crosslinker; 8) friction reducer; 9) gelling agent; 10) iron control; 11) scale inhibitor; 12) surfactant. These additives are comprised of a variety of chemicals and many of them are toxic. Even though they are only 2% of the solution for slickwater fracking, the problem is compounded by the fact that this is multiplied by millions of gallons.
Rock cuttings from a vertical well to 7,000 feet would be approximately 125 cubic yards and for horizontal wells drilled to the same depth with a 3,000 foot lateral would be 165 cubic yards. These cuttings are stored temporarily on-site in an open, lined storage pit and then disposed of as hazardous waste.
What is Marcellus & Utica Shale?
Named for the exposed outcrop in Marcellus, NY, Marcellus Shale is a large deposit of black shale and is characterized by being very rich in unoxidized carbon. Marcellus Shale covers most of New York State and ranges in depths down to 7,000 feet below the surface and is included in most of the Appalachia. The larger Marcellus shale formation becomes thinner as it moves from East to West and is named for an exposed outcrop in Marcellus, NY. Utica Shale is deposited broadly across the Appalachian Basin and into Ontario, Canada. In New York there is an outcrop along the west and southeast sides of the Adirondack Mountains, and is also exposed along the northern Allegany Plateau. It ranges in depths to over 9,000 feet in the Southern portion of the state. One of the characteristics that is common with black shale is that it contains trace levels of uranium. The concentration of this uranium at the surface, on drilling equipment, and in combination with drilling muds, fracking fluid, and other elements exposed in the process of drilling is the primary cause for concern with exposing this shale. The proper disposal of these cuttings, worker exposure, and the potential contamination from open on-site storage must be adequately addressed and present significant environmental and public health challenges.
Potential Issues & Impacts from High Volume Hydraulic Fracturing
Using High volume hydro-fracking techniques to extract natural gas and other natural resources comes with inherent risks to quality and quantity of drinking water and surface water. CCE supports rigorous environmental review, public involvement, and full disclosure of the risk to our environment and public health.
CCE is advocating that regulators considering permitting natural gas drilling with high volume hydro-fracking must:
- Ban drilling in sensitive watersheds including, but not limited to, sole-source aquifers and unfiltered drinking water supplies.
- Recognize and enforce the ban, passed by Congress and the NYS Legislature in 2008, on interbasin transfers between the Great Lakes and other watersheds and require the return of treated water to the source watershed.
- Ensure increased coordination between critical state agencies to protect the public heath and our environment while allowing permitted natural gas extraction to be efficiently delivered to market. The NYS Public Service Commission is responsible for pipeline siting and traditionally pipelines are sited following a successful well. CCE is specifically concerned with unnecessary "flaring" of natural gas until the pipeline siting process is complete. This inefficient and wasteful process will result in the release of unnecessary quantities of greenhouse gas emissions. New York needs a comprehensive, transparent, publicly accountable approach to permitting wells and siting pipelines.
- Establish a Community/Water Protection Fund. A dedicated fund to mitigate unforeseen water and public health impairments resulting from modern natural gas drilling techniques in the Marcellus and other shale formations is a critical public health and public resource protection measure. CCE recommends that New York State and other regulatory bodies require project applicants, upon approval, to pay into a dedicated, interest bearing account, to be used to mitigate unforeseen water and public health impairments and ensure utmost protection of the public and their resources.
- Require individual permitting of proposals to drill in state parks and forests to provide the public a meaningful opportunity to weigh in on how the public’s land will be used.
- Allow for a transparent process in the generic permit to provide for meaningful public comment on the cumulative impact to air, water, public health, and wildlife from the infrastructure and flowback water associated with high volume hydraulic fracturing for natural gas, including:
- Additional wells on an approved well-pad
- Freshwater impoundments
- Additional waste into an approved flowback water impoundment
Write to Governor Paterson and your state legislators and ask them to:
- Enact a moratorium on hydro-fracking in New York State;
- Ensure cumulative air and water quality impacts are assessed from high volume hydro-fracking operations;
- Ensure a clear and enforceable plan to address the safe and proper disposal of radioactive liquid waste; and
- Ensure a safe and accountable disposal plan for wastewater generated from hydro-fracking.
Remember to include your name, address, and email address in your letter.
Write To:
- Governor Paterson
The Executive Chamber
State Capitol
Albany, NY 12224 - Your New York State Assemblymember --- find your Assemblymember
- Your New York State Senator --- find your Senator
CCE's Comments to the EPA on Expanding Its Coalbed Methane Study to Include All Oil and Gas Drilling
Fact Sheet on Natural Gas Drilling in Marcellus Shale
CCE’s statement on the draft Supplemental Generic Environmental Impact Statement
CCE’s testimony to the NYS Assembly Environmental Conservation Committee, October 15, 2009
CCE’s testimony to the NYC Committee for Environmental Protection, October 23, 2009
CCE’s testimony in Allegheny, NY
CCE’s testimony in Binghamton, NY
CCE’s comments to the Susquehanna River Basin Commission
CCE's final comments on the Draft Supplemental Generic Environmental Impact Statement
NYS DEC Draft Supplemental Generic Environmental Impact Statement
NYS DEC Generic Environmental Impact Statement
More information on Marcellus Shale from the NYS DEC
updated by seckel 3/1/10