We are starting to drill down now into the NY State draft Supplemental Generic Environmental Impact Statement on permits for drilling in the Marcellus shale.  The environmental consequences of this drilling are of concern to many, such that it is important to investigate both the legal/regulatory and the technical aspects of this permitting process.

For the present, most people appear to be assuming that the whole process the NY State Department of Environmental Conservation is following meets all legal requirements.  This assumption must be carefully investigated, and there are many secondary assumptions stemming from it to understand and investigate as well.  Are the whole GEIS and draft GEIS processes, and accompanying permitting components, being done correctly, by the right agcncies, and the like?  Such global considerations ought not be left out.

Further, where is that library of stuff?  We have the draft SGEIS and the GEIS, but what about all the many letters, reports, memoranda, emails and submittals used to create them?  Most of this material is available to the public and ought to be copied and widely disseminated on the internet.  The public needs all the  source documents, and all the rest. They can’t be thorough without them.

In my experience, there is much to be learned from this material.  For example, regulators often go back and forth, in writing, with industry permittees on many issues.  The letters documenting information requests can help point to issues, both technical and legal/ regulatory,  in need further, in-depth study.  We can’t do that study without what amounts a full core dump.  Time is of the essence, and people need to start making these requests and making appointments and getting to Albany to copy it.