Shaleshock.org has a link to a nicely targeted letter by Wilma Subra, on proposed Marcellus shale hydraulic fracturing activity, to the New York State Senate Standing Committee on Environmental Conservation.   (Here is an interview with Ms. Subra, which gets into a her background and methods.  She won a MacArthur Foundation fellowship about 10 years ago.) The letter addresses a “Clean Water Hearing” by this NY State Senate committee.

The comments are nicely targeted because they go directly to the political people, state the case for concern, and provide some important solutions which these people actually should have the power to effect.  (I recommend someone address this letter separately to each committee member, via email and fax, to increase its chances of being seen.)

Solutions Ms. Subra provides the political people include changing legislation and/or regulations, to require a Waste Management Plan for all aspects of hydrofracturing chemicals, before and after drilling; and appropriate setbacks and buffer zones.

Another solution, as Ms. Subra writes, is ensuring there are sufficient regulatory resources to help prevent problems.  Thus, she writes

With the huge focus on drilling and production of shale gas in the Marcellus Shale, the regulatory agencies in the State of New York need to be provided with adequate resources and staff to review, evaluate, and issue appropriate permits for shale gas wells. The agencies also need sufficient resources and staff to observe field activities during drilling and fracturing processes, perform compliance monitoring, respond to citizens complaints and enforce the regulations in order to protect water resources and human health.

A very important idea.  NY should set aside, in an appropriate way, a significant percentage of the revenues from this activity (if it goes forward….questions of its viability remain), and devote it to the right kind of regulatory protective mechanisms.  (I have ideas on such approaches, which are different than what we see today, and will get into that in future posts.)  There should be no question that these political people will be held accountable if they don’t do this.


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