Submit Your SGEIS / Regulations / NPEDES Comments

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Concerned about gas drilling in New York State? — Submit your comments on the SGEIS

The hearings — “unofficial” and “official” — are over (over 6,000 people attended and as many spoke as time allowed — GOOD WORK!). So now is the time to send in many written comments — here’s how. Comment period has been extended to January 11.

TELL GOVERNOR CUOMO & HIS DEC: DON’T FRACK NY STATE

This from Helen Slottje of Community Environmental Defense Council — www.cedc.org

1) Submit comments by snail mail

2) Write individual comments for each topic area (one letter with a collection of comments may not be as fully considered by the DEC — given that they “categorize” each comment.)

3) Submit comments as close to the deadline (DEC must receive by close of business on 1/11/12)Best to mail by Dec 5 and be sure to include your name and address (NY address if you have one)

You have probably heard that the DEC is planning on finalizing the SGEIS this spring and issuing permits almost immediately thereafter. This should not come as a surprise despite the one month extension for comments. The DEC is dotting its i’s and crossing it’s t’s and there is a decent argument that given the lack of paper copies of the sgeis, its length, the floods and power outages, and the holidays thereafter that the comment period was not long enough. The DEC threw us a bone, but they aren’t interested in listening to us. That has NOT changed. It is vitally important that comments — if at all possible — are submitted by snail mail (Attn: dSGEIS Comments, New York State Department of Environmental Conservation, 625 Broadway,Albany, NY 12233-6510). Online comments must be submitted through a web based form — a system that requires the commentator to categorize their comments and will allow for a very easy way for the DEC to prepare its “responsiveness” summary. I cannot imagine that there will be much more than a stock response to each of the designated comment areas with a very cursory review of individual comments. If instead you send in PAPER comments — and an individual one for each specific area of comment — and you reference and print out SUBSTANTIVE papers, reports, or other backup for your comment — this will require that the DEC spend more time reviewing and considering your comment.

It is also preferable that a number of comments get submitted near or at the deadline so that the review process cannot start on those comments until they are received — submitting comments prior to the deadline allows for those comments to be considered prior to January 11. By waiting to submit comment(s) until much closer to the deadline (but not afterwards) will allow your comments to be as up to date as possible and include the best science and other information. Best to mail by Dec 5 and be sure to include your name and address (NY address if you have one).

New York State released its draft Supplemental Generic Environmental Impact Statement (dSGEIS) on September 7, 2011. Major concerns exist that the 2011 SGEIS does not contain adequate human health protections among other deficiencies. It is urgent that NYSDEC, the NYS Department of Health and Governor Andrew Cuomo hear from you — and anyone else living on the front lines of Gasland, whether in NY State or elsewhere.

Submitting your SGEIS/Regulations/NPEDES Comments

NYSDEC requires us to submit our comments via a postal service or through their online submission forms. They will not accept SGEIS comments from your personal email account or to the email address they have on the SGEIS webpage! You must go through the Department’s online submission registration process or via NYDEC postal address. We suggest you also submit your comments to Gov. Cuomo and to the NY Department of Health AND for DCS to post. You can submit multiple comments — comment early and often.

Resources:

Damascus Citizens for Sustainability’s Gas Drilling Tech Notes has:

  • a huge Gas Drilling Research Library you can use to research your SGEIS comments.
  • Dr. Larysa Dryszka’s guide to human health references in the dSGEIS. Her citations will make writing your human health comments a lot easier. The Completed Revised Draft SGEIS cannot be considered “complete” as it does not address them.
  • a library of comments: some submitted to the New York State Assembly in May 2011 from scientists, physicians, from residents living on the front lines of Gasland and the industry’s lobbyists, IOGA-NY; and additional comments are being posted daily from concerned scientists, physcians, and residents. (The comments provide a wealth of information concerning the state of regulation, the gas industry and human health concerns in NYS.)

… did you know the September 2011 dSGEIS that’s sitting on Governor Cuomo’s desk does:

  • NOT assess adequately the impacts of the natural gas extraction process on human health;
  • NOT create data-gathering mechanisms which could help provide relief to injured people;
  • NOT include a Health Impact Assessment (HIA);
  • NOT formulate a risk analysis of potential human health impacts.

AND there is an extensive and in-depth layout of material on the SGEIS and commenting on it at this link http://www.sourcewatch.org/index.php?title=DSGEIS_Responses

Rules and addresses for submitting your dSGEIS comments.

Damascus Citizens for Sustainability wants to publish your dSGEIS comments (please read about us). They will be a resource for others not sure where to begin and those wanting to have more details for their comments. SGEIS: Comments from the Front Lines. We have also reached out to health professionals whose comments are being published at: SGEIS: Health Profession Comments as trusted resources for you to craft your own responses. All comments sent to DCS will be posted quickly.

Your comments will prove that residents and those concerned about New York are deeply vested in the future of the State of New York and having clean air and water.

The SGEIS released in 2009 received more than 13,000 comments. Nobody can doubt the influence of those comments in the halls of Albany. Since then, huge amounts of work has been done to educate New York’s public. It’s time to take up the pen, the keyboard and the internet to continue that education and to put your views and concerns on record — this is our chance. And if you live in Arkansas, Michigan, Colorado, Ohio — any Gasland region — your comments will underscore what we and all the world should know: the gas industry always says they will do it right in whatever is the latest place they want to drill – your comment will be a public record and may assure that New York State will do the right thing and keep our future with clean water and air.

MORE INFO:
Hearing schedule and details of the three items open for comments

Submitting your SGEIS/Regulations/NPEDES Comments
In case both the SGEIS and the regs weren’t enough to cover in one meeting, they’re also including the SPDES general permit for stormwater runoff. SEE PAGE THREE

pages 1 | 2 | 3 | SUBMISSION PAGE

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