file. - Otsego County Conservation Association

The DEC also did not evaluate the cumulative impacts of repeatedly fracking the same well, which
should include the effects of repeatedly applying high pressure to well casings and cement, and
the impacts on roads of repeated use by heavy trucks. There is also no discussion of the
cumulative impacts on surface subsidence and its possible impact on groundwater. There is no
discussion or mitigation of cumulative impacts of drilling and fracking under the purview of the
DEC, combined with related activities that are under the purview of the Public Service
Commission. These include construction and operation of pipelines, gas treatment plants and
compression stations. The rdSGEIS should consider the combined cumulative impact of all these
activities.
There is no discussion of the cumulative impacts or mitigation of dealing with flowback fluids
and produced fluids from the large number of wells that are projected. Disposal of flowback
fluids and produced fluids to treatment plants that do little more than dilute the material before
discharge into rivers and or lakes will cumulatively result in increased levels of pollutants
downstream. This must be addressed on a cumulative basis, not by treating each discharge as a
one-time inconsequential event. Similarly, the effect of repeated spreading of produced fluids on
roads must be addressed on a cumulative basis, as well as single events. The 2011 rdSGEIS does
not address the cumulative public health impacts from protracted and/or repeated human
exposure to fracking additives, drilling fluids, methane gas, volatile hydrocarbons or other
substances used in the drilling, fracking, processing and transportation related to natural gas,
whether that exposure occurs at the drill site as a work place, at adjacent dwellings, in or near
public buildings or at any other place that people might be exposed repeatedly to substances
used during any step in the process.
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