Hydraulic Fracturing Letter NY City AIA Chapter sent to DEC

11/2/2011

 

Joe Martens

Commissioner

New York State Department of Environmental Conservation

625 Broadway

Albany, NY 12233

 

Dear Commissioner Martens:

 

On behalf of the AIA New York Chapter’s Committee on the Environment we offer comments on the New York State Department of Environmental Conservation’s proposed High Volume Hydraulic Fracturing Regulations (6 NYCRR Parts 52, 190, 550-556, 560, and 750) and the issue in general.  As environmentalists and architects, we feel it is our duty to comment on the High Volume Hydraulic Fracturing option to facilitate production of natural gas from wells in the Marcellus Shale and Utica Shale in New York, as well as the applications for permits to drill horizontal wells to evaluate and develop these areas for potential natural gas production.

 

We understand the need to identify areas for increased sources of energy to serve the NYC metro area and the greater metropolitan region, especially if the Indian Point Nuclear Facility is closed.  However we firmly believe that New York State’s support of energy efficiency strategies is a far better way to accomplish a significant increase in the available energy supply.  Buildings in New York City use 95% of the electricity and we have the knowledge and the science to retrofit existing buildings and create new buildings that dramatically reduce energy consumption.  Drilling for natural gas does not improve energy efficiency nor does it reduce carbon emissions from buildings.  While natural gas reserves are in great supply, they do not address the issues of reducing greenhouse gas emissions to control the already devastating impacts of global warming.  Energy efficiency helps solve not only a resource problem, but a climate crisis.

 

There are many knowledgeable people in New York State who could be helpful in approaching the problem through energy efficiency initiatives.  These include the American Institute of Architects New York Chapter and its Committee on the Environment, Urban Green (The New York branch of the U.S. Green Building Council) and several enlightened real estate developers. For example, witness the exceptional work done by Malkin Holding’s at the Empire State Building.

 

The Empire State Building earned LEED-Gold certification after undertaking the largest retrofit of its kind in the United States.  It is expected to reduce energy use by more than $4.4 million annually, cut carbon emissions by 105,000 metric tons over a 15-year period and provide a payback in slightly more than three years. Malkin Holdings brought together Johnson Controls Inc., Jones Lang LaSalle, the Rocky Mountain Institute, the Clinton Climate Initiative and the New York State Energy Research and Development Authority for the project. The sustainability program manager for the Empire State Building showed that these efficiencies it could be attained at an incremental cost of about $0.25 per square foot. (As reported in GreenBiz Empire State Building's Green Transformation Earns LEED-Gold by Leslie Guevarr, Sept. 7, 2011)

 

In addition, a more rewarding incentive program and additional legislation could certainly conserve as much energy as is needed in the New York City metro area.  The city of New York now has a financing vehicle for energy efficient retrofits, the New York City Energy Efficiency Corporation (NYCEEC) which was capitalized with federal stimulus funding and organized to partner with the commercial lending industry.  The City has also adopted the Greener, Greater Buildings Plan, the most far-reaching legislation in the United States impacting energy use in existing buildings.  Green technology is the future of the region and a vehicle to spur new industries, drive innovative practices and technology, and create a skilled workforce to attract investment in the region over a prolonged period of time.

 

Destruction of our natural resources is unnecessary to solve this problem. We must be more efficient in what we design and how we use our natural resources.  The current lobbying efforts of the gas industry clearly will result in the environmental degradation of our surroundings. 

 

It is not necessary to subject our environment and its inhabitants to the potential side effects or impacts associated with horizontal drilling and high volume hydraulic fracturing identified by other communities!  These detrimental impacts include:

 

·         Toxicity and disposal of working fluid

·         Enormous quantities of fresh water, wasted

·         Reduced stream flow and degradation of a stream's best use

·         Depletion of water supply in streams

·         Efficiency of process is uncertain, when embodied energy is considered

·         Quantity of gas supply has been overestimated

·         Despoiling of natural landscape for heavy equipment and drilling

·         Increased traffic on roadways; damage to local roads, bridges and other infrastructure; damage to state roads, bridges and other infrastructure

·         Risk of potentially hazardous spills

·         Degradation/contamination of the NYC/unfiltered water supplies

·         Degradation of Air Quality

·         Risk to local drinking water

·         Long‐term damage to groundwater resources

·         Degradation of local ecosystem from fragmentation of habitat, and

·         Greenhouse gas emissions from fracturing process and use of harvested natural gas

For the reasons we offer above, we reiterate our opposition to allowing permits to be issued for the High Volume Hydraulic Fracturing to facilitate production of natural gas from wells in the Marcellus Shale and Utica Shale in New York.  We should first exhaust all alternative methods to utilize the energy we produce in a more efficient manner before we allow further degradation of our environment.  Greater efficiency is the answer to our lack of unlimited natural resources.  We owe it to ourselves and future generations to do better.

 

Sincerely,

 

                                     

Margaret O’Donoghue Castillo, AIA                            Rick Bell, FAIA

2011 Chapter President                                                    Executive Director

 

 

                                                                                                

 

Pat Sapinsley, AIA                                                             Ilana Judah, Int’l Assoc. AIA, LEED

Co-Chair                                                                               Co-Chair

AIANY Committee on the Environment                           AIANY Committee on the Environment