These comments reflect our careful consideration of the Rapid Waters Draft Unit Management Plan, with emphasis on the components of the plan that address potential shale gas extraction activities and infrastructure within the state forest. Our comments are particularly focused on the Danby State Forest, but generally have equal bearing with regard to the Shindagin Hollow State Forest.
We are attaching several maps developed in order to inform our assessment and to illustrate and substantiate our recommendations. These maps show areas of the forest that align with the DEC’s definitions of types of forest land that may be compatible/incompatible with different levels of gas extraction activities and infrastructure (Category A — Compatible with well pad, road and pipeline/utility development; Category B — High canopy forest/one well pad per state forest; Category C — Possibly compatible with road and pipeline development; Category D — Not compatible with well pad, road or pipeline/utility development). As you know, we were unable to obtain some DEC datasets that would have been useful in the development of these maps. As a consequence, we did not have the data needed to classify some areas of the Rapid Waters Unit using the proposed hierarchy (those areas are designated on the maps as “unclassified”). Nonetheless, we believe that these maps are useful tools in assessing the potential impacts of gas extraction activities within the Rapid Waters Unit.
Our overall recommendation is that no gas extraction activities be permitted within the Rapid Waters Unit. This recommendation is aligned with comments submitted by the Danby Town Board which urged the DEC “to prohibit the extraction of natural gas, using high-volume, slick-water, horizontal hydraulic fracturing, from the Danby State Forest, due to its potential to disrupt forest habitat, pollute the water and air of the forest, and greatly diminish a valuable natural treasure.” Further, as noted by Danby’s Planning Board, “The DEC proposal to exploit the natural gas resources beneath the forest are inconsistent and incompatible with both the town's plans and the DEC's stated goals. The Danby State Forest straddles and encompasses the headwaters of every major aquifer in the town. Our aquifers are our most important natural resource, and we rely on the state forest to protect substantial parts of the aquifer recharge areas. To risk those aquifers for a short-term economic gain would be to recklessly endanger the health and safety of the residents of the town. The other quality of life impacts are also inconsistent with the town's plans for this rural area. The Planning Board strongly urges the DEC to delete this proposal from the UMP.”
The Danby Gas Drilling Task Force does not view the mitigation and buffering strategies proposed in the draft plan to be workable, given the relatively small size of both the Danby State Forest and the Shindagin Hollow State Forest; their proximity to high use recreational areas, recreational trails, and special ecosystem areas: the emphasis in Danby’s Comprehensive Plan on preservation of our town’s rural character: and the importance of forest-based ecological and recreational activities. Studies of Danby’s aquifers underscore their sensitivity to disruption and overuse, and confirm the vital role the State Forest lands play in their recharge.
The attached maps provide clear support of our recommendation that no gas extraction activities be permitted in the Rapid Waters Unit.
The map entitled “Danby State Forest — All Categories” (filename: DanbyAllCategories.pdf) shows the distribution of small Category A areas throughout the forest, many of which are in close proximity to areas that our preliminary analysis suggests are likely to be designated Category D. The activities and infrastructure necessary for shale gas extraction would contribute to the fragmentation of these important Category D forest lands.
The map also underscores the small amount of land area likely to be designated Category B (High Forest Canopy), as well as the adjacency of Category A and C lands to the scarce high forest canopy areas. The activity and infrastructure necessary for gas extraction are inconsistent with nurturing and sustaining high forest canopy areas; this activity would increase forest fragmentation, rather than working towards the DEC’s stated goal of reduced forest fragmentation.
As shown on this map and on the map showing an overlay of Categories A-D on a satellite image of the Danby State Forest (filename: DanbySatAllCategories.pdf), some Category A areas are uphill from highly sensitive Unique Natural Areas such as Michigan Hollow, presenting risk of contamination by above ground chemical spills and/or stormwater.
Further, according to highly expert local ornithologists, the intensive lighting required on drilling rigs during the drilling process would pose dangers to the many species of birds that migrate through and nest in the Rapid Waters Unit.
The satellite image also demonstrates that most Category A areas would require use of Town of Danby seasonal or dirt roads, increasing Town infrastructure and management costs significantly. By the DEC’s own estimate in the d/SGEIS, drilling and hydro-fracking activities on a multi-well pad with 8 wells would demand as many as 8,905 truck trips. Even one multi-well pad would have a massive cumulative impact on the forest, and under the site assessment system outlined in the plan, a number of multi-well pads could be developed within the Rapid Waters Unit, resulting in tens-of-thousands of truck trips using roads through and adjacent to the forest. This would have a massive local and regional impact — even the small number of lumber trucks traveling Peter and South Danby/Crumtown Road this winter resulted in significant damage. Even with a minimal level of build-out (one well pad per State Forest), the impact of truck traffic would place a significant burden on town resources and would have a negative overall impact on the forest lands and on multiple objectives related to the DEC’s core mission.
We have also attached maps of the Shindagin Hollow State Forest (filenames: ShindaginHollowAllCategories.pdf and ShindaginHollowSatAllCategories.pdf) that illustrate similar issues and impacts in that portion of the Rapid Waters Unit.
We see our strong recommendation that the DEC not permit shale gas extraction within the Rapid Waters Unit as consistent with New York State’s Environmental Conservation Law, Article 1: "The quality of our environment is fundamental to our concern for the quality of life. It is hereby declared to be the policy of the State of New York to conserve, improve and protect its natural resources and environment and to prevent, abate and control water, land and air pollution, in order to enhance the health, safety and welfare of the people of the state and their overall economic and social well-being." We consider the inclusion of the activities and infrastructure needed for gas extraction and distribution to be fundamentally at odds with DEC’s goals for the Rapid Waters Unit as well as incompatible with the Town of Danby’s interests and comprehensive plan.
We thank you for this opportunity to participate in the planning process for the State Forest that makes up approximately a quarter of our town’s land area and that contributes even more than that to the character and spirit of the Town of Danby.