Re: Tioga Energy Partners, LLC ECL Article 23 Application for Permit to Drill Using Gelled Propane Hydraulic Fracturing

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We are writing to express our concerns regarding the Tioga Energy Partners, LLC (“TEP”) application for a well drilling permit (for Snyder E 1-A), and more broadly, for proposals to use liquefied petroleum gas (“LPG”) as a fracturing fluid to target New York’s Utica and Marcellus natural gas bearing formations. It has been more than four years since New York State took the historic step of prohibiting high volume hydraulic fracturing (“HVHF”) based on the significant environmental harms and public health risks that would have resulted from allowing this damaging activity in New York State. Allowing fracking with LPG presents many of the same risks. We appreciate that the Department of Environmental Conservation (“DEC” or the “Department”) decided to conduct a full Environmental Impact Statement (“EIS”) for TEP’s project and urge that DEC employ the same level of scrutiny in its evaluation of this proposal, especially in this early scoping stage, that it used in deciding to prohibit HVHF.