Letters to Governor Cuomo

Since Governor Cuomo’s inauguration in January 2010, hundreds of health professionals and organizations from across the state of New York have called on his administration to conduct an independent, comprehensive Health Impact Assessment. Below are the letters.

February 27, 2013October 4, 2012March 16, 2012December 12, 2011October 5, 2011March 26, 2011February 28, 2011
The Honorable Andrew Cuomo
Governor of New York State
New York State Capitol Building
Albany, NY 12224

Dear Governor Cuomo,

We, the undersigned medical professionals, elected officials, organizations, and concerned New Yorkers, write to thank you. We support your decision to allow rule-making deadlines to lapse in order to grant Department of Health (DOH) Commissioner Nirav Shah additional time to continue the HealthReview of the Department of EnvironmentalConservation’s(DEC) draft Supplemental Generic Environmental Impact Statement (SGEIS) for High Volume Hydraulic Fracturing (HVHF). As DOH Commissioner Shah emphasizes in his recent letter to DEC CommissionerJoseph Martens, understanding the potential impact of HVHF on public health involves answering complex questions. We therefore applaud you for not rushing the DOH through this essential process in order to meet an arbitrary deadline.

In particular, we agree with DOH Commissioner Shah’s assertion, as expressed in his February 12 communiqué to DECCommissioner Martens, that “the time to ensure the impacts on public health are considered is before a state permits drilling.” On February 13, you were quoted as saying that the decision on HVHF is “too important to make a mistake.” We agree.

We look no farther than our southern border to see the terrible results of moving ahead with HVHF without properly considering the public health consequences from a range of drilling-related impacts. These impacts include 24/7 noise pollution; vehicular accidents; diesel exhaust; well casing/cement failures; direct contamination of wells with methane from deep-level fracture zones; hazardous air pollutants from venting and flaring operations; chemical spills; improper disposal of radioactive waste water; silica dust; stream sedimentation; and, of course, climate-altering methane emissions to air.

With your decision to stop the clock, we hope that you will be guiding our state along a different path—by carefully considering any and all public health impacts before deciding whether to allow fracking in New York. Such a consideration must include a close examination of health impacts in other parts of the nation where HVHF is ongoing. Commissioner Shah’s letter mentions three such studies, which, as Dr. Shah points out, represent the first comprehensive studies of HVHF health impacts at either the federal or state level. It is encouraging that Dr. Shah and his team are taking these studies into account and meeting with the principal investigators of each of them.

At the same time, we strongly disagree with DECCommissioner Martens’ statement of the same day that asserts that issuance of permits may not be delayed by lack of regulations. You have often stated that HVHF will only move forward in New York State with the nation’s strongest protections in place. An announcement that permits can go forward with no regulations at all contradicts that claim.

We now ask for three further and necessary measures.

First, we ask that you wait for the completion of these three comprehensive studies referenced in Dr. Shah’s letter before deciding whether or not to go forward with permitting a single HVHF well. The NYS DOH health review of HVHF should not be completed until the results from this trio of studies are included. Right now, we lack the meaningful data that these studies will provide. Your oft-stated promise that the science will determine your decision means waiting for that science to emerge.

Second, a secret public health review is a contradiction in terms. We ask that you open up the Department of Health’s inquiry to public comment and participation. Just as New Yorkers vigorously participated in the Department of Environmental Conservation’s proposed regulations and the draft SGEIS, they, along with New York’s health professionals, should also play a key role in this public health review. New York citizens should be allowed to know the charge that Dr. Shah gave the three outside reviewers who are assisting him and to view the documents that they have been given. Upon completion of the draft health review, a public hearing and a formal public comment period must commence.

Lastly, and most importantly, we reiterate our call for a comprehensive, independent Health Impact Assessment (HIA) that is site-specific for New York. As Department of Environmental Commissioner Martens has reminded us on several occasions, HVHF in New York State, if it does take place, would be governed by regulations different than those in any other state. Additionally, our state’s drinking water system is unique. No other major city, for example, relies on aging, 100-miles-long, century-old aqueducts that lie directly atop a fault-riddled shale bedrock. But New York City does.

Likewise, in our Southern Tier region, an interconnected web of surface streams and primary aquifers creates a hydrological system that is unique to New York. The pattern of our air currents and air quality indices are also unique, as are the agricultural practices in our world-renowned wine-producing regions. We remind you that New York State is one of the most densely populated states in the union. Among all states, we are the nation’s third largest dairy producer as well as its third largest producer of organic food. These products are not only a vigorous part of our economy, they contribute to our public health as well. In short, while a public health review of data on the health impacts of fracking from other states can provide us much important insight, it is no substitute for a New York-specific HIA.

Thank you again for your commitment to protect the public health of New Yorkers. We look forward to working with Commissioner Shah as he continues to evaluate the public health impacts of HVHF. We agree with the standard set by Commissioner Martens for HVHF on September 20, 2012: “Obviously if there was a public health concern that could not be addressed we would not proceed.” We believe that this is the standard that must be met.

Sincerely,

HEALTH & MEDICAL ORGANIZATIONS:
Alliance of Nurses for Healthy Environments
American Academy of Pediatrics, District ll New York State
American Lung Association in New York
Breast Cancer Action
Breast Cancer Coalition of Rochester
Breast Cancer Fund
Breast Cancer Network of Western New York
Breast Cancer Options
Center for Environmental Health
Children’s Health Fund
Clean Air Council
Concerned Health Professionals of New York
CRAAB! (Capital Region Action Against Breast Cancer)
Empire State Consumer Project
Great Neck Breast Cancer Coalition
Healthy Schools Network, Inc.
Huntington Breast Cancer Action Coalition, Inc.
Institute for Health and the Environment, University at Albany
LGBT Cancer Project
Maryland Environmental Health Network
New York State Breast Cancer Network, the only statewide coalition of community based breast
cancer organizations in New York
New York State Prostate Cancer Coalition
Physicians for Social Responsibility, National (1985 Nobel Peace Prize laureate)
Physicians for Social Responsibility, NYC
Physicians for Social Responsibility, Philadelphia
Physicians for Social Responsibility, San Francisco-Bay Area
Physicians for Social Responsibility, Washington State
Science and Environmental Health Network
SHARE Self-help for Women with Breast or Ovarian Cancer
Southwest Pennsylvania Environmental Health Project
Staff of the Ithaca Health Alliance

HEALTH PROFESSIONALS/SCIENTISTS:
Shannon Aether RN
Holly Anderson BS RN D-EM, Executive Director, Breast Cancer Coalition of Rochester
Richard A Bennett MD PhD, Bassett Medical Center, Child/Adolescent Psychiatrist
Michelle Bamberger MS DVM, Veterinarian
Frederick M. Barken MD
Steven Barnett MD, Family Physician
Paul Bermanzohn MD
Edward Bischof MD, Program Director of Internal Medicine Bassett Healthcare Network
Ronald E. Bishop PhD CHO, SUNY College at Oneonta, Department of Chemistry and
Biochemistry
Sheila Blume MD,former Medical Director of Chemical Dependency and Compulsive
Gambling Programs, South Oaks Hospital, Amityville
Matthew J. Bonanno MD, Aesthetic Plastic Surgery, Board-Certified, American Board of
Plastic Surgery, Fellow, American College of Surgeons
Kelly Branigan RN
Michael Branigan CRNA MS
Arlene Bregman DrPH
Charlotte Brody, RN, BlueGreen Alliance
David R. Brown ScD, Director, Public Health Toxicology for Environment and Human
Health, Inc., Former Chief of Environmental Epidemiology and Occupational Health
in Connecticut
Elizabeth Brown MD MPH
Jennifer J. Brown PhD, Geneticist, author
Sheila Bushkin-Bedient MD MPH, Public Health and Preventive Medicine Consultant
Lynn Cahill-Hoy MSN ANP-BC CDE, Family Care Medical Group
Mary Callan RN MS FNP
Lynn Carrol PhD, Senior Scientist, TEDX, The Endocrine Disruption Exchange
Jessica Castner PhD RN, University at Buffalo School of Nursing, Research Assistant
Professor
Rita Charon, MD PhD, Professor of Clinical Medicine, Director, Program in Narrative
Medicine, Columbia University
Theo Colborn PhD, President TEDX, The Endocrine Disruption Exchange
Kelly Cosgrove RN BSN
Daria Crittenden, MD, NYU School of Medicine
James T. Dalton MD, Bassett Healthcare Network, Director of Medical Education
Julie Dickens RN
Gayatri Devi MD, Clinical Associate Professor, Department of Neurology, New York
University Langone Medical Center
Paul A Dura MD, Assistant Clinical Professor of Medicine, Upstate Medical Center,
Binghamton Clinical Campus
Larysa Dyrszka MD
Katherine Eisenberg MD PhD
David Fanion MD, Emergency Physician
Thomas M. Fasy MD PhD
Madelon L. Finkel PhD, Professor of Clinical Public Health, Weill Cornell Medical
College
Kevin Fiscella MD MPH, Family Medicine
Donna Flayhan PhD, Director, The Lower Manhattan Public Health Project
Shannon Gearhart, MD, Physicians for Social Responsibility – New York City
Yurbi Gorby PhD, Howard A. Bitman Chair, Department of Civil and Environmental
Engineering, Rensselaer Polytechnic Instititute
David Gould MD MBA
Robert M. Gould MD, President San Francisco-Bay Area Chapter, Physicians for Social
Responsibility
Elizabeth Hess RN MS FNP, Gannett Health Center, Cornell University
Claire Robinson Howard ANP NPP, Nurse Practitioner in Adult Health and Psychiatry
Robert W. Howarth PhD, David R. Atkinson Professor of Ecology and Environmental
Biology,Cornell University
Katie Huffling MS RN CNM, Alliance of Nurses for Healthy Environments, Director of
Programs
Diane White Husic PhD, Professor of Biological Sciences, Moravian College, PA
Audubon TogetherGreenConservation Fellow, Board member, Lehigh Valley
Audubon Society
Anthony Ingraffea PhD, Dwight C. Baum Professorship in Engineering,Cornell University
Kenneth Jaffe MD
Lila Kalinich MD, Professor, Columbia University
Andrew S. Kanter MD MPH, Assistant Professor of Clinical and Biomedical Informatics,
College of Physicians & Surgeons; Director, Global Health Informatics Center,
Columbia University, Mailman School of Public Health
Mehemosh Khan MD, Berkshire Health System, Pittsfield, MA
Abby Kinchy, PhD and Kim Fortun, PhD, Fracking Research Group, Rensselaer Polytechnic
Institute
William Klepack MD, Family Physician
Katrina Korfmacher PhD
Marina Kubicek RN BSN
Carol Kwiatkowski PhD, Executive Director, TEDX, The Endocrine Disruption Exchange
Karen LaFace MD
Charles Levenstein PhD MS, Professor Emeritus of Work Environment, University of
Massachusetts Lowell
Stephen Malamud MD
Jonathan F Mauser MD
Arnold Matlin MD
Michelle McNamara RN
Mary Menapace RN, Women’s Services Upstate Medical University
Elise Miller MEd, Director, Collaborative on Health and the Environment
Celeen Miller, The Wellness Connection
Thomas Nash MD, New York Presbyterian Hospital–Weill Cornell Medical College of Cornell
University
Elizabeth Naumburg MD, Associate Dean, Advising Professor of Family Medicine,
University of Rochester School of Medicine
Judy Nelli CFNP, Family Care Medical Group
Kathleen Nolan MD MSL, Catskill Mountainkeeper Regional Director for the High Peaks
Melanie Novick RN BSN
Michael R. O’Brien MD, University at Buffalo, Resident Physician
Beth Olearczyk MD, Assistant Clinical Professor of Medicine, Columbia University
College of Physicians and Surgeons, Attending Physician, Bassett Healthcare
Robert E. Oswald PhD, Professor, Department of Molecular Medicine, Cornell University
Jerome A. Paulson MD FAAP, Professor of Pediatrics and of Environmental & Occupational
Health George Washington University, Medical Director for National & Global Affairs,
Director of the Mid-Atlantic Center for Children’s Health & the Environment,Child Health
Advocacy Institute
Vincent M. Pedre III MD Medical Director, Pedre Integrative Health Clinical Instructor, Mount
Sinai Medical Center
Simona L. Perry PhD, c.a.s.e. Consulting Services
Kim Pieniazek RN
Naomi Pless MD
Margaret A Rafferty DNP MPH RN, New York City College of Technology, The City
University of New York Baccalaureate Program Coordinator, Associate Professor
Irwin Redlener MD
Jennifer Rockwell RN
Ted Schettler MD MPH, Science and Environmental Health Network, Science Director
Stephen S Schneider DDS Oral and Maxillofacial Surgeon
Jill Schneiderman, PhD, Professor of Earth Science, Vassar College
Peter Schwartz MD
Avniel Shetreat-Klein MD
Maya Shetreat-Klein MD
Seth B. Shonkoff PhD MPH, Physicians, Scientists, and Engineers for Healthy Energy, UC
Berkeley
Craig Slatin ScD MPH, Professor, Department of Community Health and Sustainability,
University of Massachusetts Lowell, Editor, New Solutions: A Journal of Environmental
and Occupational Health Policy
Kristin Smith RN BS
Ken Spaeth MD MPH, Hofstra University School of Health Sciences, Assistant Professor
Lorie Stannard RN MS DNO-s FNP-C
Sandra Steingraber, PhD, Ithaca College
Douglas Stockman MD
Stephen Strasser MD
Andrea Torrado MD, Northeast Pediatrics
Jose Torrado MD FACOG, Cayuga Medical Center, Current Chair of the Dept of
OB/GYN
Julie Jacobson Vann PhD MS RN, Senior Researcher, American Institutes for Research
James W. Walker MD
David Wallinga MD, Institute for Agriculture and Trade Policy
Cynthia Walter PhD, Associate Professor Biology, Saint Vincent College, PA
Ingrid Watkins MD
Barbara Warren RN MS, Citizens’ Environmental Coalition, Executive Director
Richard Weiskopf MD, Internal Medicine, Upstate Medical University, volunteer faculty
Mary Wheat MD, Columbia University Medical Center, Special Lecturer, Department of
Medicine
Gerri Wiley RN PHN
Geniene Wilson MD AAHIVS, Institute for Family Health
George Woodwell PhD, NRDC Distinguished Scientist, founder, Woods Hole Research Center,
Woods Hole, MA
Margo Yntema RN

NATIONAL/STATE ORGANIZATIONS (non-medical):
350.org
Artists Against Fracking
Catskill Mountainkeeper
Center for Biological Diversity
Center for Media and Democracy
Citizen Action of New York
Citizens Campaign for the Environment
Citizens for Healthy Communities
Clean Air Council
Clean and Healthy New York
Clean Production Action
Clean Water Council
Damascus Citizens for Sustainability
Dear Governor Cuomo, Jon Bowermaster, Director
Delaware Riverkeeper Network
Earthworks Oil & Gas Accountability Project
Empire State Consumer Project
Environment New York
Environmental Advocates of New York
Environmental Working Group
Food & Water Watch
Frack Action
Grassroots Environmental Education
Green Umbrella
Hudson River Sloop Clearwater
Institute for Agriculture and Trade Policy
New Yorkers for Sustainable Energy Solutions Statewide
NYH2O
NYPIRG
PeaceWeavers
Sierra Club Atlantic Chapter
Story of Stuff, Annie Leonard, Director and author
Thunder Mountain Foods
United For Action
Working Families Party

NOTABLE INDIVIDUALS:
Al Appleton, former Commissioner of the NYC Department of Environmental Protection and
creator of the acclaimed New York City Catskill Watershed Protection Program
David Barsamian, director, Alternative Radio
Lois Gibbs, Love Canal organizer; Executive Director, Center for Health, Environment & Justice
Arun Gandhi
Josh Fox, filmmaker
Don Hazen, executive editor, Alternet.org
Melissa Leo
Bill McKibben, founder, 350.org
Natalie Merchant
Elisabeth N. Radow, Esq., Radow Law PLLC
Mark Ruffalo
Maya Schenwar, director, Truthout.org
Pete Seeger
Douglas A. Shields, former president, Pittsburgh City Council
Gloria Steinem
Debra Winger

LOCAL ORGANIZATIONS:
Back To Democracy
bCARP
Brewery Ommegang
Capital District Against Fracking
Citizens for Water
Citizens Radon Watch
Citizens’ Environmental Coalition
City of Binghamton Residents Against Hydrofracking
Coalition Against the Rockaway Pipeline
Concerned Citizens of Rural Broome County
Elmirans & Friends Against Fracking
Environmental Leadership and Action Network, Ithaca College
FaCT (Faith Communities Together for frac Awareness)
Finger Lakes Cleanwaters Initiative, Inc., Chris Tate, Director
Fleased
Frack Free Genesee
Friends of Times Beach
Gas Drilling Awareness for Cortland County
Gas Free Seneca
Geneseo Environmental Organization, SUNY Geneseo
Gray Panthers, NYC Network
Great Neck Breast Cancer Coalition
GreenWatch
Groton Resource Awareness Coalition GRAC
Intercultural Studies
Jay Burney for Habitat and Natural Resources Work Group, Western New York Environmental
Alliance
Lake Success Environmental Commission
LakeHouse Graphics
Learning Sustainability Campaign
Light Alliance Foundation, Inc.
Long Island Progressive Coalition
Marbletown Citizens Defense Against Fracking
Marcellus Accountability Project for Tompkins County
New York City Friends of Clearwater
New Yorkers for Clean Water Inc.
Olive Defense Against Fracking
Otsego 2000
PAUSE – People Advocating Use of Sustainable Energy
Plymouth Friends of Clean Water
Protect Pittsfield
Protecting Our Waters
PUSH Buffalo
R-CAUSE (Rochesterians Concerned About Unsafe Shale-gas Extraction)
R-CAUSE (Rochesterians Concerned About Unsafe Shalegas Extraction
Reach Out America
Residents Against Fracking Tioga
Residents Opposing to Unsafe Shale Gas Extraction
Rochester Defense Against Fracking
Sanford-Oquaga Area Concerned Citizens
Save The Southern Tier
Shaleshock CNY
Southern Cayuga Anti-Fracking Alliance
SPACE CAMP RADIO
Stop the Minisink Compressor Station
Students for Global Change at SUNY Oswego
Sullivan Area Citizens for Responsible Energy Development (SACRED)
SUNY Cortland Environmental Justice Committee of the Center for Gender and
The Carbon Squeeze
United for Action
Vestal Residents for Safe Energy
Water Equality
West Harlem Environmental Action
Westchester for Change
Western NY Drilling Defense
Wittenberg Center for Alternative Resources
Youth Now Activist Network

PA GROUPS:
Charles Kernaghan and Barbara Briggs for Institute for Labour and Human Rights,
Pittsburgh
Marcellus Outreach, Butler
Marcellus Protest
Pennsylvania Alliance for Clean Water and Air
Tour de Frack
Upper Burwell Citizens Against Marcellus Pollution
Westmoreland Marcellus Citizens’ Group

OH GROUPS:
Appalachian Ohio Sierra Club
Athens County Fracking Action Network
Buckeye Forest Council
Burning River Anti-Fracking Network
Concerned Citizens of Medina County
Concerned Citizens Ohio
Concerned Citizens Ohio/Shalersville
Concerned Citizens Portage County
Frackfree American National Coalition
FrackFree Mahoning Valley
Fresh Water Accountability Project Ohio
Green Environmental Coalition
Ohio Alliance for People and the Environment Board
Ohio Citizen Action
Ohio Environmental Council
Ohio Fraction
Ohio Sierra Club Forests and Public Lands Committee
Southwest Ohio Alliance to Save Our Water

IL GROUPS:
George J. Gordon, Chairperson, Land Use and Development Committee, McClean County Board
Illinois People’s Action
Illinois Wesleyan University, Sierra Student Coalition
Industrial Sociology, Illinois State University
JWP Audubon Chapter, National Aududon
No New Nukes, Central Illinois
SAFE: Southern Illinoisans Against Fracturing Our Environment
Stop the Frack Attack on IL
The Land Connection
Veltin Joseph Boudreaux, MD, MS, Bloomington
Vision 202–a Transition Town Initiative (Bloomington-Normal)
William C. Rau, PhD

ELECTED OFFICIALS:
Mary Adams, RN, MPH, City of Rochester, Commissioner of Education
Diane Addesso, Town of Worcester, Deputy Supervisor
Robert T. Aiello, County of Ulster, Legislator
Dan Aman, Town of Brighton, Clerk
Stephanie Aprigliano-Kiyak, City of Dunkirk, Councilmember
Kathie Arnold, County of Cortland, Legislator
Jacqueline Augustine, City of Geneva, Councilor
Don Barber, Town of Caroline, Supervisor
Bonnie Bennett, Village of Aurora , Mayor
George J. Bianchi, Town of Frankfort, Deputy Supervisor
Debra Brock, Town of Preble, Board Member
Cynthia Brock, City of Ithaca, Alderperson
Doug Bullock, County of Albany, Legislator
Will Burbank, County of Tompkins, Legislator
Linda Burkhardt, Town of Olive, Councilmember
Dominick Calsolaro, City of Albany, Councilmember
Robert K. Camera, City of Geneva, Councilmember
Scott Carlsen, Town of Wawarsing, Supervisor
Christopher Case, City of Plattsburgh, Councilor
Carl Chipman, Town of Rochester, Supervisor
Carol Chock, County of Tompkins, Legislator
Stephen Churchill, Town of Seneca Falls, Supervisor
Bernard Cohen, Town of Bethel, Councilmember
Agnes Compagnone, RPA-C , City of Beacon, Councilmember
Peter Compton, Town of Locke, Highway Superintendent
Leslie Connors, Town of Danby, Councilmember
C. Peter Cordes, Town of Sidney, Councilmember
Mark Cornwell, Town of Cherry Valley, Councilmember
D. Chad Davis, County of Oneida, Legislator
James R. Dean, Village of Cooperstown, Trustee
Rich DePaolo, Town of Ithaca, Councilmember
Jason S. DiPonzio, Town of Brighton, Councilmember
Brenda Donohue, Town of Conesus, Supervisor
David Doonan, Village of Greenwich, Mayor
James Doring, Town of Preble, Supervisor
Bob Dougherty, City of Syracuse, Councilmember
Bob Eklund, Town of New Lisbon, Councilmember
Herb Engman, Town of Ithaca, Supervisor
Cynthia Falk, Village of Coopertown, Trustee
George Farenthold, Village of Aurora, Deputy Mayor
Michele Farwell, Town of Butternuts, Councilmember
Lorie Fessenden, Town of Genoa, Supervisor
Steve Fiore-Rosenfeld, Town of Brookhaven, Councilmember
Drew Fixell, Village of Tarrytown, Mayor
Gary Ford, Town of Marshall, Councilmember
James Frisch, Town of Ledyard, Deputy Supervisor
Dominic Frongillo, Town of Caroline, Deputy Supervisor
Diane Gallo, Village of Gilbertsville, Mayor
Catharine Gardner, Town of Lima, Deputy Supervisor
Victoria Gearity, Village of Ossining, Trustee
Leah Golby, City of Albany, Councilmember
James Goldstein, Town of Lebanon, Supervisor
David Gordon, County of Oneida, Legislator
Elizabeth L. Greenwood, Village of Tully, Mayor
Donald J. Gregorius, County of Ulster, Legislator
Matthew P. Haag, City of Rochester, Councilmember
Kathy Halton, Town of Danby, Councilmember
Jude Hartrich, Town of Wales, Councilmember
Terry Harvey, Town of McDonough, Councilmember
Ruth Hopkins, Town of Lansing, Councilmember
Vera Howe-Strait, Town of Enfield, Councilmember
Julie Huntsman, Town of Otsego, Councilmember
Letitia James, City of New York, Councilmember
Brian Kehoe, Village of Catskill, Trustee
Jean Kessner, City of Syracuse, Councilmember
Penelope King, Town of Meredith, Clerk
Dan Klein, Town of Danby, Councilmember
David Koenigsberg, Village of Dobbs Ferry, Trustee
Michael Kolczynski, Town of Savannah, Supervisor
Gary Koutnik, County of Otsego, County Representative
Cindy Kurpil Gieger, County of Sullivan, Legislator
Susan Labuhn, County of Cattaraugus, Legislator
William Labuhn, City of Salamanca, Councilman
William Lancaster, Town of Richmondville, Board Member
Linda Lavine, Town of Dryden, Councilmember
Patricia Leary, Town of Ithaca, Councilmember
Lorena Lenard, Town of Sangerfield, Councilmember
Edward T. Lentz, Town of New Lisbon, Councilmember
Lynn Leopold, Village of Lansing, Trustee
Arnold Lobdell, Village of Burke, Councilmember
Michael J. LoCurto, City of Buffalo, Councilmember
James Loomis, Village of Van Etten, Trustee
Fion MacCrea, Town of Alfred, Councilmember
Laura Malloy, Town of Laurens, Councilmember
Amy Mann, Village of Cazenovia, Deputy Mayor
Christine Marshall, Village of Altamont, Trustee
Susan McConnell, Town of Marshall, Councilmember
Robert J. Meelan, Town of Kirkland, Supervisor
Kevin Millar, CRNA, MSN, Village of Owego, Mayor
William Moehle, Town of Brighton, Supervisor
Deborah Mohlenhoff, City of Ithaca, Alderperson
Patrick Murphy, Town of Colden, Councilmember
Seph Murtagh, City of Ithaca, Councilmember
Nina Nichols, City of Troy, Councilmember
Deborah Nottke, Village of Trumansburg, Deputy Mayor
Louise Novros, Town of Brighton, Councilmember
Alan Ominsky, Village of Aurora, Trustee
Jacklyn Ortiz, City of Rochester, Councilmember-at-Large
Raymond Parker, County of Cortland, Legislator
A. Martin Petrovic, Village of Trumansburg, Mayor
Gerald Pietraszek , Town of Colden, Councilmember
Jeffrey L. Pond, City of Salamanca, Mayor
Casey Powers, Town of Newfield, Councilmember
Diane Pusateri, Village of Churchville, Trustee
Virginia Rasmussen, Village of Alfred, Trustee
Larry H Richardson, Town of Cochecton, Councilmember
David Rivera, City of Buffalo, Councilmember
Martha Robertson, County of Tompkins, Chair of the Legislature
Ronal L. Rocco, Town of Cortlandville, Councilmember
Hector Rodriguez, County of Ulster, Legislator
Beth Rosenthal, County of Otsego, County Representative
Amy Rosmarin, Town of North Salem, Councilmember
Jane Russell, Town of Pulteney , Supervisor
Philip M. Sacco, County of Oneida, Legislator
Thomas Salamone, School District of Minisink Valley, Board Member
Bennett Sandler, Town of Otsego, Councilmember
Amanda Scully, Town of Highland, Councilmember
Marcia Shaw, Town of Meredith, Treasurer
Paul Shepard, Town of Shelter Island, Councilmember
Frederick Sinclair, County of Allegany, Legislator
Sue Skidmore, City of Elmira, Mayor
Steve Smith, City of Ithaca, Alderperson
Aaron Snow, Town of Caroline, Councilmember
Elaine Spaull, City of Rochester, Councilmember
Paul Stein, Town of Pittsfield, Councilmember
Dan Sturm, Town of Bethel, Supervisor
Kate Supron, Village of Cayuga Heights, Mayor
Brian Sweeney, Town of Middletown, Councilmember
Peter Swiderski, Village of Hastings-On-Hudson, Mayor
Marie Taylor, Village of Aurora, Trustee
Elizabeth Thomas, Town of Ulysses, Councilmember
Ronald D. Townsend, County of Oneida, Legislator
Sue Vaccaro, Town of Tully, Clerk
Vicky Vassmer-Simpson, Town of Bethel, Councilmember
Rickey Venditti, Town of Wales, Supervisor
Frank X. Vescera, City of Utica, Councilmember
John L. Wallace, Town of Frankfort, Councilmember
Debra Watkins, Village of Trumansburg, Trustee
Lea Webb, City of Binghamton, Councilmember
Elizabeth Weberg, Village of East Aurora, Deputy Mayor
Jay Wenk, Town of Woodstock, Councilmember
Irene Wesier, DVM, Town of Caroline, Councilmember
Wendy Whetsel, Town of Putnam Valley, Councilmember
Kevin Whitney, County of Cortland, Legislator
Rodney Wiltshire, City of Troy, Councilmember
Richard Winters, Village of Liberty, Mayor
Alden H. Wolfe, New City, Vice Chairman of the Legislature
Robert Wood, Town of Oneonta, Supervisor
Daniel V. Woolaver, Town of Rush, Councilmember
Jerald Wrubel, Town of Geneseo, Board Member
Susan Zimet, Town of New Paltz, Supervisor

FAITH:
Carol DeAngelo, SC, LMSW, MDiv, Director of Office of Peace, Justice and Integrity of
Creation, Sisters of Charity of Center, Bronx NY
Rabbi Aderet Drucker, Congregation B’nai Shalom, Walnut Creek, CA
Rabbi Michael Goldman, White Plains
The Rev. Fletcher Harper, Executive Director, GreenFaith, Highland Park, NJ
Interfaith Impact of NYS, Rob Smith, Executive Director
Rabbi Douglas E. Kranz, Congregation Bnai Yisrael, Amonk
NY State Council of Churches
Sisters of St. Francis of Philadelphia
Rev. Dr. Michael Tino, Unitarian Universalist Fellowship of Northern Westchester, Mount Kisco

The Honorable Andrew M. Cuomo
Governor of New York State
New York State Capitol Building
Albany, NY 12224

Dear Governor Cuomo,

We in the medical and scientific community in New York State are pleased that our efforts to bring the public health impacts of the largest land use decision in New York State’s history to the attention of the Department of Environmental Conservation (DEC) and Department of Health (DOH) and to the forefront of the SGEIS process have been heard. We were heartened that in DEC’s September 20, 2012 announcement regarding a health review, Commissioner Martens wrote: “Only after this evaluation is completed will a decision be made about whether to permit high volume hydraulic fracturing in New York. Obviously if there was a public health concern that could not be addressed we would not proceed.” However, a DOH review of work already prepared by DEC on this topic is not enough to answer the question of whether there is a public health concern that cannot be addressed.  New York must commission a full Health Impact Assessment to better understand the impacts of fracking (meaning the whole process of gas extraction, from site development to delivery) on public health and the measures needed to protect our communities.

DEC Commissioner Joseph Martens’  September 20th press release rejecting our request for a Health Impact Assessment and announcing DOH’s review of DEC’s work brings several concerns and questions to mind, including:

  • What is the health impact analysis document currently under DOH’s review and who will have access to it?
  • Will the questions we’ve been asking–about the health effects of air and water pollution, soil contamination, radon, community impacts, worker safety, psychosocial stress, developmental toxicants and endocrine disruptors, and social justice—be addressed in this review?
  • Will there be transparency and how will that be achieved?
  • Will it be inclusive of all stakeholders?
  • Will the DOH which previously had expressed that health impacts were adequately addressed in the 2011 draft of the SGEIS now be able to do an objective review, and if so, what has changed?
  • What is the process for this review?
  • What expertise does DEC have to conduct a health analysis in the first instance?

Our foremost concern is that the review proposed by Commissioner Martens differs significantly from the Health Impact Assessment (HIA) we requested.  A comprehensive Health Impact Assessment, is a process designed by the World Health Organization and the Centers for Disease Control, and outlined in a guidance document by the National Academies of Science, http://www.nap.edu/catalog.php?record_id=13229, for precisely the kind of decision which DEC is currently weighing.  An HIA is:

  • Transparent;
  • Inclusive of all stakeholders;
  • A recognized process which includes several public health tools;
  • Conducted by an entity with public health expertise; and
  • Includes public participation throughout the process.

We have received no indication that DOH’s proposed review will meet these standards.  There also seems to be a misconception about the Health Impact Assessment process, alluded to by Commissioner Martens in his statement that “the decision-making will remain a governmental responsibility”.  A Health Impact Assessment informs and provides recommendations to the decision-makers, and does not, in any way, take away the decision from the decision-makers.

In closing, we would like to offer the following observation for your consideration.  Commissioner Martens rightly refers to the need to establish the legitimacy of the regulatory process if the controversy that has engulfed shale gas fracking in New York is ever to be resolved.  We suggest that you consider, in the face of the overwhelming recommendation of the medical communities of New York State that a Health Impact Assessment be undertaken, what the consequences would be if a credible one is not undertaken and fracking proves to be a health disaster.  It will be impossible to contain the damage to the State’s credibility and authority in this area.  Your Administration seems to have recognized that fact in responding to the demand for some health review, but to do so in this halfhearted and questionable way is to once again ensure your well-meaning efforts will be counterproductive.   The only way to create the basis for public trust that fracking can be done without major threat to public health is to do a truly independent, truly comprehensive, truly transparent assessment, one done with all stakeholders and relevant experts at the table that demonstrates that is the case.  We urge your most careful consideration of these concerns.

Governor Cuomo, we ask that you join us in advocating on behalf of the most vulnerable, assuring that social justice is achieved, and that the relevant scientific information is in the hands of the decision-makers–yours as well as DEC’s.

We request that a copy of the DEC-generated health impact analysis referenced in the Commissioner’s press release  be made available to the public and that you re-consider the proposed DOH review, and instead commission a full and transparent Health Impact Assessment.

Sincerely,

Shannon Aether RN, Ithaca, NY

Ellis Arnstein MD, NYC, NY

Michelle Bamberger MS DVM, private practice Veterinarian, Ithaca, NY

Delores Bennett RN, Unadilla, NY

Sharon Berger RN, Trumansburg, NY

Paul C. Bermanzohn MD, Rosendale, NY

Ronald E. Bishop PhD CHO, SUNY Oneonta

Linda Bove RN CPN, Clinical Nurse Educator, Blythedale Children’s Hospital, Valhalla, NY

Kelly K. Branigan RN, Middlefield, NY

Michael P. Branigan CRNA MS, Middlefield, NY

Broome County Medical Society

Christine Brouwer, Founder, Mira’s Movement/Supporting Kids with Cancer

Sarah Buckley RN CCRN, co-founder of Protecting Our Water Rights, East Aurora, NY

Sheila Bushkin-Bedient MD MPH, Public Health and Preventive Medicine Consultant, Waterford, NY

Dyan Campbell RN BSN MPH, Past Sullivan County Public Health Director (1971 – 2000)

Marybeth Carlberg MD, Physician Advisory Board for Onondaga County Health Dept., SUNY Upstate Teaching Faculty, Syracuse, NY

Jeffrey Carlberg MD, SUNY Upstate Teaching Faculty, Syracuse, NY

David O Carpenter MD, Director, Institute for Health and the Environment University at Albany, Rensselaer, NY

Andrew D Coates MD FACP, Assistant Professor of Medicine and Psychiatry, Albany Medical College

Alice Cody RN, Town of Groton, NY

D. Barry Crittenden MD, Instructor of Medicine, Division of Rheumatology, NYU School of Medicine

Dominick Di Fabio MD, Psychiatrist, Irvington, NY

Christine K Durbak PhD, Psychoanalyst, World Information Transfer, NY, NY

Larysa Dyrszka MD, Pediatrician (retired), Bethel, NY

David Fanion MD, Cooperstown, NY

Donna Flayhan PhD, Director, The Lower Manhattan Public Health Project, New Paltz, NY

Michael Fox PhD, Psychologist, NYC, NY

Kathryn Frankiewich RN MSN PNP,  Buffalo, NY

Amy Freeth MD, Department of Endocrinology, Diabetes and Metabolism, Cooperstown, NY

Jacquelyn H Gailor BSN RN, Retired Public Health Director for Cortland County

Marion Giambattista RN, Groton, NY

Cindy Kurpil Gieger RN, Sullivan County Legislator

Cindy Gordon MD, Town of Dryden, NY

David Gould MD MBA, NY, NY

Pamela Griffith BSN, Homer, NY

Alice Grow RN, Newfield, NY

Elizabeth Hess, Family Nurse Practitioner, Gannett Health Center, Cornell University, Ithaca, NY

Patricia Jacob, Family Nurse Practitioner, Hematology/Oncology Bassett Medical Center, Cooperstown, NY

Jonathan Jiménez Pérez, Mount Sinai School of Medicine Class of 2014, NYC, NY

Marcia Heaney, President, Breast Cancer Network of Western New York

Sueane Hemmer Goodreau ND RN CFNP, Ithaca, NY

Julie Huntsman DVM, Town of Otsego Council, Otsego, NY

Kenneth Jaffe MD, Slope Farms, Meredith, NY

David W Kalb BS MS and current RN student, Freeville, NY

Lila J Kalinich MD, Professor, Columbia University, NYC, NY

Andrew S Kanter MD MPH, Asst. Prof. of Clinical Biomedical Informatics and Clinical Epidemiology

Columbia University

Amy Koreen MD, Huntington, NY

David B. Kraskow RN, Cayuga Medical Center, Ithaca, NY

Antoinette Kuzminski MD, Fly Creek, NY

Philip J Landrigan MD MSc, Dean for Global Health,

Ethel H. Wise Professor and Chairman, Department of Preventive Medicine, Professor of Pediatrics

Director, Children’s Environmental Health Center

Mount Sinai School of Medicine, NYC, NY

Adam Law MD, Ithaca, NY

Eric London MD, Bethel, NY

Judith Maidenbaum PhD, Psychoanalyst, Kauneonga Lake, NY

Mary McCutcheon RN MS, East Aurora, NY

Michelle C. McNamara RN, Ithaca, NY

Mary Menapace RN, Women’s Health, Upstate Medical University, Syracuse, NY

Kevin Millar MSN CRNA, Owego, NY

Karen Joy Miller, Founder, Huntington Breast Cancer Action Coalition, Inc.

Ramon Murphy MD MPH, Professor of Pediatrics, Mount Sinai School of Medicine, NYC, NY

New York State Breast Cancer Network (a network of 25 organizations located in communities all across the state), Andi Gladstone Executive Director

Kathy Nolan MD MSL, Pediatrician, Regional Director for the High Peaks Catskill Mountainkeeper

Kristine Noonan RN, Nurse Rise ~ Nurses for Safe Water, Buffalo, NY

Michael R. O’Brien MD, Clinical Assistant Instructor, Internal Medicine-Pediatrics, University at Buffalo, Buffalo, NY

Robert Oswald PhD, Professor, Department of Molecular Medicine, Cornell University, Ithaca, NY

Graham Ottoson CNM NP, Ithaca, NY

Julia Parete, Nurse Practitioner, Trumansburg, Town of Hector, NY

Frederica P. Perera DrPH PhD, Professor of Public Health, Director, Columbia Center for Children’s Environmental Health Department of Environmental Health Sciences, Mailman School of Public Health, Columbia University, New York, NY

Nina Pesante MD, Vestal, NY

Physicians for Social Responsibility, New York City chapter, Shannon Gearhart MD, President

Margaret A Rafferty DNP MPH, NYC, NY

Leia Raphaelidis RN FNP, Ithaca, NY

Jacqueline Reinhard, Executive Director, SHARE (Self-Help for Women with Breast or Ovarian Cancer)

Marian H Rose PhD, Bedford, NY

Toby G Rossman PhD, Professor of Environmental Medicine, NYU Langone School of Medicine, Tuxedo, NY

Carol S Ryan RN MPH, Director of Public Health/Patient Services, Sullivan County Public Health Services

William Sawyer PhD, Toxicology Consultants & Assessment Specialist, LLC, Skaneateles, NY

Ted Schettler MD MPH, Science Director, Science and Environmental Health Network

Stephen S. Schneider DDS, Oral and Maxillofacial Surgeon, Deposit, NY

Peter Schwarz MD, Ithaca, NY

Joan Sheehan, President, CRAAB! (Capital Region Action Against Breast Cancer)

Howard Silcoff MD, Town of Dryden, NY

Ken Spaeth MD MPH, Assistant Professor, Hofstra University School of Health Sciences

Sandra Steingraber PhD, Distinguished Scholar in Residence, Department of Environmental Studies, Ithaca College

Shanna H Swan PhD, Professor and Vice-Chair for Research and Mentoring, Department of Preventive Medicine, Mount Sinai School of Medicine, New York, NY

Tompkins County Medical Society

Paul F Torrisi MD, Retina-Vitreous Surgeons of CNY Inc., Associate Clinical Professor Ophthalmology, Upstate Medical University, Syracuse, NY

Mary Jane Uttech RN MSN, Marathon, NY

Kitty Vetter RN, Sullivan County Legislator

Gregory Weiland PhD, Associate Professor of Pharmacology, Cornell University, Groton, NY

Laura Weinberg, Great Neck Breast Cancer Coalition, NY

Richard Weiskopf MD, Syracuse, NY

The Honorable Andrew M. Cuomo
Governor of New York State
New York State Capitol Building
Albany, NY 12224

Dear Governor Cuomo, Senate Majority Leader Skelos, and Speaker Silver,

As you negotiate the budget, we urge you to include a Health Impact Assessment on gas exploration and production using high-volume, slick water, horizontal hydraulic fracturing in the New York State 2012-2013 budget. The New York State Assembly included such a health impact assessment in their 2012-2013 budget resolution.

The medical community across New York has become increasingly concerned about the health impacts of hydraulic fracturing. Throughout the country health impacts ranging from loss of smell, memory problems, and headaches to a number of serious respiratory illnesses and cancers have been associated with high-volume, slick water, horizontal hydraulic fracturing. In October 2011, 250 physicians and medical professionals joined together in calling for a comprehensive public health impact assessment <a href=”http://www.psehealthyenergy.org/resources/view/198813″ target=”_blank”>http://www.psehealthyenergy.org/resources/view/198813</a>. On December 10, 2011 Dr. Sandra Steingraber, Lois Gibbs and Fran Drescher echoed that call with nineteen NY-based cancer advocacy groups in a letter asking for the same assessment <a href=”http://www.psehealthyenergy.org/resources/view/198831″ target=”_blank”>http://www.psehealthyenergy.org/resources/view/198831</a>.

Experts in the federal government are also asking that more research be done on the health impacts of fracking, including Christopher Portier, the Director of the National Center for Environmental Health at the Centers for Disease Control and Prevention in Atlanta, Georgia. As one of the most respected researchers on health issues, Portier stated, “More research is needed for us to understand public health impacts from natural gas drilling and new gas drilling technologies.” To go forward in New York without a proper health impact assessment is therefore unacceptable. We respectfully request that an appropriation be made for this study.

Sincerely,

Robert F. Kennedy, Jr.
Elie Ward, American Academy of Pediatrics District II, NYS
Broome County Medical Society
Medical Society of the County of Tompkins
Familycare Medical Group, Syracuse, NY
Ramon Murphy MD
Lila Kalinich MD
Judith Maidenbaum PhD
Eric London MD
David Gould MD, MBA
Kenneth Jaffe, MD
Kathleen Nolan MD, MSL
Maya Shetreat-Klein MD
Michelle Bamberger PhD
Donna Flayhan PhD
James Dalton MD
Janet Corson-Rikert MD
Beth Olearczyk MD
Richard Weiskopf, MD
Sandra Steingraber PhD
MaryBeth Carlberg MD
John Cooke MD
James C. Macmillan MD
Suzanne Anderson MD
Rhonda Peterson MD
William Klepack MD
Dr Christine Durbak
D. Barry Crittenden, MD
Amy Freeth MD
Adam Law MD
Jeff Snedeker MD
Connie A. Jastremski RN MS MBA FCCM
Michael Jastremski MD
Larysa Dyrszka MD
Paul Bermanzohn, MD
Brent White, MD
The Honorable Andrew M. Cuomo
Governor of New York State
New York State Capitol Building
Albany, NY 12224

Dear Governor Cuomo,

We, the undersigned, represent the more than 103,000 New Yorkers diagnosed every year with cancer, as well as the loved ones of the more than 35,000 who die annually from cancer (New York State Cancer Registry, 2010). As New York State considers whether to maintain or lift its current moratorium on hydraulic fracturing, we bring to your attention the myriad ways in which the introduction of this industrial practice in New York State will raise our cancer risk even further and add more data points to the New York State Cancer Registry. As such, we echo the call of the more than 250 physicians and medical professionals who, in their letter to you of October 7, 2011, requested that the state fully assess the human health impacts of hydraulic fracturing in advance of issuing permits and as part of the decision-making process.

In our daily work we see the devastating consequences of cancer on children and adults as individuals, as well as the effects on families, workplaces, communities – indeed the entire state. These consequences include suffering, premature death, lost productivity, and ruinous health care expenses. These costs must be calculated as part of a comprehensive assessment of potential public health impacts, which, right now, is not part of the revised Supplemental Generic Environmental Impact Statement (SGEIS) issued in September of this year. We point out to you that the SGEIS contains no chapters or headings devoted to cancer or carcinogenesis. This document contains no discussion of New York’s cancer registry nor any discussion of the economics of the healthcare burden likely to be caused by the release of fracking chemicals and the attendant air pollution that invariably accompanies fracking operations. In fact, the word “cancer” itself appears only ten times within the 1,537-page SGEIS document. Without a health impact assessment and a detailed cancer risk analysis, the SGEIS should not go forward and fracking should not go forward.

Many of us devote scarce resources to the effort to research, communicate, and reduce environmental risks of cancer. It is incumbent on us to speak out about the potential for a profound increase in cancer risk in New York State by the permitting of hydraulic fracturing. We remind you that, as a percentage of US health-care spending, cancer is the third most costly condition. For an individual person, cancer is the most costly (U.S Department of Health and Human Services).

We also seek to remind you of the historic role that New York State has played in the promotion of environmental justice. From the groundbreaking investigation at Love Canal – which brought safeguards against toxic exposures to all Americans – to the pioneering Long Island Breast Cancer Study Project, New York State is known around the world for demonstrating that public health and environmental protection are inextricably bound. As we painstakingly remove carcinogenic PCBs from the sediments of the Hudson, as researchers investigate the environmental effects of the 9/11 attack on firefighters and first responders, as the Empire State Building undergoes its splendid green restoration – cutting air pollution by 105,000 metric tons a year and winning a gold Leadership in Energy and Design rating – New York State continues to be a model for the nation.

With knowledge grounded in our state’s proud environmental health legacy and with the unflinching spirit of those who have confronted cancer and know its terrible costs, we offer you these observations and concerns about fracking.

Hydraulic fracturing introduces cancer risks from the start and into perpetuity. Cancer-causing chemicals are associated with all stages of the high-volume hydraulic fracturing process, from the production and use of fracking fluids, to the release of radioactive and other naturally hazardous materials from the shale, to transportation- and drilling-related air pollution, to the disposal of contaminated wastewater. The potential for accidents during the injection and transportation of fracking chemicals concerns us deeply. And, as data from other states clearly demonstrate, the storage, treatment and disposal of the contaminated water can be a source of human exposure to chemical carcinogens and their precursors (Volz, 2011). In addition, the industrialization of the landscape and congestion of small communities with truck traffic impairs the safety and healthfulness of outdoor exercise. Regular exercise is an important, established risk reducer for many cancers, including breast cancer (Bernstein, 2009). Outdoor exercise is associated with a greater intent to continue the activity, along with other positive health indicators.

Fracking fluids contain carcinogens and cancer-promoting chemicals. More than 25% of the chemicals used in natural gas operations have been demonstrated to cause cancer or mutations (Colborn, Kwiatkowski, Schultz, & Bachran, 2011). Between 2005 and 2009, according to the Committee on Energy and Commerce, hydraulic fracturing companies used 95 products containing 13 different known and suspected carcinogens. These include naphthalene, benzene, and acrylamide (Committee Staff for Waxman, 2011). Thirty-seven percent of chemicals in fracking fluids have been identified as endocrine-disruptors. By definition, these substances have the power, at vanishingly low concentrations, to alter hormonal signaling pathways within the body. Many can place cells on the pathway to tumor formation. Exposure to endocrine-disrupting chemicals has been implicated in cancers of the breast, prostate, pituitary, testicle, and ovary (Birnbaum & Fenton, 2003; Soto & Sonnenschein, 2010). These exposures may alter gene expression in pregnancy and early life (Colborn, et al., 2011).

Fracking operations release from the earth radioactive substances, carcinogenic vapors, and toxic metals. The shale bedrock of New York State contains many highly carcinogenic substances that can be mobilized by drilling and fracturing. Among these are arsenic, chromium, benzene, uranium, radon, and radium (Bishop, 2011). Drill cuttings and flowback waste are typically contaminated with naturally occurring radioactive substances and cancer-causing metals, which would otherwise remain safely entombed underground. Flowback waste can contain up to 16,000 picoCuries per liter of radium-226, which is more than 200 times higher than the discharge limit in effluent (60 pCi/L) and more than 3,000 times higher than the US EPA drinking water standard (5 pCi/L) (NYSDOH Bureau of Environmental Radiation Protection, 2009). Traditional water filtration cannot remove these contaminants. We are especially alarmed by the ongoing practice of burying radioactive drill cuttings on-site (Bishop, 2011) and of using radioactive production brine from (currently out-of-state) fracking operations on New York State roads, for purposes of dust control and de-icing (NYSDOH Bureau of Environmental Radiation Protection, 2009). This practice exposes unknown numbers of people, without their consent, to unknown amounts of a known human carcinogen.

Fracking pollutes the air with known and suspected human carcinogens. Air pollutants from fracking take the form of diesel exhaust (from trucks, pumps, condensers, earthmoving machines, and other heavy equipment) along with volatile organic compounds, including benzene (released from the wellheads themselves) and formaldehyde (produced by compressor station engines). Exposure to these air pollutants have been demonstrably linked to lung, breast, and bladder cancers (Brody et al., 2007; Liu et al., 2009). Using US EPA risk assessment tools to examine carcinogenic effects of air quality at oil and gas sites, researchers in Colorado found excess cancer risks from air pollution alone (from 5 to 58 additional cancers per million). At 86 percent of these sites, the human carcinogen benzene was found at hazardous levels. Airborne concentrations of other carcinogens were also elevated (Witter et al., 2008).

Volatile organic compounds can combine with tailpipe emissions to create ground-level ozone. We are alarmed by studies conducted in the gas fields of Wyoming that reveal ozone non-attainment in areas with formerly pristine air quality (Wyoming Department of Environmental Quality, 2009). Ozone can travel up to 200 miles beyond the gas production area (Colborn, et al., 2011). While not a direct carcinogen, ozone exposure is strongly associated with premature death and is believed to promote the development of metastases, thus making cancer more lethal (Breslin, 1995; Fann et al., 2011). Exposure to traffic exhaust and petroleum fumes further potentiates tumor formation and increase cancer risk (Hanas et al., 2010).

Natural gas drilling in New York State is predicted to increase heavy truck traffic on local roads by as much as 1.5 million more trips per year, with an average of 90 and up to 1000 trucks per day at a single well pad (NYSDOT, 2011). For each individual site, hundreds of tanker trucks hauling fracking fluids for injection and flowback fluids for disposal will roll through our communities and neighborhoods, and yet no one has calculated the cumulative impact of the resulting particulate matter and ozone on public health. We remind the Governor that traffic exhaust, especially from diesel engines, is a well-established cause of chronic illness and premature death – even at levels well below regulatory limits. Most ominously, research is steadily corroborating the relationship between childhood leukemia and traffic density, and childhood leukemia and exposure to airborne benzene (Amigou et al., 2011; Pearson, Wachtel, & Ebi, 2000; Whitworth, Symanski, & Coker, 2008). We are also deeply concerned by the growing evidence linking lung cancer in non-smokers to air pollution, including traffic exhaust. Among adults, non-smoker’s lung cancer is now the sixth most common cancer diagnosis, and rates are rising particularly rapidly among women. A new, nationwide study finds that people who have never smoked but live in areas with higher air pollution are 20 percent more likely to die from lung cancer than people breathing cleaner air (Turner et al., 2011). Fracking will increase this lethal risk.

Fracking adds carcinogens to drinking water. Nationwide, more than a thousand different cases of water contamination have been documented near fracking sites. We draw your attention to one of these: the drinking water wells of Pavillion, Wyoming. An EPA study released just this month confirms the presence of the carcinogen 2-butoxyethanol, a widely used fracking chemical, in the aquifer under Pavillion, which is an intensively drilled community (U.S. Environmental Protection Agency, 2011). Pavillion’s drinking water also contains benzene, naphthalene, and diesel fuel. We are deeply troubled that confirmation of these cancer-causing contaminants comes three years after their initial discovery and in the wake of repeated denials of responsibility by the gas industry. The story of Pavillion reveals not only that drinking water is at risk of chemical contamination from fracking operations but also that swift mitigation of such disasters is far from assured. The wheels of science grind slowly while the lives of people have remained in harm’s way.

We are also troubled by the discovery that drinking water wells located near active gas wells here in the Marcellus region contain methane levels that are 17 times higher than those located near inactive wells (Holzman, 2011; Osborn, Vengosh, Warner, & Jackson, 2011) and by the reports of spiking bromide levels in the rivers of western Pennsylvania that followed discharges of fracking wastewater into sewage treatment plants last spring (Hopey, 2011).While methane and bromide are not suspected carcinogens, they serve as precursors for the creation of trihalomethanes, which can form when water is chlorinated. Trihalomethanes are associated with both bladder and colorectal cancers (Weinberg, Krasner, Richardson, & Thruston, 2002).

Preliminary evidence points to high rates of cancer in intensively drilled areas. In Texas, breast cancer rates rose significantly among women living in the six counties with the most intensive gas drilling (Heinkel-Wolfe, 2011). By contrast, over the same time period, breast cancer rates declined within the rest of Texas. In western New York State – where vertical gas drilling has been practiced since 1821 and has resulted in significant contamination of soil and water – rural counties with historically intensive gas industry activity show consistently higher cancer death rates than rural counties without drilling activity. In women, cancers associated with residence in a historically drilling-intensive county include breast, cervix, colon, ovary, rectum, uterus, and vagina. Men living in the same region are consistently in the highest bracket for deaths from cancer of the bladder, prostate, rectum, stomach, and thyroid (Bishop, 2011), (based on National Cancer Institute cancer mortality maps and graphs, http://www3.cancer.gov/atlasplus/type.html). While these correlations do not prove a connection between abnormally high rates of cancer and gas industry pollution, they do offer clues for further inquiry. We in the cancer advocacy community believe that this inquiry must precede, not trail behind, any decision to bring hydrofracking to New York State. Benefit of the doubt goes to public health rather than to the forces that threaten it.

Fracking operations will undermine New York State efforts to prevent chronic disease. New York State currently funds important projects, such as the Creating Healthy Places To Live, Work and Play programs, many of which are being carried out in rural or small-town communities. Objectives of this initiative include increasing the availability and accessibility of places to be physically active, and creating landscapes conducive to physical activity, such as playgrounds and walking trails. It is clear that the industrialization of the landscape where fracking would occur – with increased truck traffic and reduction in air quality described above – undermines these initiatives. As cancer advocates, we know that regular physical activity lowers the risk for many common cancers. Indeed, the American Cancer Society attributes one-third of all cancer diagnoses to sedentary lifestyles, obesity, and poor diet and thus specifically advocates for land use and urban design that encourages outdoor exercise: “Let’s make our communities safer and more appealing places to walk, bike, and be active” (American Cancer Society). Fracking does the opposite. No one wants to walk, bike, or jog along roads filled with 18-wheelers hauling hazardous materials and filling the air with diesel exhaust. Changes to the built environment that discourage outdoor recreation and promote sedentary behavior will increase our state’s cancer burden and further fan the flames of rising health care costs.

The proposed mitigation strategies set forth in the revised environmental impact statement are insufficiently protective. The revised SGEIS makes no attempt to explicate the possible human health effects that may result from permitting thousands of gas wells within New York State and from filling our roadways with the fleets of trucks that will service them – or to project the monetary costs of these health effects. Rather, the document asserts, axiomatically, that no such health effects will occur because each gas well will be surrounded by a buffer zone that sets it apart from residential areas and public drinking water sources. But set-backs, like non-smoking sections inside airplanes, are imaginary circles that cannot contain volatile, inherently toxic substances when they are released from multiple sources into interconnected environmental media. We all breathe the same air, and we all live downstream. The best science shows us that cancer is the end result of multiple stressors adding together over time to alter the genetic signaling pathways within our cells (President’s Cancer Panel, 2010) When it comes to cancer, the cumulative impact of many small straws is what breaks the camel’s back.

Chemical disclosure requirements, health registries, and after-the-fact biomonitoring programs cannot substitute for due diligence. Disclosing the chemicals used in fracking operations, monitoring human exposures to those chemicals, and establishing registries of those harmed by chemical exposures are useful tools for scientific study and are basic to a transparent, right-to-know democracy, but they do not, by themselves, protect public health. Instead, we need a precautionary, prevention-oriented approach to reducing environmental cancer risk. Drawing on scientific research conducted here in New York and concluding that “… the true burden of environmentally induced cancer has been grossly underestimated,” the 2008-2009 Annual Report of the President’s Cancer Panel, calls on state governments to take action to reduce and eliminate toxic exposures implicated in cancer causation before human harm occurs (President’s Cancer Panel, 2010). To permit a form of fossil fuel extraction that opens countless portals of toxic contamination – upon commencement of the fracking operation and in perpetuity – turns us away from a meaningful approach to cancer prevention.

Governor Cuomo, New York State ranks 11th in highest overall annual incidence cancer rate in the United States at 486.2 cancer diagnoses for 100,000 New Yorkers each year – well above the national average of 455.7 (National Cancer Institute, 2011). We urge to you to improve this situation rather than risk raising our cancer rank further by allowing a carcinogen-dependent industry into our state. Instead, let’s seek a plan of economic development that arises from our state’s venerated identity as a world leader in environmental health – one that is worthy of the passionate labors of its scientists and cancer survivors and that is as elegant and transformational in design as the award-winning Empire State Building itself. The state that can claim America’s tallest green building deserves an energy system to match.

Sincerely,

Sandra Steingraber, Ph.D.
Distinguished Scholar in Residence, Ithaca College
Science Advisor, Breast Cancer Action
Former working group member, National Action Plan on Breast Cancer
Former science advisor, California Breast Cancer Research Program

Lois Gibbs
Love Canal Homeowners Association
Executive director, Center for Health and Environmental Justice

Adelaide P. Gomer, breast cancer survivor
President, Park Foundation

Fran Drescher
President & Visionary, Cancer Schmancer Movement
US Diplomat
President, FranBrand Skincare
The Nanny

Babylon Breast Cancer Coalition

Breast Cancer Action, a national grassroots education and advocacy organization with over 2000 members in New York State

Breast Cancer Coalition of Rochester

Breast Cancer Network of Western New York

Breast Cancer Options

Brentwood/Bayshore Breast Cancer Coalition

Cancer Action NY

Cancer Awareness Coalition

Capital Region Action Against Breast Cancer (CRAAB!)

Great Neck Breast Cancer Coalition

Huntington Breast Cancer Action Coalition, Inc.

I’m Too Young For This! Cancer Foundation

LGBT Cancer Project

New York State Prostate Cancer Coalition

New York State Breast Cancer Network, a statewide network of community-based, survivor-driven breast cancer organizations located in communities stretching from Buffalo to Long Island

Physicians for Social Responsibility, New York City

Physicians for Social Responsibility, Hudson-Mohawk

Physicians Scientists & Engineers for Healthy Energy

SHARE (Self-Help for Women with Breast or Ovarian Cancer)

References

American Cancer Society. Diet and Physical Activity: What’s the Cancer Connection? Retrieved November 11, 2011, from http://www.cancer.org/Cancer/CancerCauses/DietandPhysicalActivity/diet-and-physicalactivity.

Amigou, A., Sermage-Faure, C., Orsi, L., Leverger, G., Baruchel, A., Bertrand, Y., . . . Clavel, J. (2011). Road traffic and childhood leukemia: The ESCALE Study (SFCE). Environmental Health Perspectives, 119(4), 566-572.

Bernstein, L. (2009). Exercise and Breast Cancer Prevention. Current Oncology Reports, 11(6), 490-496.

Birnbaum, L. S., & Fenton, S. E. (2003). Cancer and developmental exposure to endocrine disruptors. Environmental Health Perspectives, 111(4), 389-394.

Bishop, R. E. (2011). Chemical and Biological Risk Assessment for Natural Gas Extraction in New York. Retrieved November 11, 2011, from http://sustainableotsego.org/Risk%20Assessment%20Natural%20Gas%20Extraction-1.htm.

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Colborn, T., Kwiatkowski, C., Schultz, K., & Bachran, M. (2011). Natural gas operations from a public health perspective. Human and Ecological Risk Assessment, 17(5).

Committee Staff for Waxman, H. A., Markey, E.J., and DeGette, D. (2011). Chemicals Used in Hydraulic Fracturing: United States House of Representatives Committee on Energy and Commerce.

Fann, N., Lamson, A. D., Anenberg, S. C., Wesson, K., Risley, D., & B.J., H. (2011). Estimating the National Public Health Burden Associated with Exposure to Ambient PM(2.5) and Ozone (Epub ahead of print). Risk Analysis.

Hanas, J. S., Briggs, G. B., Lerner, M. R., Lightfoot, S. A., Larabee, J. L., Karsies, T. J., . . .Hocker, J. R. (2010). Systemic molecular and cellular changes induced in rats upon inhalation of JP-8 petroleum fuel vapor. Toxicology Mechanisms and Methods, 20(4), 204-212.

Heinkel-Wolfe, P. (2011). Breast cancer rate climbs up: Six counties including Denton have state’s highest incidence rates, August 31, 2011. Denton Record Chronicle. Retrieved from http://www.dentonrc.com/sharedcontent/dws/drc/localnews/stories/DRC_Breast_Cancer_0831.11947df68.html

Holzman, D. C. (2011). Methane found in well water near fracking sites. Environmental Health Perspectives, 119(7), A289.

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Liu, C. C., Tsai, S. S., Chiu, H. F., Wu, T. N., Chen, C. C., & Yang, C. Y. (2009). Ambient exposure to criteria air pollutants and risk of death from bladder cancer in Taiwan. Inhalation Toxicology, 21(1), 48-54.

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NYSDOH Bureau of Environmental Radiation Protection. (2009). Supplemental Generic Environmental Impact Statement on the Oil and Gas regulatory Program Well permit issuance for Horizontal Drilling and High-Volume Hydraulic Fracturing to Develop the Marcellus Shale and other Low-Permeability Gas Reservoirs, NYSDOH Bureau of Environmental Radiation Protection Comments.

NYSDOT. (2011). Transportation Impacts of Potential Marcellus Shale Gas Development: Draft Discussion Paper June 22, 2011.

Osborn, S. G., Vengosh, A., Warner, N., & Jackson, R. B. (2011). Methane contamination of drinking water accompanying gas-well drilling and hydraulic fracturing. Proceedings of the National Academy of Sciences of the United States of America.

Pearson, R. L., Wachtel, H., & Ebi, K. L. (2000). Distance-weighted traffic density in proximity to a home is a risk factor for leukemia and other childhood cancers. Journal of the Air & Waste Management Association, 50(2), 175-180.

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Soto, A. M., & Sonnenschein, C. (2010). Environmental causes of cancer: endocrine disruptors as carcinogens. Nature Reviews Endocrinology, 6, 363-370.

Turner, M. C., Krewski, D., Arden Pope III, C., Chen, Y., Gapstur, S. M., & Thun, M. J. (2011). Long-term ambient fine particulate matter air pollution and lung cancer in a large cohort of never smokers. American Journal of Respiratory and Critical Care Medicine. doi: 10.1164/rccm.201106-1011OC

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The Honorable Andrew M. Cuomo
Governor of New York State
New York State Capitol Building
Albany, NY 12224

Dear Governor Cuomo,

On behalf of the undersigned organizations and health professionals, we are writing with regard to the revised draft of the Supplemental Generic Environmental Impact Statement (SGEIS) on the Oil, Gas, and Solution Mining Program issued in full in September 2011. We are greatly concerned about the omission of a critical issue related to the development of natural gas using high-volume hydraulic fracturing, or “fracking”: human health impacts.

For the reasons detailed below, we believe that the Department of Environmental Conservation (DEC) must correct this oversight in the continued stages of the State Environmental Quality Review Act (SEQRA) process.

Specifically, we request that the draft SGEIS be supplemented to include a full assessment of the public health impacts of gas exploration and production. This should include analysis of the existing documentation of the baseline health status of the New York State population; systematic identification and analysis of direct and indirect health effects; a cumulative health impacts analysis that includes a reasonable “worst case” assessment; and any potential measures to eliminate these impacts.

Notably, a comprehensive assessment of health impacts is likely to include information—such as mounting costs for health care and air and water pollution mitigation—that could inform how DEC and other agencies, such as the Department of Health (DOH), evaluate and assess cumulative impacts and how DEC reviews any proposed gas development permit applications. A comprehensive Health Impact Assessment (HIA) would be the most appropriate mechanism for this work, conducted by an independent entity such as a school of public health. This request is based in part on the fact that the New York DOH is unwilling to perform this function. Please refer to attached communication from Dr. Howard A. Freed, director of the DOH Center for Environmental Health, stating that “another methodology such as Health Impact Assessment would not provide significant additional information that is not already being covered” in the SGEIS. The undersigned disagree with this conclusion because the SGEIS does not, in fact, consider health impacts.

Next, we believe that a comment period of less than 180 days is not acceptable, for either the medical profession or the public. The medical profession was not adequately consulted during the scoping of the SGEIS and had little input into the draft SGEIS. A minimum of 180 days is necessary for health professionals to review and comment on the current draft SGEIS which must be reviewed in its entirety since there is no chapter dedicated to human health. The 96 day comment period which DEC has now proposed is also not enough to afford the public an adequate opportunity to express its concerns about potential health impacts given that DEC is also asking the public to comment on draft regulations during that same time period, and that potentially drill-impacted communities are now facing significant post-Irene challenges.

Finally, we strongly request that an independent health professional be appointed to the High Volume Hydraulic Fracturing Advisory Panel, such as a medical doctor with public health experience.

Our requests are based on the following considerations:

  • According to SEQRA, the DEC has the authority to consider a wide range of impacts related to environmental actions, including public health. In the current situation, the environmental impacts of gas development include air and water pollution and soil contamination, which are clearly established pathways for health impacts.
  • There is established precedent for the inclusion of an HIA in the Environmental Impact Statement process. In 2008, an HIA was completed for the U.S. Bureau of Land Management regarding an oil and gas development proposal in Alaska’s North Slope, and a multi-stage HIA for natural gas development and production has been done in Garfield County, Colorado. New York has the opportunity to set the bar equally high as these other states when it comes to the health of its residents.
  • Former Governor David Paterson’s Executive Order #41 (2010) directing the DEC to undertake further review of high-volume hydraulic fracturing and horizontal drilling specifically cited the need “to ensure that all environmental and public health impacts are mitigated or avoided”.
  • In December 2009, U.S. Environmental Protection Agency Region 2 submitted its comments on the first draft SGEIS. The agency called for “a greater emphasis…on the potential health impacts that may be associated with gas drilling and hydrofracturing.” With this in mind, the agency also suggested that NY’s DOH join DEC as co-lead on the SEQRA process and SGEIS document, which was not done. (See attached letter.)
  • In February 2011, hundreds of physicians, scientists, and organizations representing thousands of health professionals sent a letter to DOH Commissioner Dr. Nirav R. Shah detailing the risks to human health from various stages of the gas development process and urging co-lead status for the DOH in the SGEIS process. (See attached letter.)
  • On May 26, 2011, the NYS Assembly Environmental Conservation and Health Committees jointly held a public hearing on the connection between natural gas development and public health. Testimony by medical professionals and scientists indicated the need for thorough public health investigation before permits for high volume hydraulic fracturing and horizontal drilling are issued. (See attached testimony and letter to you from Committee Chairs Robert Sweeney and Richard Gottfried.)
  • There is a growing body of evidence on health impacts from industrial gas development. In Texas, Wyoming, Louisiana, North Dakota, Pennsylvania, and other states, cases have been documented of worsening health among residents living in proximity to gas wells and infrastructure such as compressor stations and waste pits. Symptoms are wide-ranging, but are typical for exposure to the toxic chemicals and air and water pollutants used in oil and gas development and can often be traced to the onset of such operations. (See attached documents.)

Thank you for your consideration of this information and our requests. We look forward to speaking with you and working together to ensure changes to the SGEIS process that will protect the long-term health and well-being of all New Yorkers.

Sincerely,

(List of signatories attached)

ATTACHMENTS:

  1. Letter to NY DOH Commissioner Dr. Nirav Shah from health professionals (February 5, 2011) with CD of footnoted articles.
  2. DVD of NY State Assembly public hearing on potential health effects of gas drilling (May 26, 2011).
  3. Letter to Governor Cuomo from Assemblymen Robert Sweeney and Richard Gottfried (June 14, 2011).
  4. Letter from EPA Region 2 with comments on the first draft SGEIS (December 30, 2009).
  5. Theo Colborn, Carol Kwiatkowski, Kim Schultz, and Mary Bachran. “Natural Gas Operations from a Public Health Perspective.” International Journal of Human and Ecological Risk Assessment. Accepted for publication; forthcoming 2011.
  6. Earthworks Oil & Gas Accountability Project. Flowback: How the Texas Natural Gas Boom Affects Health and Safety. April 2011.
  7. Dr. Conrad Daniel Volz, DrPH, MPH. Testimony to the U.S. Senate Committee on Environment and Public Works and the Subcommittee on Water and Wildlife, Joint Hearing on “Natural Gas Drilling, Public Health and Environmental Impacts.” April 12, 2011.

SIGNATORIES

Health Professionals

Allan Abramson, MD, Chairman and Professor, Department of Otolaryngology, Hofstra North Shore-LIJ School of Medicine, Hempstead, NY

Judith Abrams, PA, LAc, Trumansburg, NY

Margo Alexander, RN, Trumansburg, NY

David Allyn, Skaneateles, NY

American Academy of Pediatrics District ll (New York State)

Holly McGregor Anderson, RN, BS, Executive Director, Breast Cancer Coalition of Rochester, NY

Suzanne Anderson, MD, Trumansburg Family Heath Center, Trumansburg, NY

Michelle Bamberger, MS, DVM, Veterinarian, Vet Behavior Consults, Ithaca, NY

Delores Bennett, RN, Unadilla, NY

Phyllis Beren, PhD, Psychoanalyst/Child Psychotherapist, New York, NY

Cassia Berman, Medical Qigong Therapist, Woodstock, NY

Paul Bermanzohn, MD, Psychiatrist, Poughkeepsie, NY

Jennifer Bieler, RN, Memorial Sloan Kettering, NYC, NY

Justin Bishop, RN, Schenectady, NY

Ronald Bishop, PhD, CHO, State University of New York at Oneonta, NY

Ellen Bloom, Integrative Medical Network, Lake Katrine, NY

Michael P. Branigan, CRNA, MS, Middlefield, NY

Kelly K. Branigan, RN, Middlefield, NY

Arlene Bregman, DrPH, White Lake, NY

Maureen Brennan Mercier, Saugerties, NY

John Braunius, Mount Vision, NY

Eva F. Briggs, M.D. Family Practice, Ithaca, NY

Roger Brinkerhoff, LCSW, Milanville, PA

Judith Bromley, RN, Olivebridge, NY

Broome County Medical Society

Christopher Brown, LCSW Delhi, NY

Glenda Brown, RN/Benedictine Hospital, Tivoli, NY

Ronald Burakoff, DMD, MPH, White Lake, NY

Peter Burgevin, RN, Trumansburg, NY

Carole Busch, Brooklyn, NY

Drs. Jeffrey and Marybeth Carlberg, Family Practice, Skaneateles, NY

Patricia Carlson, NYS LMT, Ithaca, NY

Jennifer Carroll, MD, MPH, Assistant Professor of Family Medicine and Oncology, University of Rochester Medical Center, Attending Physician, Brown Square Health Center, Rochester, NY

Edgar Charles, MD, Rockefeller University and Manhattan VA Hospital, NYC, NY

Kevin Chatham-Stephens, MD, Pediatrics and Preventive Medicine, Mount Sinai School of Medicine, NY

Lolline Chong, St. Luke’s-Roosevelt Hospital, Astoria, NY

Sheryl Collins BSMT, ASCP, Schenectady, NY

Nancy Cook, Licensed Psychologist, Painted Post, NY

John David Cooke, MD, Family Practice, Trumansburg Family Health Center, Trumansburg, NY

Linda Corshon, Healthcare Consultant, Livingston Manor, NY

Janet Corson-Rikert, MD, Pediatrics and Adolescent Medicine, Ithaca, NY

Ann Costello, MD, Internal Medicine, Ithaca, NY

John Costello, MD, Internal Medicine, Ithaca, NY

Deborah Covi, member of ADHA, Glenford, NY

John A. del Campo, DDS, Alfred, NY

Marcel Crago, Woodstock, NY

Daria B. Crittenden, MD, NYU School of Medicine, Dept of Rheumatology, New York, NY

Jane Crowe, RN, New Springfield, OH

Jonathan E. Cryer, MD, Otolaryngology – Head and Neck Surgery, Ithaca, NY

Margaret Davidson, RN, VNS, Hancock, NY

Lennard Davis, University of Illinois, Department of Medical Education, Bronx, NY

Susan Delone, PhD, Clinical Psychologist, Doylestown, PA

Wendy DeMarzo, Rochester, NY

Roland A. DeSilva, Managing Partner, desilva + phillips, NYC, NY

Dyan Diemer, NYS LMT, NYC, NY

Karen Dipane, RN, Callicoon, NY

Ann Dnistrian, PhD, Laboratory Medicine, South Ozone Park, NY

Robert M. Donius, Clare College Mentor, St. Bonaventure University,St. Bonaventure, NY

Diane Dougherty, RN, Brooktondale, NY

Dr. Christine K. Durbak, Chair and CEO, World Information Transfer, Inc., NYC, NY

Larysa Dyrszka, MD, Pediatrician, Bethel, NY

Padma Dyvine, RN, CHPN, Hospice of Orange and Sullivan Counties, Hurleyville, NY

Kathleen E. Dyman, Executive VP, on behalf of the Medical Societies of the Counties of Oneida, Herkimer, Madison, Chenango, Oswego and Cayuga

Martin Ehrlich, MD, MPH, CAc, Integrative Medicine, Beth Israel Hospital Continuum Center for Health and Healing, NYC, NY

Joan Farber, Clinical Psychologist, NYC, NY

Lisa Fawcett, CSW/psychoanalyst, New York, NY

David Feldshuh, MD, PhD, Emergency Medicine, Cayuga Medical Center, Ithaca, NY

Karen Felker Harrity, RN, Cortland County Health Department, Cortland, NY

Donna Fellenberg, LCSW, Psychotherapist, Callicoon, NY

Philip L. Ferro, MD, Professor, OB/GYN, Director of Family Planning, Associate Director-Residency Program SUNY Upstate Medical University, Syracuse, NY

Donna Flayhan, PhD, Professor, State University of New York at New Paltz, Director, The Lower Manhattan Public Health Project

Christopher Fordice, Research Chemist, Ithaca, NY

William Foresman, MD, President of the Medical Staff, Auburn Memorial Hospital, Auburn, NY

Elaine Frank, CSW, Philadelphia, PA

Jerry Freedner, MD, Valatie, NY

Amy E. Freeth, MD, Attending, Department of Endocrinology; Medical Director, Comprehensive

Diabetes Program; Research Scientist, Bassett Healthcare Network, Cooperstown, NY

Neil Friedman, Institute for Expressive Analysis, Brookyn, NY

Ruth Garbus, Therapist, Woodstock, NY

Sharon Gary, NYS LPT, NYC NY

Carol Gehl, RN, retired, Chippewa Falls, WI

Leon F Gerard, DDS, Boca Raton, FL

Annelise Gerry, Gerry Foundation, Bethel, NY

Margarita Gershik-Gleyzer, LMSW, MA, Orange Regional Medical Center, Bethel, NY

Cindy Gieger, RN, Jeffersonville, NY

Daniela Gioseffi, Retired Professor, Brookyn, NY

Andi Gladstone, Executive Director, New York State Breast Cancer Network

Donald Glauber, PhD, Vestal, NY

Andrew F. Gold, DDS, and Associated Dentists Group, Bronx, NY

Doris Goldberg, MD, MPH, public health physician, Woodstock, NY

Alice Goodman, ASCO POST, Bearsville, NY

Cindy Gordon, MD, Internal Medicine, Dryden, NY

Arnold Gore, Consumers Health Freedom Coalition, New York, NY

David Gould, MD, MBA, Livingston Manor and New York City, NY

John Grant, CSW, Kingston, NY

Alice Grow, RN, Geriatrics and Home Care, Newfield, NY

Savannah Hadler, LMSW, NYC, NY

Adam Hait, RPh, Bethel, NY

Andrew Hall, Colorado Springs, CO

Chad Haller, MD, Ophthalmology, Astoria, NY

Katherine Halton, Willseyville, NY

Sue Hammond, MD, retired, Syracuse, NY

Jay Hanas, Biochemist/Toxicologist, Dundee, NY

Elaine Hardman, Wellsville, NY

Yusuf Harper, MD, Pure Grown LLC, Norwich, NY

Sueane Hemmer Goodreau, ND, RN, CFNP, Ithaca, NY

Barbara H Heywood, Barton, NY

Nedra Hoffman, MPH, NYC, NY

Magdalena D. Hohn, Internal Medicine, Cayuga Medical Center, Ithaca, N.Y

Carol Hornig, Nutritionist, West Hurley, NY

Claire Robinson Howard, MS, ANP-C, NPP, Syracuse, NY 13202

Antony Hsu, MD, Emergency Physician, Ithaca, NY

Julie Huntsman, DVM, Otsego, NY

Susan J Huxtable, MA, CCC-SLP, Speech Language Pathologist, West Winfield, NY

Susan L. Hyman, MD, Developmental and Behavioral Pediatrician, Rochester, NY

Patricia Jacob, Family Nurse Practitioner, Department of Hematology/Oncology, Bassett Medical Center, Cooperstown, NY

Kenneth Jaffe, MD, Slope Farms, East Meredith, NY

Lucia Jander, MD, Ithaca, NY

Janet L. Johnson, MD, Tully Family Practice, Tully, NY

Chris Jones, PA, Beacon, NY

Sarah Kager, RN, Ithaca, NY

Lila Kalinich, MD, Professor of Psychiatry, Columbia College of Physicians and Surgeons, NYC, NY

Past President of the Association for Psychoanalytic Medicine

Fredric Kardon, MD, Internal Medicine, Ithaca, NY

Lee Karr, PhD, Psychologist, Venice, FL

Suzanne Kates, NYS LMT, Ithaca, NY

David Kauber, NYS LMT, Aurora, NY

Mary Alice Keator, MS, LAc, CNC, Rochester, NY

Basia Kielczynska, MS, L.Ac, Beth Israel Medical Center, Staten Island, NY

Connie Kieltyka, CNM, NP, Olivebridge Midwifery PLLC, Olivebridge, NY

Helen Koerner, Livingston Manor, NY

Katrina Smith Korfmacher, PhD, Deputy Director, EHSC Community Outreach and Engagement Core, Assistant Professor, Department of Environmental Medicine, University of Rochester, Rochester, NY

Bonnie Koshofer, Occupational Therapist, Schenectady, NY

Judy Kugelmass, PhD, Special Ed and Counseling, Binghamton, NY

Antoinette Kuzminski, MD, Fly Creek, NY

Karen LaFace, MD, Family Medicine Associates of Ithaca, Ithaca, NY

Robert Laurentz, PsyD, PhD, Clinical Psychologist, Cayuga Medical Center, Ithaca, NY

Adam Law, MD, Endocrinologist, Clinical Assistant Professor, Ithaca, NY

Rosa Lee, Holistic Practitioner, Rock Hill, NY

James Leff, DC, Lyons, NY

Lilly Lei, MD, Bovina Center, NY

Gail Lennstrom, Physical Therapist, Delaware Co Public Health, Margaretville, NY

Eric Lessinger MD, Family Medicine, Hospice and Palliative Care, Ithaca, NY

Rebecca Liddell, RN, Downsville, NY

Sam Liebowitz, Double Diamond Wellness, Inc., New York, NY

Jamie Loehr, MD, Cayuga Family Medicine, Ithaca, NY

Andrea Lomanto, The NY Open Center, NYC, NY

James D Lomax, MD, Bethel, NY

Eric London, MD, Psychiatrist and Autism Researcher, New York, NY

Wendy Lubin, New York University Postdoctoral Program, Bronx, NY

James C. Macmillan, MD, President, Tompkins County Board of Health, Ithaca, NY

Judith Maidenbaum, PhD, Licensed New York State Psychoanalyst, NYC, NY

Terry Major, Skaneateles, NY

Barbara Mancroni, RDH, Rock Hill, NY

Dana Mandel, Lifespan PT, OT, and SLP Services, PLLC, King Ferry, NY

John Manring, MD, Associate Professor of Psychiatry, Director of Psychiatry Residency Training, SUNY-Upstate Medical University, Syracuse, NY

Graham Marks, MAc, Director Acupuncture Clinic/Jones Memorial Hospital, Wellsville , NY

Peter Martin, LMSW, Claryville, NY

Betty Marton, New Paltz, NY

Jonathan Mauser, MD, Cayuga Cardiology, Ithaca, NY

Merle McEldowney, NYC, NY

Nancy McGraw, Public Health Professional, Long Eddy, NY

Ellen M McHugh, MD, Pediatrician, Horseheads, NY

Joy McIlvaine, Nurse Practitioner, NYC, NY

Carol McIntosh, Retired RN, BS, PHN, Oneonta, NY

Susan Mead, Visitng Nurse Service, Ithaca, NY

Mary Menapace, RN, Skaneateles, NY

Michael Messing, DDS, MPH, Copake, NY

Renee E. Mestad, MD, MSCI, Syracuse, NY

Kevin Millar, CRNA, MSN, Owego, NY

Alice Miller, MD, Camillus, NY

Karen Miller, President of Huntington Breast Cancer Action Coalition and Prevention Is the Cure

Susan G. Miller, MD, Internal Medicine, Lansing, NY

Teresa R. Miller, MD, Aurora, NY

Irving Laurice Mintz, MSW, Bio-psycho-social consultant, Staten Island, NY

Gary Mirkin, MD, Pediatrician, Long Island, NY

Christina Mitchell, Certified Healing Touch Practitioner, Walton, NY

Sarah Mitchell, Glen Spey, NY

Susan Moran, Health Professional, Woodstock, NY

Monica Morgan, MD, Department of Emergency Medicine, Ithaca, NY

Lori Anderson Moseman, Ithaca, NY

Amy Moses, LMT, Stone Ridge, NY

Marian Mumford, LCSW, Ithaca, NY

Linda Murphy, RN, Rhinebeck, NY

Ramon JC Murphy, MD, MPH, Professor of Clinical Pediatrics, Mt Sinai Medical Center, NYC, NY

Nurit Nardi, Inner Connection, Highland, NY

Laura Neiman, Psychologist, New York, NY

John Nelson, PhD, CPNP, Nurse Practioner, Livingston Manor, NY

Kaima Nelson-Bowne, LMT, Franklin, NY

Jamie Noeth, Body, Mind and Spirit, Mongaup Valley, NY

Kathleen Nolan, MD, MSL, Bioethics Consultant, Mt Tremper, NY

Mary O’Brien, MD, Columbia University Health Service, NYC, NY

Richard O’Keefe, MD, Columbia University, NYC, NY

Elaine Olshan, Social Services, Smallwood, NY

Robert Oswald, PhD, Biochemistry, Cornell University, Ithaca, NY

Michelle Oswald, Ithaca, NY

Otsego County Medical Society

Lili Packer, RN, COHN, Retired, Catskills, NY

Elizabeth Parker, RN, Tivoli, NY

Sheldon Pasternack, Monticello, NY

Paula Patell, RN, Auburn, NY

Vincent M. Pedre, MD, Clinical Instructor, Mt. Sinai School of Medicine; Medical Director, Pedre Integrative Health, New York, NY

Monica Perrotti, RN, Clinton, NY

Mike Pesci, PA, Syracuse , NY

Rhonda Peterson, MD, Hornell, NY

Physicians, Scientists and Engineers for Healthy Energy

Carol Piciullo, RDH, Laurens, NY

SJ Pike, Federal employee, New York, NY

Beatrice Plasse, MSW, PhD, Columbia University, NYC, NY

Lou Priem, MD, ICU physician, Cooper, NY

Sophia Prybylski, Retired, Prattsville, NY

Joseph Martin Quezada, DPM, AACFAS, Podiatrist, Ithaca, NY

Rose Marie Raccioppi, APOGEE Learning™ Tappan, NY

Dr. Donald Raddatz, Chief, Department of Rheumatology, Bassett Medical Center, Cooperstown, NY

Alice Radosh, Psychologist, Lake Hill, NY

Margaret Rafferty, DNP, MPH, RN, NYC, NY

Leia Raphaelidis, FNP, Ithaca, NY

Sue Rapp, LCSW-R, Vestal, NY

Elizabeth Rappaport, RN, Gardiner, NY

Carol Flamm Reingold, NYS LMT, New York, NY

Jeannette Rice, MSHEd, Rensselaerville, NY

Barbara Rosen, MD, Psychiatrist, OMH, Woodstock, NY

Chris Rosenthal, Harmony Hill Retreat Center, East Meredith, NY

Stacey Rosenzweig, MD, Chestnut Ridge Pediatric Associates, Woodcliff Lake, NJ

Toby Rossman, PhD, Nelson Institute of Environmental Medicine, NYU-Langone Medical Center, Tuxedo Park, NY

Peter O. Rostenberg, MD, Internal Medicine and Public Health, Sherman, CT

Allan B. Rubin, MD, Professor NY Medical College, Nanuet, NY

Renee A. Ryan, MD Family Practice / Urgent Care, Ithaca, NY

Madelon Sann, LCSW, Mental Health Practitioner, New York, NY

Barbara Sarah, LCSW, Third Opinion, Kingston, NY

William R. Sawyer, PhD, D-ABFM, D-ABFE, Toxicologist, Skaneateles, NY

Naomi Schechter, PhD, Psychologist, New York, NY

Cynthia Schnedeker, FNP-C, Occupational Medicine, Ithaca, NY

Peter Schwartz, MD, Ophthalmology / Pediatric Ophthalmology, Ithaca, NY

Diane Schwarzbrott, RN, Huntington Station, NY

Jan Shapiro, RN, Hospice Inc, Wallkill, NY

Joan Sheehan, President, and Margaret Roberts, Program Coordinator, Capital Region Action Against BreastCancer (CRAAB)

Perry Sheffield, MD, MPH, Assistant Professor, Pediatrics and Preventive Medicine, Mount Sinai School of Medicine, New York City, NY

Avni Shetreat-Klein, MD, Rehabilitation Medicine, Assistant Professor, Mt Sinai Hospital, NYC, NY

Maya Shetreat-Klein, MD, Pediatric Neurologist, Clinical Assistant Professor, Albert Einstein College of Medicine, Bronx, NY

Howard Silcoff, MD, Family Medicine, Dryden, NY

Marjory Slobetz, CSW, Brookyn, NY

Susan Soboroff, MD, Ithaca Free Clinic and PNHP, Trumansburg, NY

Irene Soloway, Albert Einstein College of Medicine, New York, NY

Gregg StClair, LAc, MS, St.Clair Family Health, Clifton Park, NY

Sandra Steingraber, PhD, biologist, author, Distinguished Scholar in Residence, Department of Environmental Studies, Ithaca College, Ithaca, NY

Izetta Stern, CSW, NYC, NY

Sally Steedman, Nurse, NYC, NY

Jeff Snedeker, MD, Northeast Pediatrics and Adolescent Medicine, Ithaca, NY

Kenneth R. Spaeth, MD, MPH, Hastings on Hudson, NY

Kathleen Sumner, Collaborative Healing Physical Therapy, Fonda, NY

Wayne E. Sygman, DC, Sygman Chiropractic, Levittown, NY

Carolyn Tavares, RN, Ithaca, NY

Melissa W. Thibault, MD, Physical Medicine & Rehabilitation, Ithaca, NY

Brooke Tinney, Dweller By The Stream Inc., Boiceville, NY

Natasha Tolaram, CSW, Jersey City, NJ

Paul F. Torrisi, MD, Clinical Associate Professor, SUNY Upstate Medical University, Syracuse, NY

Andrea Torrado, MD, Pediatrician, Ithaca, NY

Tompkins County Medical Society

Wayne Tusa, Environmental Risk, New York, NY

William Tyler, MD, retired physician (oncology), Dryden, NY

Marguerite Uhlmann-Bower, Registered Nurse, Herbalist, East Meredith, NY

Mary Jane Uttech, Deputy Public Health Director, Cortland County Health Department, Cortland, NY

Janet Waterston MSW, Queens, NY

Muhammad Wattoo, MD, Internal Medicine, Ithaca, NY

Heather Wdowin, NMD, CA

Laura Weinberg, President, Great Neck Breast Cancer Coalition, NY

Ellen White Weir, Goldpetals, Cooperstown, NY

Jonathan Weiss, MD, Swan Lake, NY

Richard Weiskopf, MD, affiliated with Physicians for Social Responsibility, Syracuse, NY

William Weissman, New York Chiropractic College, Lake Hill, NY

Helene Weissman, Woodstock, NY

Laura Weinberg, President of Great Neck Breast Cancer Coalition

Robin Whelan, retired LTC nurse, Luterville-Timonium, MD

Ben Williams, MPH, George Washington University, Washington, DC and Ithaca, NY

Nena Winand, DVM, PhD, Department of Molecular Medicine, College of Veterinary Medicine, Cornell University, Ithaca, NY

Rebecca Woutersz, LAc, Delmar, NY

Emily Wurth, MPH, Water Program Director, Food & Water Watch

Margo A. Yntema RN, Willseyville, NY

Wendy S. Ziecheck, MD, Internal Medicine, CEO/President: Park 55 Medical Associates, New York, NY

David Zimmerman, MD, NYC, NY

Organizations

Advocates for Cherry Valley, Inc., Lynn Ellen Marsh

Advocates for Morris, Maureen Dill

Advocates for Springfield, Harry Levine

Allegany County Concerned Citizens, Shari Collins

Binghamton Regional Sustainabilty Coalition, Chris Burger

Breast Cancer Coalition of Rochester, Holly Anderson

Capital Region Action Against Breast Cancer (CRAAB!), Margaret Roberts, Program Coordinator

Catskill Citizens for Safe Energy, Bruce Ferguson

Catskill Mountainkeeper, Wes Gillingham

Chenango Community Action for Renewable Energy (C-CARE), Erin Heaton

Church Women United of New York State, Mary Smith

Citizens Campaign for the Environment, Adrienne Esposito

Citizens to Preserve the Character of Skaneateles, Holland C. Gregg

Croton Watershed Clean Water Coalition, Inc, David Ferguson

Coalition to Protect NY (CPNY), Jack Ossont

Coalition to Stop the Minisink Compressor Station, Pramilla Malik

Committee to Preserve the Finger Lakes, Edward Seus

Concerned Citizens of Danby, Gay Garrison RN

Concerned Citizens of Town of Oneonta, Maria McMullen

Concerned Citizens of Ulysses, Michelle Bamberger, DVM

Cortlandt W.A.T.C.H., Susan McDonnell

Damascus Citizens for Sustainability, Barbara Arrindell

Delaware Riverkeeper Network, Tracy Carluccio

Dryden Resource Awareness Coalition, Marie McRae

Earthjustice, Deborah Goldberg, JD, Managing Attorney

Earthworks’ Oil & Gas Accountability Project, Nadia Steinzor

Empire State Consumer Project, Inc., Judy Braiman

Environment New York, Eric Whalen

Environmental Advocates of New York, Rob Moore

Food & Water Watch, Water Program Director, Emily Wurth, MPH

Frack Action, Julia Walsh

Friends of Butternuts, Michele Farwell

Friends of Decatur, Gail Sondergaard

Friends of Vestal, Sue Rapp

Gas Drilling Awareness for Cortland County (GDACC), Sheila Cohen

Gas Free Seneca, Yvonne Taylor

GASLAND, Josh Fox

Grassroots Environmental Education, Patti Wood

Great Neck Breast Cancer Coalition, Laura Weinberg

Groton Resource Awareness Coalition, Sharon Kohkonen

Highland Concerned Citizens, Carol Roig

Huntington Breast Cancer Action Coalition, Prevention Is the Cure, Karen Miller

Keuka Residents Against Hydrofracking, Joe Hoff

Residents Opposing Unsafe Shale-Gas Extraction (ROUSE), Bill Podulka

Marcellus Accountability Project–Tompkins (MAP–Tompkins), Sandy Podulka

Middlefield Neighbors, Kelly Branigan

Neighbors of the Onondaga Nation (NOON), Jack Ramsden

New York Residents Against Drilling (NYRAD), Kevin Millar

New York State Breast Cancer Coalition, Andi Gladstone

Northeast Organic Farming Association of New York, Inc. (NOFA-NY), Lea Kone

New York Public Interest Research Group Fund, Inc., Watershed Protection Coordinator, Cathleen Breen

Otsego 2000, Nicole A. Dillingham, JD

Otsego Neighbors, Julie Huntsman DVM

People for a Healthy Environment, Doug Couchon

Protect Laurens, Kristina W. Turechek

Rabbit Creek Farm, Dyan Hazer-Lombardi

Riverkeeper, Inc, Katherine Hudson, Watershed Program Director

Roseboom Owners Awareness Response (ROAR), Allegra Schecter and Lynn Ellen Marsh

Sanford/Oquaga Area Concerned Citizen’s group (SOACC), Kathy Klopchin

Shaleshock Action Alliance, Sara Hess

Sierra Club Atlantic Chapter, Roger Downs

Sullivan Area Citizens for Responsible Energy Development, Wendy Robinson, JD

Summerhill Gas Action, Shannon Caldwell

Tioga Peace and Justice, Cecile Lawrence, PhD, JD

United for Action, David Braun

Upper Unadilla Valley Association, Larraine McNulty

Westchester for Change, Susan Van Dolsen and Ellen Deixler

Nirav R. Shah, M.D., M.P.H.
Commissioner, New York State Department of Health
Corning Tower
Empire State Plaza,
Albany, NY 12237

Dear Dr Shah,

I am following up on the letter sent to you several weeks ago from a large group of medical doctors, scientists and
other health professionals regarding public health and hydrofracking.

Since we have not had a response, I am re-sending our original letter to you, as well as this summary and additional
signatories we have collected since the letter was sent to you on March 1st. In addition to the individual signatories,
the Physicians for Social Responsibility, National, Washington, DC, have signed this letter since February 28th.

To summarize our requests, we again respectfully ask that the SGEIS on hydraulic fracturing in Marcellus and other
tight shales combined with horizontal drilling be expanded at this time to include human health impacts.

The public health concerns are the following:

  • DOH had inadequate input into the drafting of the SGEIS as it is clear from the contents of that document
    that human health was not addressed adequately;
  • the medical community has had inadequate input; in fact, many physicians are just now learning about hydrofracking;
  • public health hazards of the lifecycle of gas drilling with horizontal hydrofracking were not addressed;
  • the SGEIS contains no health impacts assessment;
  • the potential health impacts may have serious and widespread negative public health consequences;
  • exemptions from federal health laws which would have served to protect public health have not been addressed in the current SGEIS.

We therefore request:

  • involvement of the NYS DOH in all matters concerning gas drilling with hydraulic fracturing in Marcellus
    and other tight shales;
  • co-lead agency status of the DOH with the DEC on the SGEIS, as the EPA recommended, and to consider
    other steps that can be taken to evaluate the risks to public health prior to the State permitting hydraulic
    fracturing;
  • involvement of the medical community, including the many leading research and health institutions within
    NY State in assessing the risks to human health via a comprehensive Health Impacts Assessment, coordinated by the NYS DOH;
  • an expansion of the scope of the SGEIS to include the Health Impacts Assessment;
  • inclusion in the SGEIS of all the exempted provisions of the federal public health and environmental laws.
  • a prohibition of all hydrofracking while a health impacts assessment is being done and the findings reviewed
    by all stakeholders as to whether the risks to human health are worth the gas extracted.

We again respectfully request a meeting to review these necessary measures and will follow up in a week.

Regards,
Larysa Dyrszka, MD

Additional Signatories to Letter for Nirav R. Shah, MD

Physicians for Social Responsibility, National, Washington, DC
Perry Sheffield, MD, Mt. Sinai School of Medicine, New York, NY
Philip J. Landrigan, MD, Dean for Global Health, Mt. Sinai School of Medicine
James E. Cone, MD, Medical Director, World Trade Center Health Registry, New York, NY
Vinod Namana, MSSM MPH, Hicksville, NY
Shruti Kumar, Flushing, NY
Allina Nocon, MPH Student, Mt. Sinai School of Medicine, New York, NY
Mahak Jain, MSBS Student, Mt. Sinai School of Medicine, New York, NY
Prashant Vempati, MSBS Student, Mt. Sinai School of Medicine
Anita Lui, MSBS, Mt. Sinai School of Medicine
Emily Pepyne, Mt. Sinai School of Medicine, New York, NY
J. Legha, NY School of Medicine, New York, NY
Joel Kupferman, Esq., NY Env. Law & Justice Project, New York, NY
Mohanie Sahades, N.Y.C.C.T., Ozone Park, N.Y.
Dr. Pulmer, Columbia University, New York, NY
Lila J. Kalinich, MD, Professor of Psychiatry, Columbia University, New York, NY
Ani Tilozian, Cornell University/Mt. Sinai School of Medicine, New York, N.Y.
Naomi Silberstern, RPH, Registered Pharmacist N.Y., Washington State, Florida 1620 Ave. I, Brooklyn, NY
Jesse Cohen, MD MPH Student, New York, NY
Kathy Kiverson Hecht, Volunteer for MSSM Global Health Training Center, Princeton Jct., NJ
Zoey Luskaris, MPH Hunter Collage/ CBNS Queens College, Brooklyn, NY
Michall Ignot, DO, Candidate NY College of Osteopathic Medicine, Brooklyn NY
Penelope Suero, Mt. Sinai School of Medicine, Brooklyn, NY
Courtney Nagel, MD, Mt. Sinai Hospital, New York, NY
Caitlin O’Brien, MD, Mt. Sinai Hospital, New York, NY
Joseph Truglio, MD, New York, NY
Justine Witzke, MSSM Student, New York, NY
Sweta Patel, MSSM Student, New York, NY
Mansi Mehta, MPH Student, Lake Hiawatha, NJ
Jonathan Jimenez, Mt. Sinai Hospital, Medical Student, New York, NY
Xenia Lynn Teresa Williams, Heartsoul Ekonomia Institute, New York, NY
Temitape Awosogba, Medical Student, Mt. Sinai School of Medicine, NYC, NY
Elena Rohona, Medical Student, Mt. Sinai School of Medicine, Brooklyn, NY
Fred Chyke, Cert. Industrial Hygienist (NYLDEP), Flushing, NY
Bonnie Wifler, Sierra Church, New York, NY
Barry Castleman, ScD Environmental Consultant, Garrett Park, MD
Jonathan Ripp, Associate Director, Global Health Training Center, New York, NY
Teodora Romano
Jamie Zimmerman, Medical Student, New York, NY
Margaret Rafferty, NDNP MPH, New York, NY
Herline Dolce, RN AAS, Brooklyn, NY
Elena Limonile, RN, Brooklyn, NY
Carlos A. Castro, RPA-C Mt. Sinai/ MMSc Physician Assistant, MPH Student, Jackson Heights, NY
Ramon Murphy, MD, Mt. Sinai Hospital, New York, NY
Nedra Huffman, MPH, New York, NY
Dr. Judith Hodge, DVM, MPH Candid. NYU Master Global Public Health Program, New York, NY
Torian Easterlina, MD, Mt. Sinai Medical Center, New York, NY
Michael R. Dillon, PhD, AAIDD, New York, NY
Marie Park, Retired Scientist, New York, NY
Loraine O’Neil, RN MPH, New York, NY
Santish Niraula, MD, MBBS, Tribhuvan University, Staten Island, NY
Lauren Peccoralo, MD, MSSM, ABM, New York, NY
Shreedhar Paudel, Mt. Sinai School of Med., Staten Island, NY
Anna Koulova, New York Medical College, Bronx, NY
Antoinette Kuzminski, MD, Fly Creek, NY
Joseph Gilbert, MSSM MPH Student, Astoria, NY
Arlene Bregman, DrPH, Bethel, NY

Additional signatories, added May 2011
Shaleshock Action Alliance (Sara Hess)
Westchester for Change (Susan Van Dolsen)

The following group of physicians are residents of, and practice in Sullivan County, NY
IA Shahid Chouhdry, MD
Michael Siegel, MD
Amasit Gill, MD
Erie Agustin, MD
Shu Chu, MD
Arthur Goldstein, MD
Scott Morgan, MD
Dreher Patel, MD
Camille Irvelyne, MD
Julie Steiner, MD
Hussein Omar, MD
Barry Scheinfeld, MD
W Sidorowicz, MD
Darshman Trivedi, MD
Clifford Teich, MD
Dr Zipparo
Cherif Makram, MD
Renu Seth-Jerath, MD
David Schwalb, MD
Umhey & Raspa, MD, PC

Additional signatories:
Julia Parete, NP Adult and Women’s Health, Ithaca, NY
Jessica Ernst B.Sc., M.Sc., President Ernst Environmental Services, Rosebud, Alberta, Canada
Bob Stuart, Spiritwood, SK, Canada

Nirav R. Shah, M.D., M.P.H.
Commissioner, New York State Department of Health
Corning Tower
Empire State Plaza,
Albany, NY 12237

Dear Dr. Shah:

Congratulations on your appointment as Commissioner of New York State’s Department of Health. We wish you much success in this important position.

Physicians, researchers and other representatives of the undersigned organizations would appreciate the opportunity to meet with you on an issue we believe is the most pressing health issue confronting our State. This is the near-term prospect of massive unconventional gas drilling in upstate New York and its potential for significant adverse impacts on the health of citizens throughout the State. We would like to discuss this issue and the pivotal role that the DOH must play in the consideration and study of the health impacts of unconventional gas drilling.

The NYS Department of Environmental Conservation is in the process of revising its draft “Supplemental Generic Environmental Impact Statement” (the “dSGEIS”) regarding the new technology of “high water volume horizontal fracturing” (“hydraulic fracturing”). The potential health impacts associated with the life-cycle of hydraulic fracturing were almost completely overlooked in the dSGEIS despite numerous reports of health-related concerns in other parts of the country where hydraulic fracturing is on-going (1). Over 13,000 comments were submitted to the DEC regarding the dSGEIS. Concerns about the health impacts of hydraulic fracturing were a recurrent theme as was the fact that no cumulative impact study has been undertaken. Our regional office of the EPA, for example, concluded that “potential impacts to human health and the environment…warrant further scientific and regulatory analysis,” expressing particular concern about local and regional air quality, water quality and radioactive materials disturbed during drilling (2).

It is estimated that tens of thousands of wells would be drilled in New York State (as well as in neighboring Pennsylvania). It is important to note that drilling proponents claim that gas extraction activities are afforded a unique exemption under State law from local zoning laws so as to be situated anywhere; as such, this industrial activity can be sited not just in industrial areas but also in residentially and agriculturally zoned areas, in our State’s watersheds and food sheds– literally in backyards and schoolyards.

Each well and each fracturing cycle requires 3-9 million gallons of fresh water mixed with thousands of pounds of chemicals (10,000 gallons of chemicals per million gallons of water), many of them known neurotoxins, carcinogens and endocrine disruptors. Estimates are that 50-95% of the fracking fluids are permanently left underground where, over time, they may migrate to contaminate ground water and aquifers (3). Fluids that are returned to the surface are contaminated with the fracturing chemicals and the “brines” from the gas bearing layers that may contain, among other things, naturally occurring radioactive substances and heavy metals (4). Dr. Theo Colborn, a renowned environmental health analyst, has listed many of the chemicals on the website of The Endocrine Disruption Exchange and provides evidence of the possible health effects of some of the chemicals that drillers/frackers have disclosed they are using (5). And just last month, investigators from a House Energy Committee announced that diesel fuel, containing benzene, toluene and other BTEX compounds, were extensively used in hydraulic fracturing operations in 19 states despite an industry pledge not to do so. The US Department of Health and Human Services and private research have recognized that the BTEX compounds can lead to brain, respiratory, and kidney damage (6).

Moreover, the processing of gas at the drill site and at compressor stations generates significant air pollution. Volatile organic compounds, BTEX, NOx, PAHs and H2S, and other HAPs are routinely released into the atmosphere. Al Armendariz, now EPA’s Region 6 Regional Administrator, documented the amounts of air polluting fugitive gases
from the hydraulic fracturing in the Barnett Shale near the Dallas/Fort Worth Area. (7). The health impacts of these emissions are potentially enormous and, of course, affect populations both near the extraction activity as well as “downwind” (1) (8).

Risks to human health are therefore present at every step of the gas extraction process. These include possible contamination of drinking water sources through surface spills, well casing failures, blowouts, and other events, migration of drilling and fracking fluids, during drilling or fracking or over time to ground water sources and aquifers through naturally occurring fissures, well blow-outs and well casing failures (9), noise and VAD (Vibro-Acoustic Disease) (10), radioactive contamination (11) and air contamination by emissions from venting, pipeline leaks, compressor stations and the intense truck traffic required over each well’s life-cycle (12).

Despite these known hazards, the oil and gas industry is exempt from important provisions of the Safe Drinking Water Act, the Clean Air Act, the Clean Water Act, and other federal environmental laws. The absence of federal regulatory oversight has left it up to individual states to regulate this industry and adequately enforce those regulations.

In the opinion of many, shale gas extraction employing the current technology has the potential to compromise the
quality of our water and air for decades to come. It also has the potential to significantly and negatively impact the health of our citizens, especially those with respiratory ailments, the elderly, infants and children, pregnant women and their unborn children. Expressing concern, the Medical Society of the State of New York recently adopted a resolution calling for a moratorium on natural gas extraction using hydraulic fracturing until valid information is available to evaluate the process for its potential effects on human health and the environment (13). The NYS Chapter of the American Academy of Pediatrics supported a moratorium on gas drilling pending further studies (14). Dr. ChathamStephens of The Mt Sinai Children’s Environmental Health Center recently testified before the NYC Council expressing serious concerns that children’s health will be adversely impacted by gas drilling (15). And just this week, the Board of Trustees of Basset Medical Center issued a statement calling hydrofracking “a public health issue of the highest priority” and urging the DOH to work with the DEC to fulfill DOH”s “historic responsibility” to protect public health (16).

New Yorkers are fortunate that our leaders have pressed the “pause” button on the commencement of hydraulic fracturing activities. Governor Paterson ordered a SGEIS prior to the permitting of hydraulic fracturing and, before leaving office, issued Executive Order 41 ordering the DEC to revise the draft SGEIS and hold a second public comment period. Governor Cuomo signed a continuation of this important order. Yet, to our knowledge, the DOH has not been an involved agency of any significance on this matter.

We are now at a crossroads –to include a rigorous discussion and investigation of the public health issues as they will be affected by unconventional natural gas extraction or face the potential consequences for years and decades to come. We believe that DOH must be an essential player in this process. Only the DOH has the expertise–and mandate–to assure that public health is not endangered by the commencement of hydraulic fracturing in New York. The DOH was also delegated primary enforcement responsibility for the Safe Drinking Water Act by EPA. We therefore urge the DOH to secure co-lead status with the DEC on the dSGEIS, as the EPA recommended, and to consider other steps that can be taken to evaluate the risks to public health prior to the State permitting hydraulic fracturing.

Footnoted are several papers that we believe will be of interest. Representatives of the health community would like to schedule a meeting with you at your earliest convenience to discuss this matter further. Please contact Dr. Larysa Dyrszka if you have any further questions at this time as well as to schedule the aforementioned meeting.

Thank you for your consideration. We look forward to your response.

Sincerely,

Medical and Scientific Societies, Organizations and Professionals

Allied Pediatrics of New York, LLC, Gary Mirkin, MD, CEO (75+ pediatricians), Long Island/Queens, NY
American Academy of Pediatrics District II
Donna Bacchi, MD, MPH, Chair, Department of Public Health and Preventive Medicine, Director, CNYMPH Program, SUNY Upstate Medical University
Michelle Bamberger, MS, DVM, Veterinarian, Ithaca, NY
Claire L. Barnett, MBA, Founder and Executive Director, Healthy Schools Network, Inc
Paul Bermanzohn, MD, Ulster County, NY
Ronald Bishop, PhD, CHO, State University of New York at Oneonta
Sarah Buckley, RN, critical care nurse, founder of Wales POWR (Protecting Our Water Rights)
Broome County Medical Society
Theo Colborn, PhD, President, The Endocrine Disruption Exchange
Cortland County Board of Health
Daria Barrett Crittenden, MD, New York, NY
Nicholas Cunningham, MD, Dr P.H., Pediatrician and Public Health Physician, Springfield, NY
Douglas DeLong, MD, Chief, Division of General Internal Medicine, Bassett Healthcare Network
Larysa Dyrszka, MD, Pediatrician, Bethel, NY
Joan C. Farber, PhD, clinical psychologist (retired), New York, NY
Clare Fewtrell, D.Phil., Associate Professor of Pharmacology, College of Veterinary Medicine, Cornell University
Donna Flayhan, PhD, Director, The Lower Manhattan Public Health Project; Professor, State University of NY at New Paltz
Amy E. Freeth, MD, Attending, Department of Endocrinology; Medical Director, Comprehensive Diabetes Program; Research Scientist, Bassett Healthcare Network, Cooperstown, NY
Sueane Hemmer Goodreau, ND, RN, CFNP, Ithaca, NY
David Gould, MD, MBA, New York, NY
Eileen Hoffman, MD, FACP, Clinical Associate Professor of Medicine, NYU School of Medicine
Robert W. Howarth, PhD, The David R. Atkinson Professor of Ecology and Environmental Biology at Cornell University
Susan Hyman, MD, FAAP, Developmental Pediatrician, Rochester, NY
Anthony R. Ingraffea, PhD, PE, Dwight C. Baum Professor of Engineering; Weiss Presidential Teaching Fellow, Cornell University
Kenneth Jaffe, MD, Slope Farms, Meredith, NY
William Klepack, MD, Dryden Family Medicine, Dryden, NY
Bruce G. Kornreich, DVM, PhD, DACVIM (Cardiology), Senior Research Associate, Department of Clinical Sciences, NYS College of Veterinary Medicine, Cornell University
Adam Law, MD, Endocrinologist, Ithaca, NY
Robin R. Leger, RN, MS, PhD
Eric London, MD, Psychiatrist and Autism Researcher, Harris, NY
Judith Maidenbaum, PhD, Psychoanalyst, New York, NY
Mary Menapace, RN, Women’s Services, Upstate Medical University, Syracuse, NY
Mt. Sinai Global Health Training Center, Natasha Anushri Anandaraja, MD, MPH, Director
Mt. Sinai School of Medicine Children’s Environmental Health Center, Philip Landrigan, MD, MSc, Director; Ethel H. Wise Professor and Chairman, Department of Preventive Medicine; Professor of Pediatrics; Dean for Global Health Bola Omotosho, MD, Bronx, NY
Robert E. Oswald, PhD, Professor of Molecular Medicine, Cornell University
Vincent M. Pedre III, MD, Integrative & Preventive Medicine; Medical Director, Pedre Integrative Health; Clinical Instructor, Mount Sinai School of Medicine
Nina Pesante, MD, Vestal, NY
Peter Rostenberg, MD, Public Health Director, retired; Steering Committee, Highland Coalition
Stanley N. Salthe, PhD, Professor Emeritus Biology, City University of New York; Deposit, NY
William R. Sawyer, PhD, D-ABFM, D-ABFE, TCAS Toxicology Consultants and Assessment Specialists, LLC, Skaneateles, NY
Stephen S. Schneider, DDS, Oral & Maxillofacial Surgeon, Deposit, NY
Nadia Shmigel, LCSW, New York, NY
Ted Schettler, MD, MPH, Science and Environmental Health Network
Kenneth R. Spaeth, MD, MPH, Director, Occupational and Environmental Medicine Center; Director of Education, Department of Population Health, North Shore University Hospital, Hofstra School of Medicine, NY
Sandra Steingraber, PhD, Ithaca College, Ithaca, NY
Jeanne Mager Stellman, PhD, Professor Emerita & Special Lecturer, Mailman School of Public Health, Columbia University; Professor of Environmental & Occupational Health Sciences and Professor of Neurology, SUNY-Downstate Medical Center
Daniel Thau Teitelbaum, MD, Colorado
Tompkins County Medical Society
Gregory A. Weiland, PhD, Associate Professor of Pharmacology, Department of Molecular Medicine, College of Veterinary Medicine, Cornell University
Wayne G. Whitmore, MD, FACS, New York, NY
Nena J. Winand, DVM, PhD, Groton, NY
World Information Transfer, Inc, Dr. Christine K. Durbak, Chair and CEO

Community and Environmental Organizations

Advocates for Cherry Valley, Inc. (Lynne Marsh)
Advocates for Springfield (Harry Levine)
Binghamton Regional Sustainability Coalition (Chris W. Burger)
Catskill Citizens for Safe Energy (Bruce Ferguson)
Catskill Mountainkeeper (Kathleen Nolan, M.D., MSL)
Chenango Community Action for Renewable Energy (Erin Heaton)
Chenango Delaware Otsego Gas Drilling Opposition Group
Citizens Energy and Economics Council of Delaware County
Coalition to Protect New York (Jack Ossant and Kate Bartholomew)
Community Environmental Defense Council, Inc. (David Slottje, J.D.)
Concerned Citizens of Ulysses (Michelle Bamberger)
Croton Watershed Clean Water Coalition, Inc. (Fay Muir)
Damascus Citizens for Sustainability (Barbara Arrindell)
Delaware Action Group (Caroline Martin)
Delaware Riverkeeper Network (Tracy Carluccio)
Earthworks Oil & Gas Accountability Project (Nadia Steinzor)
Food & Water Watch (Eric Weltman)
Frack Action (Claire Sandberg)
Frack Action Buffalo (Patricia Carson)
Friends of Vestal (Sue Rapp)
Gas Drilling Awareness Coalition (Tom Juinta, D.P.M.)
Gas Drilling Awareness for Cortland County (Sheila Cohen, Ed.D.)
Highland Concerned Citizens (Debra Conway)
Homestead School Green Power Alliance (Peter Comstock)
Landowners Against Natural-gas Drilling (Teresa Winchester)
Lexington Cooperative Market–Buffalo (Tim Bartlett)
Lumberland Concerned Citizens (Peter Comstock)
Marcellus Accountability Project for Tompkins County (Bill and Sandy Podulka)
Neighbors of the Onondaga Nation (Jack Ramsden)
New York Residents Against Drilling (Kevin Millar)
Northeast Organic Farming Association of New York (Lea Kone)
NYH2O (Joe Levine)
Otisco Lake Preservation Association (Anita Williams)
Otsego County Conservation Association (Martha Clarvoe)
Otsego 2000 (Nicole Dillingham, J.D.)
Park Slope Food Coop (Jess Robinson)
People for a Healthy Environment, Inc. (Frank Patterson)
Residents Opposing Unsafe Shale-Gas Extraction (Bill Podulka)
Sierra Club Atlantic Chapter (Rachel Treichler, J.D.)
Skaneateles Lake Association (Mary Menapace)
Sullivan Alliance for Sustainable Development (Dick Riesling)
Sullivan Area Citizens for Responsible Energy Development (Karen London, J.D.)
Sustainable Otsego (Ron Bishop, Ph.D., CHO)
The Basha Kill Area Association, Inc. (Paula Medley)The Committee to Preserve the Finger Lakes (Melanie Steinberg)
The Finger Lakes Group of the Atlantic Chapter of the Sierra Club (Kate Bartholomew)
Tioga Peace and Justice (Cecile Lawrence, J.D., Ph.D.)
United for Action (Owen Crowley)

Notes:

  1. Potential Exposure-Related Human Health Effects of Oil and Gas Development: A Literature Review (2003-2008), Colorado School of Public Health, University of Colorado Denver (August 1, 2008). Also Witter power point presentation, and Witter white paper 2010 Health Impact Assessment for Battlement Mesa, Garfield County, Colorado (2010) .
  2. Comment letter of the EPA, Region 2, dated December 30, 2009 to NYSDEC Division of Mineral Resources and Otsego 2000 2010 comments to the EPA.
  3. “Final Impact Assessment Report: Impact Assessment of Natural Gas Production in NYC Watershed,” Hazen and Sawyer Environmental Engineers and Scientists, December 2009, page 57; and Statement of James L. Northrup, former ARCO Planning Manager, to Otsego County Board (July 21, 2010); and Power point by Professor Tony Ingraffea from http://www.otsego2000.org/ The Facts about Shale Gas Drilling in New York State Unatego, NY, 10/6/2010 and Chemical and Biological Risk Assessment of Natural Gas Extraction in New York by Ron Bishop, SUNY Oneonta and Sustainable Otsego
  4. http://un-naturalgas.org/resources_and_documents.htm -> DEC’s dSGEIS download page see chapter 5 (chemicals) and appendix 13 (NORMs) and http://www.nytimes.com/2011/02/27/us/27gas.html?_r=1&hp with additional references here http://www.nytimes.com/interactive/2011/02/27/us/natural-gas-documents-1-intro.html?ref=us
  5. http://endocrinedisruption.com/chemicals.multistate.php (2011) and http://endocrinedisruption.com/files/NaturalGasManuscriptPDF09_13_10.pdf Video also available at www.endocrinedisruption.com.
  6. http://www.nytimes.com/2011/02/01/business/energy-environment/01gas.html?src=me&ref=business; industry reply: http://www.chron.com/disp/story.mpl/business/energy/7406933.htmlhttp://hinchey.house.gov/index.php?option=com_content&view=article&id=1556:hinchey-holt-urge-drbcto-suspend-hydrofracking-rulemaking-process&catid=71:2011-press-releases and this about the investigation: http://democrats.energycommerce.house.gov/index.php?q=news/waxman-markey-and-degetteinvestigation-finds-continued-use-of-diesel-in-hydraulic-fracturing-f
  7. Armendariz, A. Emissions from Natural Gas Production in the Barnett Shale Area and Opportunities for Cost Effective Improvements (January 26, 2009).
  8. London, E. Comments to the EPA regarding the impacts of toxic emissions from natural gas extraction activities September 27, 2010.
  9. see “exploratory” well papers http://www.damascuscitizens.org/DRBC-HEARING.html and http://www.scientificamerican.com/article.cfm?id=wastewater-sediment-natural-gas-mckeesport-sewage and http://www.vanityfair.com/business/features/2010/06/fracking-in-pennsylvania-201006 and from the University of Pittsburgh School of Public Health http://www.fractracker.org/2010/09/water-wellcontamination-studies.html and NRDC’s Amy Mall’s report on cases of water contamination http://switchboard.nrdc.org/blogs/amall/incidents_where_hydraulic_frac.html
  10. http://teeic.anl.gov/er/oilgas/impact/drilldev/index.cfm and comments to the NYS DEC on the scoping of the dSGEIS 12/2/2008 by Kristina Turechek and a medical article on noise and VAD
  11. USGS and NORMs and a NYSDOH commentary on the dSGEIS of 7/21/2009 from http://63.134.196.109/documents/10sep28_Otsego2000EPACommentsFINAL.pdf and Resnikoff et al’s report on Radioactivity in the Marcellus Shale of 5/19/2010 and a Scientific American article on radioactivity in wastewater 11/9/2009 and Radioactive Waste in Horizontal Hydrofracking by James L. “Chip” Northrup, September 20, 2010 from http://www.otsego2000.org and comments by the NYS Conference of Environmental Health Directors on SGEIS and http://www.nytimes.com/2011/02/27/us/27gas.html?_r=1&hp with additional references here, and an article by David Lewis with additional embedded links
  12. Dr Eric London’s comments to the EPA and Dr Robert Howarth’s article on GHG Emissions from Nov 2010 and updated Jan.26, 2011 and a recent (2010) technical paper from the EPA on GHG emissions from natural gas development and a report on H2S emissions health and an article from the San Antonio Current on health issues from gas emissions and this about formaldehyde in air emissions in Texas from HARC.edu
  13. http://gdacc.wordpress.com/2010/12/10/new-york-state-medical-societies-call-for-moratorium
  14. NYS AAP on a moratorium, see http://gdacc.wordpress.com/medical-professionals-information/
  15. Mt Sinai Children’s Environmental Health Center comments to the EPA
  16. http://www.damascuscitizens.org/BASSETT_MEDICAL_CENTER_BOARD_OF_TRUSTEES_STATEMENT.pdf